PRIVACY POLICY

1. About this privacy policy

1.1 This privacy policy sets out our use and sharing of your Personal Data, including what types of Personal Data is collected and why, and the rights you have relating to it in accordance with the General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018.

1.2 This policy was last updated on 5 May 2023.

2. Who looks after your personal information?

Your personal information will be held and processed by Allen Ford (UK) Limited (including Essex Auto Group, SMC, MK Autorama & Delgarth). See "About Us" for more details on Allen Ford (UK) Limited. Allen Ford (UK) Limited is registered with the ICO under registration number Z9340106.

3. What data about you we process

Personal Data is data that relates to an identified or identifiable individual. It is necessary for us to collect, maintain and process Personal Data about our prospective or existing customers to provide our products and services. Personal Data that we’ll process in connection with all our products and services, if relevant, includes:

  • personal & contact details.
  • date of birth.
  • gender and/or age.
  • records of your contact with us.
  • products & services you have purchased, as well as have been interested in & have held, plus the associated payment methods used.
  • marketing to you & analysing data.
  • vehicle data.
  • data about your use of products or services held with our business partners.
  • data we obtained from third parties.
  • data from Credit Reference Agencies & Fraud Prevention Agencies.
  • fraud, debt & theft information.
  • criminal records.
  • information about your health or if you are a vulnerable customer.
  • financial details about you.
  • data about your employment status.
  • and third-party transactions.

4. How we use your information

4.1 We will use your personal information to provide products and services, manage your relationship with us and comply with any laws, regulations, or guidelines we are subject to (for example the laws that prevent financial crime or the regulatory requirements governing the products we offer).

4.2.1 Where it is in our legitimate interests to do so, such as:

  • to keep you and your vehicle safe.
  • to save you money.
  • to carry out monitoring and keep records of our communications with you and our staff.
  • to administer our good governance requirements and those of other members of our Group, such as internal reporting and compliance obligations or administration required for AGM processes.
  • for market research and analysis.
  • for marketing communications and related profiling to help us to offer you relevant products and services, including deciding whether to offer you certain products and service (we will send marketing to you by SMS, email, phone, post, and social media and digital channels, e.g., using Facebook Custom Audiences & Google Custom Match).
  • subject to the appropriate controls, to provide insight and analysis of our customers to business partners either as part of providing products or services, or to assess or improve our products, services, or businesses.
  • for some of our profiling and other automated decision making; and
  • where we need to share your personal information with people or organisations to run our business or comply with any legal and/or regulatory obligations.

4.2.2 We sometimes engage social media platforms to display direct marketing to you on their platform. We use “list-based” and “lookalike” functionality to do this. Using list-based functionality involves the uploading of Personal Data to the social media platform in question (such as a list of email addresses). The platform then matches the uploaded Personal Data with its own user base. Any user that matches the uploaded list is added into a group that will be sent the selected marketing message. Lookalike functionality offers the ability to build other audiences based on the characteristics of an original audience that was created using list-based functionality. These audiences generally comprise of users that have not previously engaged, but who “look like” the list-based audience (i.e., they are users with similar interests, behaviours or characteristics). When creating this sort of audience, the social media platform uses Personal Data it has about other users of its platform to find users who match the interests and behaviours of users that are current customers. Examples include Facebook Custom Audiences or LinkedIn Contact Targeting. We will not undertake this processing unless you have provided us with consent for the purposes set out above and we have contractual controls in place to ensure that the social media platform can only use the Personal Data we share to enable the provision of the Services. We are not responsible for the data practices of social media platforms and recommend you read their own privacy policies.

4.3 With your consent or explicit consent for some of our profiling and other automated decision making; and/or for some of our processing of special categories of Personal Data (e.g., health, criminal records or if you are a vulnerable customer).

4.4 For a public interest, such as processing of special categories of Personal Data (e.g. your health, criminal records or if you are a vulnerable customer).

4.5 To support us with the above, we analyse information we know about you and how you use our products and services, including some automated decision making.

5. Who we share your personal information with

Your personal information will be shared within Allen Ford (UK) Limited and with (for details of their privacy notices and/or privacy policies please click the following links)

Ford https://www.ford.co.uk/useful-information/terms-and-privacy/privacy-policy

Kia https://www.kia.com/uk/privacy/

Hyundai https://www.hyundai.co.uk/legal/privacy

Suzuki https://cars.suzuki.co.uk/privacy/

and other companies that provide services to you or us, so that we and any other companies in our Group can look after your relationship with us. By sharing this information, it enables us to better understand our customers’ needs, run accounts and policies, and provide products and services efficiently. This processing may include activities which take place outside of the United Kingdom. If this is the case, we will ensure that appropriate safeguards are in place to protect your personal information. We may pass your information to the supplying dealer, any other franchised dealer, or the manufacturer and all companies within the manufacturer or dealer group to support their business and marketing activities.

