1. Who We Are
We are Group 1 Retail. Group 1 Retail includes the following companies, all of which are Registered in England & Wales and have their Registered Office at First Point St. Leonards Road, Allington, Maidstone, Kent, ME16 0LS:-
Group 1 Retail Limited (Company Number 194561) which is authorised and regulated by the Financial Conduct Authority;
Chapelgate Motors Limited (Company Number. 2841981) (an Appointed Representative of Group 1 Retail Limited);
Gerard Mann Limited (Company Number 660644) (an Appointed Representative of Group 1 Retail Limited); and
The Cooper Group Limited (Company Number 821770) (an Appointed Representative of Group 1 Retail Limited;
We are also registered with the Information Commissioner's Officer with the following registration numbers:
Group 1 Retail Z5437528;
Chapelgate Motors Limited Z7569674;
Gerard Mann Limited Z5063131; and
The Cooper Group Limited Z6970928;
2. What is Personal Information?
Personal information is any information which we collect about you that can be used to identify you and is stored either electronically or in a usable filing system.
Personal information will include any information, such as your name, address, ip address, vehicle registration number, that is collected about you by us for any reason, whether it be in connection with a purchase, by visiting our store or by contacting us.
It also includes any personal information that we may collect about you that is in the public domain, such as information made public on social media that is available to us when you connect with us on social media.
It is our intention to provide you with as much information as possible about what we do with that personal information, so that when you provide the personal information to us, you do so with an awareness of how it will be used.
3. How we collect your personal information and why
Group 1 Retail (we, us, our, Inchcape) will need to collect personal information about you, and there are different ways that we might do so; this privacy notice tells you what to expect when we collect personal information:
(a) from visitors to our website, www.inchcape.co.uk;
(b) through social media;
(c) anyone referred to us from enquiries made of our brand partners (via their websites or otherwise) or used vehicle websites such as Auto Trader Limited or Carwow;
(d) anyone who contacts us;
(e) anyone who purchases a vehicle;
(f) anyone who uses our service and maintenance services
(g) anyone who subscribes to our marketing;
(h) from visitors to our online store, www.store.inchcape.co.uk.
3.2 Visitors to our store
Our online store is managed by Omni Automotive Ltd they will help to maintain the security and the performance of our store by (i) encrypting data in transit and protecting user connections (ii) using third party scanning services to scan against known web attacks (iii) investigating site errors and (iv) providing secure hosting services.
When you visit the store, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the store, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the store, and information about how you interact with the store. We refer to this automatically-collected information as “Device Information”.
3.2.1 Cookies
Cookies are small files of letters and numbers that we store on your browser or the hard drive of your device. Like most online stores, we use cookies on our store for our legitimate interests. There are different types of cookies that we use for different purposes; however generally speaking cookies help us to distinguish you from other users of our online store, which allows us to provide you a better experience and also allows us to improve our online store.
You can block cookies at any time by activating the setting on your browser that allows you to refuse some or all cookies. However, if you do block cookies there may be parts of our store that you will be unable to access or that will not function properly.
We use the following types of cookies:
(a) Strictly necessary cookies.
These are cookies that are essential for the operation of our online store. They include, for example, cookies that enable you to log into secure areas of our store, use a shopping cart or make use of e-billing services.
(b) Analytical/performance cookies.
They allow us to recognise and count the number of visitors and to see how visitors move around our store when they are using it. This helps us to improve the way our online store works, for example, by ensuring that users are finding what they are looking for easily.
(c) Functionality cookies.
These are used to recognise you when you come back to our store so that we can personalise our content for you, greet you by name and remember your preferences (for example, your region).
3.2.2 Third party services
Whenever you visit our store, www.store.inchcape.co.uk, we will use a third party service, Google Analytics, to collect standard information about your store use, such as internet logs and details of your visitor behaviour patterns. The reason we use this service is that it is within our legitimate interests to find out how many people visit the store and the various parts of the store, it improves the service provided to you and improves customer experience. This information helps us to find out how our store is working and how to improve it. We do not identify anyone, and we do not make or allow Google Analytics to (or attempt to) identify anyone visiting our store.
