Terms and Conditions

Euro Commercials (SW) Ltd Privacy Policy

1.0 ABOUT THIS POLICY

1.6 Your privacy is extremely important to us. This Privacy Policy explains what information we collect and how we use it.

1.7 This Privacy Policy will detail how Euro Commercials (SW) Ltd will obtain your personal information and detail when, how and why it is collected and how it is kept securely.

1.8 Our contact details are at the end of this policy which you can use if you have any questions, including how to update or access your personal information or to make a complaint.

1.9 This policy is liable to change, so please refer to this policy periodically to ensure that you remain happy with the updates made.

1.10 Policy Updated 01/01/2020.

2.0 WHO WE ARE

2.1 Euro Commercials Ltd is registered in England under company registration number 1459115, it is an automotive business


Registered office address is Ipswich Road, Cardiff, CF23 9AQ.

VAT Registration Number is 329 0150 83.

Euro Commercials is authorised and regulated by the Financial Conduct Authority for credit broking (Firm Reference Number: 678833).

Contact number 029 20310310


3.0 HOW AND WHAT PERSONAL INFORMATION WE COLLECT

3.1 We may collect and process the following personal information about you:
Personal information you give to us: This is information about you that you give to us by entering information via our websites or our social media pages or by corresponding with us by phone, email or otherwise and is provided entirely voluntarily. The information you give to us includes your name, contact details (such as phone number, email address and address), enquiry details and your opinion of our products.

In addition to the above we will also store personal information only if you share that information; for instance, by filling out a registration form, contact form, survey, contest entry or to execute a contract. In such cases we will, store only the data we are allowed to keep based on consent given by you or in accordance with applicable legal regulations.

Personal Information we collect about you: We store certain information about the browser and operating system you are using; the date and time of your visit; the status of interaction (e.g. whether you were able to access the website or received an error message); the usage of features on the website; any search phrases you entered; how often you visit individual websites; the names of files you access; the amount of data transferred; the Web page from which you accessed our website; and the Web page you visited after visiting our website, whether by clicking on links on our websites or entering a domain directly into the input field of the same tab (or window) of the browser in which you have our websites open. In addition, we store your IP address and the name of your internet provider for seven days. This is for security reasons; in particular, to prevent and detect attacks on our websites or attempts at fraud.

Personal information we may receive from other sources: We obtain certain personal information about you from sources outside our business which may include third party companies; the personal information received is as described in the two paragraphs above.
Information in any of these ways can be withdrawn at any time. Please see Withdrawing your consent in Section 8.4 for further details.

3.2 Please see further how we use your personal information in Section 4 for details of the purposes for which we use the personal information we obtain from these sources and the legal basis on which we rely to process that information. The remaining provisions of this policy also apply to any personal information we obtain from these sources.

3.3 You are neither legally nor contractually obligated to share your personal information. However, certain features of our website may depend on the sharing of personal information. If you do not provide your personal information in such cases, you may not be able to use those features, or they may be available with very limited functionality.

3.4 If telematics software is installed in the vehicle, the vehicle manufacturer or telematics services provider may share vehicle location data with Euro Commercials Ltd in order to retake possession of the vehicle if it reasonably suspects that the vehicle has been abandoned (or that you have otherwise breached any term of an agreement with Euro Commercials Ltd) and you do not respond satisfactorily despite attempts to contact you or if the data is requested by law enforcement agencies. No behavioural or vehicle usage data is shared with Euro Commercials Ltd. Euro Commercials Ltd may share the vehicle location data with third parties instructed to recover the vehicle or with law enforcement agencies in connection with their investigations.

Euro Commercials Ltd may transfer information about you and this Agreement to debt collection agencies

4.0 HOW WE USED YOUR PERSONAL INFORMATION

4.1 Where you have provided CONSENT

If you have given us your consent to process your personal information, then that is the legal foundation for processing it (Art. 6, para. 1, letter a, of the EU’s General Data Protection regulation, or GDPR).

We may use and process your personal information where you have consented for us to do so. For the following purposes:

• To share your personal information with our Sales Team to arrange test drives or where you have requested a call back.
• To supply product information and other material you have specifically requested from us.
• To contact you via email, text message, post or telephone with marketing information about Euro Commercials Ltd, please see the Marketing section below for further detail.
• To share your personal information with our recommended third-party partners for them to contact you with marketing information about their products and services. Please see the Marketing section below in this policy to find out more about these third parties; and
• To process payments on your behalf including but not limited to card payments taken over the phone for the purposes of making payment of a deposit related to a vehicle.

