Who we are: We are Halliwell Jones (the “Company” or “we” or “us”). This privacy policy applies to all companies within the Halliwell Jones group of companies, including the following associated companies registered in England and Wales:
Halliwell Jones Limited (including its trading division Premium Trade Cars)
Company number: 02043705
59/61 Southport Road
Southport
Merseyside
PR8 5JF
____
Halliwell Jones (Chester) Limited (including its trading division Halliwell Jones Chester Motorrad)
Company number: 02665815
Sealand Road
Chester
Cheshire
CH1 4LS
____
Halliwell Jones (Warrington) Limited
Company number: 03323081
Winwick Road
Warrington
Cheshire
WA2 8HY
____
Halliwell Jones (North Wales) Limited
Company number: 01266292
BMW Dealers
Ffordd Maelgwyn
Tremarl Industrial Estate
Llandudno Junction
Gwynedd
LL31 9PL
____
Halliwell Jones (Wilmslow) Limited
Company number: 00398803
130 Manchester Road
Wilmslow
Cheshire
SK9 2LE
____
Halliwell Jones (Wilmslow) Bodyshop Limited
Company number: 02575743
130 Manchester Road
Wilmslow
Cheshire
SK9 2LE
____
Halliwell Jones Deva Ltd
Company number: 13917978
Knutsford Road
Chester
CH1 4NS
____
and any holding company or subsidiary of such companies. Any reference to the “Company”, “we” or “us” refers to this group of companies – or where intended to identify the data controller of any personal information, will refer to the group company to whom you provided your information, which will be made clear on any sales paperwork, website sign-up form or other documentation.
The Company and personal information: we are committed to lawful, fair and transparent processing of all personal information about our employees, customers, suppliers and other third parties during the course of our business activities. We will always comply with any applicable data protection legislation and we will ensure that collection and use of personal information is carried out in accordance with applicable data protection laws. The main law governing data protection is the General Data Protection Regulation (Regulation (EU) 2016/679 of 27 April 2016) known as the “GDPR”.
What this policy is: This policy (and any other documents referred to in it, together with any privacy notice displayed on our website) sets out the basis on which we will process any personal information about you or individuals generally - whether it’s information we collect from those individuals or that is provided to us from other sources. This policy sets out rules on data protection and the legal conditions that must be satisfied when we obtain, handle, process, transfer or store personal information.
Registration: While the Data Protection Act 1998 requires us to be registered with the Information Commissioner’s Office, we will remain registered. We will also comply with any successor notification requirements.
Controlling and processing information: We are the controller of all personal information used in our business for our own commercial purposes. Sometimes though, we will process personal information on behalf of another data controller – and when this is the case, we will do so only in accordance with the instructions of that data controller and otherwise in accordance with the GDPR.
Why you should read this policy: It is important that you read this policy, together with any other documents referred to in it, so that you are aware of how any personal information relating to you will be dealt with by us.
DATA PROTECTION PRINCIPLES
We are accountable for demonstrating compliance with the GDPR’s six principles of processing personal information. These provide that personal information we deal with must be:
SOME BASIC DEFINITIONS WE USE IN THIS POLICY
Personal information: In this policy, when we use the term “personal information” we mean any information relating to an identified or identifiable human being. (An “identifiable natural person” is one who can be identified, directly or indirectly, for example, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, biometric, mental, economic, cultural or social identity of that person).
Sensitive personal information: In this policy, when we use the term “sensitive personal information” we mean special categories of information which are personal information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying someone, data concerning health or data concerning a someone’s sex life or sexual orientation.
THE KIND OF PERSONAL INFORMATION WE HOLD ABOUT YOU
We may collect, record, organise, structure, store, adapt, alter, retrieve, consult, use, disclose by transmission, disseminate or otherwise make available, align or combine, restrict, erase or destroy the following types of personal information about you:
We may also collect, store and use the following sensitive personal information:
HOW IS YOUR PERSONAL INFORMATION COLLECTED?
In the course of our business, we may collect personal information directly from an individual:
We may also collect personal information about individuals from other sources such as:
We will only collect personal information to the extent that it is required for the specific purpose notified to individuals about whom we are collecting it - and we will keep it only as long as is necessary.
HOW WE WILL USE PERSONAL INFORMATION
We will only use personal information when the law allows us to do so and relying on a relevant basis for lawful processing in each instance. We will use your personal information in the following circumstances, relying on the basis of processing indicated:
Basis of processing: Where we need to perform a contract we are about to enter into or have entered into with you.