(a) We may have YouTube video content embedded on our store. YouTube controls any information that is collected by viewing their content. YouTube's privacy policy can be located at https://www.google.co.uk/intl/en-GB/policies/privacy/.
3.3 Social media
Any information you provide to us via social media (including messaging, "liking", "following" and other communications) is controlled by the social media network. Our store contains links to our social media pages. We currently use:
3.3.1 Twitter, which has its own privacy notice that can be located at https://twitter.com/en/privacy;
3.3.2 Facebook, which has its own privacy notice that can be located at https://www.facebook.com/privacy/explanation;
3.3.3 LinkedIn, which has its own privacy notice that can be located at https://www.linkedin.com/legal/privacy-policy?trk=uno-reg-guest-home-privacy-policy;
3.3.4 Instagram, which has its own privacy notice that can be located at https://help.instagram.com/519522125107875?helpref=page_content.
We recommend that you read their privacy notices and contact them directly if you have any concerns regarding their use of your personal information.
3.4 Contacting us
Our store provides you with different ways to contact us. All communications are handled, reviewed and responded to internally by us.
Calls made to our dedicated contact centres will be recorded. It is within our legitimate interests to record such calls for training, monitoring and quality purposes. The call recording system, ‘Genesys’, is operated by Redcentric Limited and the data is stored and hosted on Inchcape UK’s own servers in the UK. Call data will be retained for up to 1 year before being deleted. Advisors are also videoed making the customer bookings via the Genesys system. The videos are retained on the same server for 62 days before being deleted.
Please note, however, that email monitoring or blocking software may also be used and that you have a responsibility to ensure that any email you send to us is within the bounds of the law.
As part of communicating with us, you will also submit personal information about you that we require in our legitimate interest. This includes your name, address, email address, phone number and sometimes additional details such as a registration or VIN number.
Any personal information that is provided in and during communications is used only for the purpose of reviewing the communications and conducting the ongoing administration and management of communications. We will not use your personal information in an identifiable manner in any publication without your further explicit consent.
We will delete this personal data when we reasonably consider that we no longer need it for this purpose. Please note that we may need to contact you about the application through any of post, email or telephone. Please can you make sure that you keep us updated of any changes to your contact details.
3.5 Personal information collected when you make a purchase
When you make a purchase on the Inchcape online store, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit card numbers), email address, and phone number. We refer to this information as “Order Information”.
3.6 Duty of care communications
If you have (i) purchased a vehicle from us, (ii) serviced a vehicle with us or (iii) obtained finance through us, then we will also use your contact details, name, vehicle make, model and registration number, service history and finance terms to contact you for one of the following purposes;
3.6.1 to notify you that there is a product recall on your vehicle, and where appropriate we will also offer to book you in and change the recalled part for you which is in our legitimate interests to do in order to (i) ensure that the vehicle is safe and road worthy and for your and the public benefit (ii) to ensure that your vehicle is safe at all times and (iii) to promote our services to you;
3.6.2 to remind you that your vehicle is due for a service within the next month and, where appropriate, notify you of our service options and offer to book you into a service at your local authorised dealer, which is in our legitimate interest to do so for (i) both your and the public benefit to ensure that your vehicle is checked, maintained and road worthy and (ii) to promote our services to you;
3.6.3 to remind you that your vehicle MOT is due to expire and will need to be renewed, and, where appropriate, notify you of our MOT options and offer to book you into a MOT at your local authorised dealer, which is in our legitimate interest to do (i) for your benefit to allow you to comply with your legal obligation to renew your vehicle MOT annually and (ii) to promote our MOT services to you;
3.6.4 to contact you regarding your finance contract to explore any added value you can achieve with your current package and, where appropriate, offer you any upgrades to your finance package, which is in our legitimate interest to do (i) to manage your finance contract, (ii) and for your benefit to offer you the best value for money in terms of the finance package you obtain and (iii) to promote our business interests.
In each instance we will only contact you for the specific purpose(s) set out above. Please note that these communications will include marketing specific to the purpose of contact and you have the right at any time to opt-out of receiving further communications.