6. Where we collect your personal information from

We will collect personal information about you from several sources, including but not limited to:

  • Information given to us on application forms submitted by you or by a supplying dealer on your behalf when you talk to us over the phone or when new services are requested.
  • From analysis of how you operate our products and services, including the frequency, nature, location, origin, and recipients of any payments; and
  • From or through other organisations (for example card associations, credit reference agencies, insurance companies, dealers, retailers, comparison websites, social media, and fraud prevention agencies).
  • Monitoring devices such as closed-circuit television (CCTV) within our premises, which monitors our business premises 24 hours a day.

In certain circumstances we may also use information about health or criminal convictions, but we will only do this where allowed by law or if you give us your consent.

7. Do you have to give us your personal information?

We may be required by law, or as, a consequence of any contractual relationship we have, to collect personal information from you. Failure to provide this information can prevent or delay us fulfilling these obligations or performing services.

8. Do we do any monitoring involving processing of your personal information?

Monitoring means any listening to, recording, viewing, intercepting, or taking and keeping records (as the case may be) of calls, email, text messages, social media messages, in-person meetings and other communications. We may monitor where permitted by law and we’ll do this where the law requires it, or to comply with regulatory rules, to prevent or detect crime, in the interests of protecting the security of our communications systems and procedures and for quality control and staff training purposes. This information may be shared for the purposes described above.

9. What about other automated decision making?

We sometimes make decisions about you using only technology, where none of our employees or any other individuals have been involved. For instance, we may do this to decide whether to offer you a product or service. We’ll do this where it is necessary for entering into or performing the relevant contract, is authorised by laws that apply to us, or is based on your explicit consent.

10. How long is your personal information retained by us?

Unless we explain otherwise to you, we’ll hold your personal information based on the following criteria:

  • For as long as we have reasonable business needs, such as managing our relationship with you and managing our operations.
  • For as long as we provide goods and/or services to you and then for as long as someone could bring a claim against us; and
  • For retention periods that are in line with legal and regulatory requirements or guidance.

11. What rights you have over your personal information

The law gives you a number of rights in relation to your personal information, including:

11.1 The right to access the personal information we have about you. This includes information from application forms, statements, correspondence, and call recordings.

11.2 The right to rectification of personal information that is wrong or incomplete. Please inform us as soon as possible if personal information we hold on you changes.

11.3 The right to request erasure of your Personal Data. You have the right to ask us to remove or delete your personal information. However, this right only applies in certain circumstances, including but not limited to withdrawal of consent, unlawful processing or where you have exercised your right to object to processing.

11.4 The right to object to processing where we are relying on legitimate interest and you object to processing where it may impact your interests, rights, or freedoms. This includes the right to object to processing of Personal Data for direct marketing purposes. We may demonstrate that we have compelling, legitimate grounds to process your information, overriding your interest, rights, or freedoms.

11.5 The right to portability where we are relying on your consent or performance of a contract as the lawful basis for our processing, or the processing is carried out by automated means, you may request that we provide your Personal Data to you in a structured, commonly used, machine-readable format, or port it to another data controller.

11.6 The right to restriction of processing of your Personal Data. You have the right to ask us to restrict processing of your Personal Data, meaning that we keep it but do not use it, in the following circumstances: contesting the accuracy of the data until such time as it is verified; the processing is unlawful but you do not want your data erased; no longer necessary for processing but retained for the establishment, exercise or defence of legal claims; or you have objected to processing and verification of legitimate overriding grounds is pending.

11.7 The right to not be subject to automated decision making where automated processing has been the sole basis for a decision that produces legal effects concerning you (such as rejection of a claim). This will not apply where the decision: is necessary for entering into or performing a contract with you; is required or authorised by domestic law; or is based your explicit consent. In any case, you can obtain human intervention in the decision making and can express your point of view and contest the decision made.

11.8 The right to withdraw consent where consent has been used as the lawful basis to process your personal data. This will not affect any processing carried out before consent is withdrawn. If consent is withdrawn, this may affect if or how we provide certain products or services to you.