4.2 You may withdraw your consent for us to use your information in any of these ways at any time. Please see Withdrawing your consent in Section 8.4 for further details.

4.3 Where required to perform a CONTRACT with you

We may use and process your personal information where it is necessary for the performance of a contract with you or in order to take steps at your request before entering into a contract with you including for the following purposes;

• To exchange information for warranty/aftersales.
• For the purchase of a motor vehicle.
• To allow for the provision of third-party breakdown services by our breakdown provider.

4.4 Where it is in your VITAL INTEREST

We may use your personal information to contact you if there are any urgent safety or product recall notices to communicate to you or where we otherwise reasonably believe that the processing of your personal information will prevent or reduce any potential harm to you. It is in your vital interests for us to use your personal information in this way.

4.5 Where required to comply with our LEGAL OBLIGATIONS

We will use your personal information to comply with our legal obligations including: (i) to assist HMRC, the Police, the Driver and Vehicle Licensing Agency (DVLA) or any other public authority or criminal investigation body; (ii) to identify you when you contact us; and (iii) to verify the accuracy of data that we hold about you. This is in line with art.6, para. 2, letter c, of the GDPR.

4.6 Where there is a LEGITIMATE INTEREST

We may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business for the following purposes:

• for analysis, and profiling to inform our marketing strategy, and to enhance and personalise your customer or visitor experience;
• for market research in order to continually improve the products and services that we and our authorised dealers deliver to you;
• to administer our websites and for internal operations, including troubleshooting, testing, statistical purposes;
• for marketing activities (other than where we rely on your consent) e.g. to tailor marketing communications or send targeted marketing messages via social media and other third-party platforms;
• for the prevention of fraud and other criminal activities;
• to undertake credit checks for finance;
• to correspond and communicate with you;
• to create a better understanding of you as a customer or visitor;
• for network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access;
• to comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);
• for the purposes of corporate restructure, reorganisation or sale of our business or assets;
• for efficiency, accuracy or other improvements of our databases and systems e.g. by combining systems or consolidating records we or our group companies hold about you;
• to enforce or protect our contractual or other legal rights or to bring or defend legal proceedings; and
• for general administration including managing your queries, complaints, or claims, and to send service messages to you;
• To locate the vehicle, as per section 3.4.

5.0 OTHERS WHO MAY RECEIVE OR HAVE ACCESS TO YOUR PERSONAL INFORMATION

5.1 Group companies

We may share your information with other companies within our group.

5.2 Our suppliers and service providers

We may disclose your information to our third-party service providers, agents, subcontractors and other organisations for the purposes of providing services to us or directly to you on our behalf. Such third parties may include cloud services providers (such as hosting and email management) or advertising agencies, administrative services or other third parties who provide services to us.

When we use third party service providers, we only disclose to them any personal information that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.

5.4 Third parties who provide products and services

We work closely with various third parties to bring you a range of products and services which are complimentary to ours.

When you enquire about or purchase one or more of these products or services through us (e.g. via our websites), the relevant third party may use your details to provide you with information and carry out their obligations arising from any contracts you have entered into with them.

These third party product providers may share your information with us which we will use in accordance with this policy. In some cases, they will be acting as a controller of your information and therefore we advise you to read their privacy policy.

5.5 Other ways we may share your personal information

We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation. We may also transfer your personal information if we’re under a duty to disclose or share it in order to comply with any legal obligation (e.g. by sharing your personal information with the DVLA), to detect or report a crime, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our visitors and customers.

However, we will always take steps with the aim of ensuring that your privacy rights continue to be protected.

6.0 WHERE WE STORE YOUR PERSONAL INFORMATION OUTSIDE THE EEA

6.1 All information you provide to us may be transferred to countries outside the European Economic Area (EEA). By way of example, this may happen where any of our group companies are incorporated in a country outside of the EEA or if any of our servers or those of our third party service providers are from time to time located in a country outside of the EEA. These countries may not have similar data protection laws to the UK.

6.2 If we transfer your information outside of the EEA in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this policy. These steps include imposing contractual obligations on the recipient of your personal information or ensuring that the recipients are subscribed to ‘international frameworks’ that aim to ensure adequate protection. Please contact us using the details at the end of this policy for more information about the protections that we put in place and to obtain a copy of the relevant documents.

6.3 If you use our services whilst you are outside the EEA, your information may be transferred outside the EEA in order to provide you with those services.

7.0 HOW LONG WE KEEP YOUR PERSONAL INFORMATION FOR

7.1 If we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws.

7.2 We do not retain personal information in an identifiable format for longer than is necessary.

7.3 We may need your personal information to establish, bring or defend legal claims, in which case we will retain your personal information for 7 years after the last occasion on which we have used your personal information in one of the ways specified in How we use your personal information in Section 4.