Basis of processing: Where it is necessary for our legitimate interests (or those of a third party, such as any finance house or manufacturer on whose behalf we are processing data) and we have undertaken an assessment to determine that processing for those interests (listed below) does not outweigh your interests and fundamental rights, considering the nature and impact of the processing and any relevant safeguards we can put in place.
Basis of processing: Where we need to comply with a legal or regulatory obligation.
Basis of processing: Where you have consented to the processing.
Other issues about how we use personal information:
DIRECT MARKETING
As indicated above, we may use your personal information to provide you with information about goods and services which may be of interest to you and we may contact you about these by post, email, text or telephone. This is known as direct marketing.
Examples of direct marketing may include:
We will only process personal information for the above purposes with your specific consent. You have the right to withdraw this consent at any time. Information about how to withdraw your consent is set out below.
We may also disclose your information to third parties (including associated companies, as this term is explained at the start of this policy), and any marketing agencies or goods manufacturers for the purpose of direct marketing. Again, we will only do this with your explicit consent and you have the right to withdraw this consent at any time. Information about how to withdraw your consent is set out below.
CONSENT
In this Policy, where we need your consent, we will make sure that the consent:
HOW WE USE SENSITIVE PERSONAL INFORMATION
Protection for sensitive personal information: Processing of sensitive personal information requires higher levels of protection. We may process sensitive personal information about an individual in the following circumstances:
Specific sensitive personal information we process and why we are allowed to do this:
Where an individual has explicitly consented:
AUTOMATED DECISION-MAKING
Automated decision-making takes place when an electronic system uses personal information to make a decision relevant to you without human intervention.
We do not envisage that we will use any automated means to make decisions about you, however we will notify you in writing if this position changes.
DATA SHARING
Transfer of personal information outside of the EEA: We may transfer certain personal information that we hold on individuals living in the European Union to a country outside the European Economic Area ("EEA"), provided that one of the following conditions applies:
Subject to the requirements set out above, the personal information we hold may also be processed by individuals operating outside the EEA who work for us or for one of our suppliers. Those individuals may be engaged in, among other things, the fulfilment of contracts with the relevant individual, the processing of payment details and the provision of support services.
Safeguards: If we use a third party data processor to process personal information on our behalf, we will obtain contractual commitments to safeguard the security of the personal information to ensure that the third party only acts on our instructions when using that personal information and that the third party has in place appropriate technical and organisational security measures to safeguard the personal information. Whenever we transfer your personal information out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal information outside the EEA.
Why we might share your personal information with third parties: We may share personal information we hold with any of our associated companies (which term is described at the start of this policy). We may also disclose personal information we hold to third parties if we are under a duty to disclose or share an individual’s personal information in order to comply with any legal obligation, or in order to enforce or apply any contract with that individual or other agreements; or to protect our rights, property, or safety of our employees, customers or others. This includes exchanging personal information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
We may share personal information with other of our associated companies as part of our after-sales service and repeat sales activities. When appropriate, we will anonymise personal information when used for performance reviewing and reporting activities.
We may also share personal information we hold with selected third parties for the purposes set out below.
Third party service providers who may process your personal information: When we use the term “third party”, we mean any entity who is not one of the associated Halliwell Jones companies listed at the start of this policy, including third party service providers and contractors. The following third party service providers may process personal information for the following purposes:
Finance houses |
To engage finance houses to finance your purchase or hire of our vehicles |
Insurance providers |
To arrange insurance on vehicles you may test drive, lease and/or purchase from us |
Software providers/IT support |
Certain of our IT providers have access to our systems in order to manage and maintain our systems and ensure everything is secure and up to date |
Security providers for CCTV and related services |
We engage security providers at our premises to protect our customers and staff |
Marketing agencies |
To manage any promotional communications and/or customer offers on our behalf |
Digital advertisers and analytics providers |
To analyse usage of our website(s) and the demographic of our customer base in order to ensure we provide appropriate services |
Motability |
To advise on and process applications relating to any mobility allowance for leasing vehicles suited to your disability |
Car park and toll bridge operators |
Where we receive, manage and pay fines raised by such persons relating to vehicles in your possession or control |
Where we are acting as a data processor on behalf of someone else, we will process your data as they ask us to do so and they will be responsible for deciding how it is used. You will know who that data controller is because they should advise you that we are acting on their behalf. We also share personal information where we have a legal obligation to do so, such as with the DVLA and HMRC.