If you ever decide you no longer wish to receive our duty of care communications, you may opt out at any time by unsubscribing from the mailing list, using the link provided in the communication email, or by using the contact details below. If you do unsubscribe, please note that we will still keep your details in our system marked as ‘denied’ so that we can make sure that you do not receive these communications again in the future.
3.7 Subscribing to our general marketing
If you are a customer, or have made an enquiry into our products or services, we will provide you with a clear choice to consent to receiving general marketing promotional material, updates, reminders and communications, which are not duty of care communications (such communications are covered in section 3.6 above) by giving you an opt-in to receiving such communications. If you have provided your consent we will collect your contact details (name, postal address and email address) and vehicle details (make and model) to provide you with such communications. You have the right to withdraw your consent at any time. For full details on how to withdraw consent please see below.
We will collect your personal information via our online store. All electronic files are stored on Shopify, our e-Commerce platform, and our Dealer Management System, Autoline. The Autoline system is provided, maintained and hosted by CDK Global (UK) Limited in the United Kingdom. We also store customer data in our showroom system, IA Live. The IA Live system is provided, maintained and hosted by Group 1 Retail in the United Kingdom. In respect of our Jaguar Land Rover brand, we store customer data in a system called enquiryMAX. The enquiryMAX system is provided, maintained and hosted by enquiryMAX Limited on behalf of Jaguar Land Rover. enquiryMAX Limited and CDK are providers of industry standard software solutions and a copy of their privacy notices can be found at http://www.cdkglobal.co.uk/privacy-policy and http://www.enquirymax.com/privacy/.
We use third parties, Emailcenter UK Limited, Northend Print Solutions Limited, Webmart Limited, and Marks Fitzpatrick Gaule Limited to manage our newsletter subscriptions.
If you ever decide you no longer wish to receive our marketing communications, you opt out at any time by unsubscribing from the mailing list, using the link provided in the marketing communications email, or by using the contact details below. If you do unsubscribe, please note that we will still keep your details in our system marked as ‘denied’ so that we can make sure that you do not receive our marketing communications again in the future.
4. Your data and third parties
We use third parties to provide services to us from time to time; therefore, we will need to share data with them that it is in our legitimate interests for business administrative needs. A list of third parties that we use and how they process personal information can be found here: https://www.inchcape.co.uk/privacy-policy/.
Where such third parties are located outside of the EEA there are additional safeguards in place to protect your personal information when transferring personal information outside of the EEA.
5. Disclosure of personal information
We will not usually disclose your personal information other than as already explained in Section 2 and 3 above. However, there may be circumstances where we need to share personal information other than as anticipated in Section 2 and 3 above. These include:
5.1.1 where we are legally required to disclose the information. This includes sharing the personal information with tax authorities and law enforcement agencies for the purposes of the prevention and detection of crime;
5.1.2 where we need to disclose the personal information for the purpose of or in connection with any legal proceedings, or for the purpose of obtaining legal advice, or the disclosure is otherwise necessary for the purposes of establishing, exercising or defending legal rights;
5.1.3 disclosure is required to protect the our interests, or someone else's interests (for example, to prevent fraud);
5.1.4 disclosure is necessary to protect your vital interests (for example if you are unwell at our premises, we may need to seek medical assistance);
5.1.5 it is to a third party for the purposes of providing administrative or processing services on our behalf. If such disclosure is required we will take steps to ensure that the third party protects the personal information in the same way that we do and notify you of any changes to this privacy notice; and
5.1.6 to any prospective purchaser of our business assets or organisation.
6 . Keeping personal information secure
We know that you provide your personal information in good faith and expect it to be looked after. This is why we take the security of your personal information seriously. This means that we have taken steps internally in order to ensure that our systems adequately protect your personal information. This includes:
(a) keeping special categories of data in a separate password protected file to all other personal information;
(b) locating all personal information that we control on internal servers located in the United Kingdom;
(c) ensuring strict access controls on a need to know basis; and
(d) monitoring access to the personal information.
7. Your rights
You have rights in respect of your personal information and this Section explains a bit more about those rights that are applicable to what we do with your personal information and when you can exercise them. If you would like more information about any of your rights, please contact us on the details set out below.