12. Other individuals you have financial links with

We may also collect personal information about other individuals who you have a financial link with. This may include people who you have joint accounts or policies with such as your partner/spouse, dependents, beneficiaries, or people you have commercial links to, for example other directors or officers of your company. We will collect this information to assess any applications, provide the services requested and to carry out credit reference and fraud prevention checks.

13. How we use credit reference agencies

In order to process your application, we may supply your personal information to credit reference agencies (CRAs), including how you use our products and services, and they will give us information about you, such as about your financial history. We do this to assess creditworthiness and product suitability, check your identity, manage your account, trace and recover debts and prevent criminal activity. We may also continue to exchange information about you with CRAs on an ongoing basis, including about your settled accounts and any debts not fully repaid on time, information on funds going into the account, the balance on the account and, if you borrow, details of your repayments or whether you repay in full and on time. CRAs will share your information with other organisations, for example other organisations you ask to provide you with products and services. Your data will also be linked to the data of any joint applicants or other financial associates as explained above.

14. How we use fraud prevention agencies

The personal information we have collected from you and anyone you have a financial link with may be shared with fraud prevention agencies who will use it to prevent fraud and money laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance, or employment.

15. Contact from us and your marketing choices

Personal contact is an important part of our service, and we may contact you personally by mail, telephone, email or text message to inform you about products and services offered by Allen Ford (UK) Limited and others that they think are relevant to you, based on their understanding of your financial needs. You have the right at any time to ask us not to contact you or give your details to others for these marketing purposes. You can contact Allen Ford (UK) Limited by mail, telephone or email and we will update your marketing preferences. The supplying dealer may also contact you with information and offers on vehicles and/or vehicle finance packages (which may refer to our products and services). If you would like the dealer to stop using your details for these marketing purposes, you should contact the dealer.

16. How you can contact us

16.1 If you have any questions, concerns or require more information about how we use your personal information, please contact us by e-mailing: data@allenmotorgroup.co.uk

16.2 If you have any concerns or complaints about our processing of your Personal Data or our response to you exercising your rights, you have the right to lodge a complaint with the UK data protection authority, the Information Commissioners Office (ICO).

17. Version Control

We may update our privacy policy from time to time to reflect changes in the law and/or privacy practices. We encourage you to check this privacy policy for changes whenever you revisit our website. We will notify you of any changes to this policy that may materially affect how we use or collect your Personal Data.

18. Accreditation Statement

We are a proud member of The Motor Ombudsman accreditation scheme and are accredited to the CTSI-approved Service and Repair / New and Used Car Code of Practice, ensuring we operate to the highest standards of service and offering peace of mind for customers.

19. What are cookies?

There is a technology called "cookies" which can be used to provide you with tailored information from a website. A cookie is an element of data, a file which is nothing but a line of text that a website can send to your browser, which may then store it on your system. Some Allen Ford (UK) Limited pages use cookies so that we can better serve you when you return to our website. For example, a cookie might help you to avoid having to re-enter data you have given us before. You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether to accept it.

20. Which cookies does the Allen Ford (UK) Limited website use?

We may use essential cookies to enable our site to function correctly, and you will have the option to opt-out of any non-essential cookies.

We use cookies to help you store used vehicles in the "My Showroom" page, and we use Google Analytics to help us understand how people use our site (neither of these collect ANY information that could be used to personally identify you or your computer). The "My Showroom" cookie contains only vehicle reference numbers and details of pictures for that vehicle. It is NOT a "tracking" cookie.

More information about the cookies we use can be found in our cookie policy here. Full details about the purpose and actions of the Google Analytics cookies can be found here.

21. Vehicle search records

If you conduct a vehicle search on our website, GForces deposits a record of the search on your device. If you visit our website again, GForces accesses that record and offers you the option to replicate your previous search to save you time repeating it. It also uses that record to present recommended alternatives to the vehicles you viewed previously. To do this, GForces sends details of your previously viewed vehicles (without any personal information) to Amazon Web Services, which produces the recommendations using machine learning. If you don’t want search records to remain on your device, you can clear local storage in your browser. To find out how to manage website data (Local Storage) on popular browsers, see the links below. For information relating to other browsers, visit the browser developer's website.

• Google Chrome – https://support.google.com/chrome/answer/2392709

• Microsoft Edge – https://support.microsoft.com/en-gb/help/4468242/microsoft-edge-browsing-data-and-privacy

• Mozilla Firefox – https://support.mozilla.org/en-US/kb/storage

• Microsoft Internet Explorer – https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies

• Apple Safari – https://support.apple.com/en-gb/guide/safari/sfri11471/mac