7.4 The only exceptions to this are where:

• the law requires us to hold your personal information for a longer period, or delete it sooner;
• you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted in this section 7, or because we are required under the law (see further Erasing your personal information or restricting its processing in Section 8.6);
• and in limited cases, the law permits us to keep your personal information indefinitely provided we put certain protections in place.

8. YOUR RIGHTS

8.1 Your ‘data subject’ rights:

You have a number of rights in relation to your personal information under data protection law. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within 30 days after we have received this information or, where no such information is required, after we have received your request.

8.2 Accessing your personal information

You have the right to ask for a copy of the information that we hold about you by emailing or writing to us at the address at the end of this policy. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.

8.3 Correcting and updating your personal information

The accuracy of your information is important to us and we are working on ways to make it easier for you to review and correct the information that we hold about you.

In the meantime, if you change your name or address/email address, or you discover that any of the other information we hold is inaccurate or out of date, please let us know by contacting us in any of the details described at the end of this policy.

8.4 Withdrawing your consent

Where we rely on your consent as the legal basis for processing your personal information, as set out under How we use your personal information in Section 4, you may withdraw your consent at any time by contacting us using the details at the end of this policy. If you would like to withdraw your consent to receiving any direct marketing to which you previously opted-in, you can also do so using our unsubscribe tool. If you withdraw your consent, our use of your personal information before you withdraw is still lawful.

8.5 Objecting to our use of your personal information & automated decisions made about you

Where we rely on our legitimate business interests as the legal basis for processing your personal information for any purpose(s), as out under How we use your personal information in Section 4, you may object to us using your personal information for these purposes by emailing or writing to us at the address at the end of this policy. Except for the purposes for which we are sure we can continue to process your personal information, we will temporarily stop processing your personal information in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise we will provide you with our justification as to why we need to continue using your data.

You may object to us using your personal information for direct marketing purposes and we will automatically comply with your request. If you would like to do so, please use our unsubscribe tool.

You may also contest a decision made about you based on automated processing by contacting the data protection department.

8.6 Erasing your personal information or restricting its processing

In certain circumstances, you may ask for your personal information to be removed from our systems by emailing or writing to us at the address at the end of this policy. Unless there is a reason that the law allows us to use your personal information for longer, we will make reasonable efforts to comply with your request.

You may also ask us to restrict processing your personal information in the following situations:

• where you believe it is unlawful for us to do so,
• you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings.

In these situations, we may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings.

8.7 Transferring your personal information in a structured data file

Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with your contract, as set out under Section 4 How we use your personal information, you may ask us to provide you with a copy of that information in a structured data file. We will provide this to you electronically in a structured, commonly used and machine readable form, such as a CSV file.

You can ask us to send your personal information directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.

8.8 Complaining to the UK data protection regulator

You have the right to complain to the Information Commissioners Office (ICO) if you are concerned about the way we have processed your personal information. Please visit the ICO’s website for further details.

9. SECURITY / COOKIES / LINKS / SOCIAL PLUGINS

9.1 Security measures we put in place to protect your personal information

Euro Commercials Ltd use technical and organisational security measures to protect the personal information supplied by you and managed by us against manipulation, loss, destruction, and access by third parties. Our security measures are continually improved in line with technological developments.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information whilst in transit to our website and any transmission is at your own risk.

Where we have given (or where you have chosen) a password which enables you to access an account, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

9.2 Use of 'cookies'

'Cookies' are small pieces of information sent to your device and stored on its hard drive to allow our websites to recognise you when you visit. They enable us to e.g. recognise whether there has been a previous connection between your device and our websites, take into account your preferred language or other settings, offer you certain functionalities (e.g. online shop, vehicle configurator) or recognise your interests on the basis of previous use. Cookies can also contain personal information.



If you use our websites, you consent to the use of cookies – with the exception of cookies for Google marketing products. Cookies for Google marketing products (e.g. Google Search Ads, Google Display & Video 360) are only used with your express consent.

You can also visit our websites without consenting to the use of cookies by such use. In other words, you can reject the use of cookies and delete them at any time by making the appropriate settings to your device.