7.1. Withdrawing consent
Where you have explicitly consented to us processing special categories of data, you can withdraw consent to our processing the special categories of data at any time during the application process. If you wish to withdraw consent, please do so by sending your request in writing to our contact details below.
7.2. Accessing your personal information
We want you to fully understand and be comfortable with how we use your personal information. You can contact us at any time to ask whether we process any personal information about you. If we do hold or use your personal information in any way, you have the right to access that personal information. All we ask is that:
7.2.1 you make your request to access in writing to the contact details below;
7.2.2 you verify your identity; and
7.2.3 you are fair and reasonable with how often you make this kind of request (otherwise we may be entitled to charge a fee for handling excessive requests). Please allow us up to one month from receipt of your request in order to provide a response.
7.3. Requesting more information
We hope that you can understand that it is very difficult to cover all the possible ways in which we collect and use personal information. We have tried to be as clear and as open as we can and will continue to update this privacy notice as our use of personal information develops. However, if you have any questions regarding our use of your personal information, we will be happy to give you peace of mind by answering any questions or providing any additional information that we can. If you do have any specific questions, or need anything explaining, please get in touch on the contact details below.
7.4. Additional rights
You also have some additional rights that you may exercise as set out here. We may publish a policy, from time to time, to explain how we will handle such requests and what you can expect from us when you make a request to exercise your rights. If we do publish any such policy, we will provide a link to it here. In each instance we may ask you to make your request in writing to the contact addresses below and provide verification of your identity.
7.4.1 You have the right to request that we rectify any inaccuracy about you that we may hold, in which case we may ask you to verify the corrected information (for example, we may ask for a recent utility bill for proof of change of address)
7.4.2 You have the right to request that we erase your personal information. Please be aware that we can only comply with such a request if
(a) your personal information is no longer required for the purposes it was collected for (for example, we need your personal information to respond to a communication);
(b) the collection, storage or use of the personal information by us is prevented by law;
(c) your personal information is not required for the purposes of establishing, exercising or defending a legal claim such as in the conduct of legal proceedings.
7.4.3 You have the right to request that we restrict or refrain from processing your personal information:
(a) for the time it takes us to verify the accuracy of your personal information where you have disputed its accuracy;
(b) where the collection, storage or use of the personal information by us is unlawful but you decide not to ask for erasure;
(c) where, we no longer need your personal information but you need them for the purposes of establishing, exercising or defending a legal claim;
(d) for the time it takes to determine whether we have an overriding legitimate ground to continue to process your personal information, where you have exercised your right to object to processing.
7.4.4 You have the right to data portability in respect of information we have collected from you based on consent or for the reason of entering into a contract. If you exercise this right, we will transfer a copy of the information that you have provided to us at your request.
7.4.5 You have the right to object to our use of your personal information:
(a) where we are using that information based on our legitimate interests, and where we do not have compelling overriding grounds to continue to use your personal information; or
(b) at any time, where we use your personal information to send you the newsletter or any other type of direct marketing, in which case it will no longer be used for that purpose, but may use it for another lawful purpose.
8. Complaints
You are important to us, and so is protecting your personal information. We have high standards when it comes to collecting and using personal information. For this reason, we take any complaints we receive from you about our use of your personal information very seriously and request that you bring any issues to our attention.
Where you are communicating with us for the purpose of making a complaint, we will only use your personal information to handle, investigate and respond to the complaint and to check on the level of service we provide. Where the complaint is about a member of our team, we may have to disclose your identity to whoever the complaint is about. You may let us know that you don't want information that identifies you to be disclosed and we will try to respect your request; however, it may not be always possible to handle a complaint on an anonymous basis. If you are unhappy, you can also contact the Information Commissioner's office to make a complaint directly.
9. Updating this privacy notice
We keep our privacy notice under regular review in order to ensure that it properly reflects our use of personal information. This privacy notice was last updated on 20 March 2019.
Contacting Us
You can contact us by:
Post: First Point St. Leonards Road, Allington, Maidstone, Kent, ME16 0LS
Email: data.protection@inchcape.com
Telephone: 0330 404 7343