DATA SECURITY
We will always take appropriate technical and organisational measures to protect personal information against accidental or unlawful destruction or accidental loss, alteration, unauthorised disclosure or access, in particular where the processing involves the transmission of data over a network, and against all other unlawful forms of processing (including taking reasonable steps to ensure the reliability of employees who have access to personal information). Our employees may only process personal information in accordance with this privacy policy, and any employee who breaches this privacy policy may be subject to disciplinary action, up to and including dismissal.
We have put in place internal procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
DATA RETENTION
We will not keep personal information in a form which permits identification of individuals for longer than is necessary for the purpose or purposes for which they were collected. We will take all reasonable steps to destroy, or erase from our systems, all data which is no longer required. To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of personal information, the purposes for which we process information and whether we can achieve those purposes through other means, and the applicable legal requirements.
We will only keep personal information for as long as is necessary for the purpose or purposes for which that personal information is processed; and we will let anyone about whom we process data know how long that is or the criteria that go into deciding how long that is.
We may sometimes anonymise your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Our website may, from time to time, contain links to and from the websites of partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies or the security of these websites. Please check the relevant policy before you submit any personal information to these websites.
YOUR RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal information, as summarised below.
You have the right to:
If you wish to exercise any of the rights set out above, please contact us at [email protected] or contact our ICO as detailed below. We aim to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive - alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask for further information in relation to your request to speed up our response.
COOKIES
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or device if you agree. Cookies contain information that is transferred to your computer or device. We use the following cookies:
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
Name |
Purpose |
Duration |
_gat |
This cookie name is associated with Google Universal Analytics, according to documentation it is used to throttle the request rate - limiting the collection of data on high traffic sites. It expires after 1 minute.
|
1 minute |
_gid |
This cookie name is associated with Google Universal Analytics. It stores and updates a unique value for each page visited. The main purpose of this cookie is: Performance |
24 Hours |
cookieconsent_status |
Every user has the ability to manage their cookie jars, so if you're not happy with us using these cookies then you may adjust your browser settings to suit. Please remember we use cookies for users benefit and turning them off may affect the performance of the site. As delighted as we are that you have decided to visit our site if you're not happy with our use of cookies you do have the option not to visit the site again. Please find instructions for managing cookies on your browser below. |
1 year |
CraftSessionId |
This cookie name is associated with the Craft web content management system, where it functions as an anonymous session identifier. The main purpose of this cookie is: Strictly Necessary |
Session |
_hjIncludedInSample |
This cookie is associated with web analytics functionality and services from Hot Jar, a Malta based company. It uniquely identifies a visitor during a single browser session and indicates they are included in an audience sample. The main purpose of this cookie is: Performance |
Session |
v24s_halliwelljones |
This cookie is used to enable the online chat functionality and allows us to analyse the use of online chat. |
Session |
vee24.testCookie |
This cookie is used to enable the online chat functionality and allows us to analyse the use of online chat. |
Session |
vee24.nudges |
This cookie is used to enable the online chat functionality and allows us to analyse the use of online chat. |
Session |
vee24.userIsActive |
This cookie is used to enable the online chat functionality and allows us to analyse the use of online chat. |
Session |
viewedOuibounceModal |
This cookie tracks which users have closed the popup on the approved used section, so it won’t pop-up again after a user has closed it. |
48 hours |
_ga |
This cookie name is associated with Google Universal Analytics. This cookie is used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports. By default it is set to expire after 2 years, although this is customisable by website owners. The main purpose of this cookie is: Performance |
2 years |
v24u_halliwelljones |
This cookie is used to enable the online chat functionality and allows us to analyse the use of online chat. |
10 years |
Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you block cookies you may not be able to access all or parts of our site.
Information Compliance Officer
The person responsible for how the Company deals with personal information, our Information Compliance Officer (“ICO”) is responsible for ensuring compliance with GDPR and with this policy. The post of ICO post is held by Glyn Howes, Finance Director, who can be contacted at [email protected]. Any questions about the operation of this policy or any concerns that the policy has not been followed should be referred in the first instance to the ICO.
CHANGES TO THIS POLICY
We reserve the right to change this policy at any time. Where appropriate, we will notify individuals of those changes by post or email. Each time you enter or use our website, you agree that the privacy policy current at that time shall apply to all information we hold about you.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
CONTACT
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to [email protected].
You have the right to make a complaint at any time to the Information Commissioner's Office, the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the Information Commissioner's Office, so please contact us in the first instance.
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