SG Petch Privacy Policy
IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this privacy policy
This privacy policy aims to give you information on how SG Petch collects and processes your personal data through your use of our website, including any data you may provide through this website when you register with us, contact us or when you express an interest in or purchase products or services from us.This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Controller
SG Petch is the controller and responsible for your personal data (collectively referred to as "SG Petch", "we", "us" or "our" in this privacy policy).We have appointed a data privacy team who are responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy team using the details set out below.
Contact details
- Email address: dataprotection@sgpetch.com
- Postal address: SG Petch Data Protection Department Office, McMullen Road, Darlington, DL1 1XZ
- Telephone number: 01325 488886
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated on 30 June 2021.It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Profile Data includes purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We may, in certain circumstances (such as in connection with the Motability Scheme) collect Special Categories of Personal Data about you (this includes details about your health and medical conditions). We will always be clear to explain when and why we need this information and the purposes for which we will use it and will obtain your explicit consent to use sensitive personal information. We do not collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services or respond to your enquiries). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- Enquire about or book our products or services;
- Create an account on our website;
- Subscribe to our service club or subscribing to our publications;
- Request marketing to be sent to you;
- Enter any competition, promotion or survey we may promote; or
- Give us feedback or contact us.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. You can view and edit your cookie settings at any time when visiting the site.
- For further information on our use of cookies, including a detailed list of your information which we and others may collect through cookies please our section below or else visit:
www.aboutcookies.org
www.allaboutcookies.org
- Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
- Technical Data from the following parties from analytics providers such as Google based outside of the UK.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as payment services providers, financial institutions and credit search providers.
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.
- Information about you from other sources (such as vehicle and parts manufacturers, credit reference agencies, medical professionals, or your employer), which we will add to the information we already hold about you.
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:- Where we need to perform the contract we are about to enter into or have entered into with you - in these circumstances, we will process your data only where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract;
- Where it is necessary for our legitimate interests (or those of athird party) and your interests and fundamental rights do not override those interests - a legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. Where we are processing your personal data in these circumstances we:
- Will consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests; and
- Will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or we are otherwise required or permitted to by law).
- You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
- Where we need to comply with a legal obligation - this means we are processing your personal data only where it is necessary for compliance with a legal obligation that we are subject to.
Purposes for which we will use your personal data
We have set out below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
To register you as a new customer and identify you and manage any accounts you hold with us | (a) Identity (b) Contact | Performance of a contract with you |
To process and deliver your order including: (a) Managing payments, fees and charges (b) Collecting and recovering money owed to us (c) Providing you with payment options (d) Ensuring that you can afford any financial agreement offered (e) Administering your any finance agreements including updating you on and delivering our services | (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey (c) Maintaining a service record for your vehicle, conducting research, statistical analysis and behavioural analysis (d) Carrying out customer profiling and analysing purchasing preferences | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Transaction | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
To enable you to partake in a prize draw, competition or complete a survey | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
To administer and protect our customers, business and this website (including fraud detection and prevention, troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
To deliver relevant website content and advertisements to you (where you agree) and measure or understand the effectiveness of the advertising we serve to you | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical | Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | (a) Technical (b) Usage | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
To make suggestions and recommendations to you about goods or services that may be of interest to you including MOT and service reminders where we believe this would be helpful or of interest | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications | Necessary for our legitimate interests (to develop our products/services and grow our business) |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:- Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing. - Third-party marketins
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. - Opting out
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions. - Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
Cookies we use include:
Facebook pixel - The Facebook pixel is code that we place on our website. It helps us track conversions from Facebook ads, optimize ads based on collected data, build targeted audiences for future ads, and remarket to qualified leads - people who have already taken some kind of action on our website;
Google remarketing cookie - We use Google's 'IDE' cookies technology to serve you relevant ads on third-party websites including Google, after you have visited and left our website. You can find more information about how you can opt out of Google's use of cookies by visiting Google's ad setting website https://adssettings.google.com/authenticated; and
Google analytics - We use Google Analytics to help us analyse data reports from visitors to our website and to gain a deeper understanding of the customer experience, so we can make improvements. Whilst the service does not collect any of your personal data such as name, address, post code, email address, it does collect data such as your I.P address, browser and computer settings, like screen resolution, operating system, how long you stay on the website, which pages you view and how many times, an approximate location, the referral source which brought you to our website and how you exit the pages.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
CALL MONITORING DISCLOSURE
Please note that for quality assurance and training purposes, we may monitor or record incoming calls. This helps us improve our service and ensure the best possible experience for our customers. Your privacy is important to us, and any recordings will be handled in accordance with our privacy policy.DISCLOSURES OF YOUR PERSONAL DATA
Personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.
- External Third Parties such as:
- Service providers acting as processors who provide IT and system administration services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
- Credit reference agencies and fraud prevention organisations acting as processors or joint controllers.
- Vehicle manufacturers (e.g. in relation to warranty claims and vehicle repairs).
- Insurance providers (e.g. where we are helping you source insurance for your vehicle).
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
INTERNATIONAL TRANSFERS
We do not usually transfer your personal data outside the UK. If we do (or a third party on our behalf does) transfer your personal data out of the UK, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:- only transferring your personal data to countries that have been deemed to provide an adequate level of protection for personal data; and
- where we use certain service providers, using specific contracts approved for use in the UK which give personal data the same protection it has in the UK. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed including, amongst other things:- limiting access to your account by using a password and user name that are unique to you;
- storing your personal data on secure servers; and
- encrypting payment details using SSL technology (typically you will see a lock icon or green address bar (or both) in your browser when we use this technology).
- In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
DATA RETENTION
How long will you use my personal data for?We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are set out in the table Purposes for which we will use your personal data above.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymise your personal data (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.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
No fee usually required
You will not have to pay a fee to access your personal data (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 could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could 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.