• Most browsers are set to accept cookies automatically by default; you are usually able to alter this setting. You can delete stored cookies at any time. The manufacturer's instructions will tell you how this is done in the browser or device you use.
• You can delete the content of Web/DOM Storage at any time. The manufacturer's instructions will tell you how this is done in the browser or device you use.
• Information can be found online on how to deactivate and delete local shared objects
• The same rules that apply to the use of cookies also apply to rejecting or deleting them. The procedure is tied to the device being used as well as the browser being used with that device. In other words, you will need to reject or delete the cookies separately for each of your devices and each browser if you use more than one.

If you opt out of the use of cookies, you may not be able to use all the features of our websites, or individual features may be available with limited functionality only.



We categorise cookies as follows:

• Essential cookies (type 1) - These cookies are essential for websites and their features to work properly. Without these cookies, we would not be able to provide you with services such as the vehicle configuration.
• Functional cookies (type 2) - These cookies enable us to improve the usability and performance of our websites. For example, we store your language settings in functional cookies.
• Performance cookies (type 3) - These cookies collect information about how you use our websites. They help us to identify which parts of our websites are especially popular, enabling us to improve what we offer you (so-called, tracking). Further information about this can be found in section 5 of our data protection notes.
• Third-party cookies (type 4) - These cookies are used by third parties – for example social networks such as Facebook, Twitter and Google+. You can integrate their contents by using the social plugins offered through our websites. They are also used by our targeting and retargeting partners, with the aid of whom we tailor our online marketing more specifically to your specific needs and interests. Further information about this can be found in sections 4 and 5 of our data protection notes.

9.3 Links to other website

Our website may contain links to other websites run by other organisations which we do not control. This policy does not apply to those other websites and Apps‚ so we encourage you to read their privacy statements. We are not responsible for the privacy policies and practices of other websites and Apps (even if you access them using links that we provide) and we provide links to those websites solely for your information and convenience. We specifically disclaim responsibility for their content, privacy practices and terms of use, and we make no endorsements, representations or promises about their accuracy, content or thoroughness. Your disclosure of personal information to third party websites is at your own risk.

In addition, if you linked to our website from a third party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party website and recommend that you check the policy of that third party website.

9.4 Social plugins

Euro Commercials Ltd use so-called social plugins (buttons) of social networks such as Facebook, Google, Twitter and Instagram.

When you visit our websites, social media plugins are deactivated. That means no information whatsoever is transferred to the operators of those networks. If you wish to use one of the networks, click on the appropriate plugin in order to be connected directly to that network's server.

If you have a user account with that network and are logged in at the moment you activate the plugin, the network will be able to detect your visit to our websites and assign it to your user account. If you wish to prevent that, please log off from the network before activating the social plugin.

When you activate a social plugin, the network transfers the content thus made available directly to your browser, which incorporates it into our websites. In that situation, data transfers initiated and controlled by the respective social network may also take place. Your connection to a social network, the data transfers that take place between the network and your system, and your interactions on that platform are governed exclusively by the respective network's data protection provisions.

This policy does not apply to those other websites and Apps‚ so we encourage you to read their privacy statements. We are not responsible for the privacy policies and practices of other websites and Apps (even if you access them using links that we provide) and we provide links to those websites solely for your information and convenience.

10.0 MARKETING PREFERENCES

10.1 We may collect your marketing preference to send you marketing information directly from Euro Commercials Ltd via email / SMS / phone (whichever is applicable) including:

* Test drive request or call back request

* Online booking or account request

10.2 We will contact you with targeted advertising through social media and online platforms (operated by other companies) – we will ensure that using your personal information we will tailor our marketing to ensure it is relevant to you, unless you object.

10.3 We will only share your personal information with recommended third parties for them to contact you with marketing information about their products and services where you have indicated that you would like us to do so. Once shared, the relevant third party’s privacy policy will apply to their processing of your personal information, not ours. If you’d like to opt-out of receiving marketing from a third party after providing your consent, you can do so at any time by contacting the relevant third party directly.

11.0 CHANGES TO THIS POLICY

We may review this policy from time to time and any changes will be notified to you by posting an updated version on our website and/or by contacting you by email. Any changes will take effect 7 days after the date of our email or the date on which we post the modified terms on our website, whichever is the earlier. We recommend you regularly check for changes and review this policy when you visit our website. If you do not agree with any aspect of the updated policy, you must promptly notify us and cease using our services.

12.0 CONTACT US

If you have any questions, suggestions or complaints about the processing of your personal information or wish to contact us to amend/update your marketing preferences with Euro Commercials Ltd

Euro Commercials Ltd Data Protection Co-ordinator:

Rebekka Salway

Euro Commercials Ltd

Ipswich Road

Cardiff

CF23 9AQ



Email: rebekka.salway@euro-commercials.co.uk
Telephone: 02920230530