Under EU data protection laws, personal information may only be used where one of the following applies:
- You have consented to the use
- We use it to achieve a legitimate interest, and our reasons for using it outweigh any prejudice to your data protection rights
- It is necessary to enter into or perform a contract with you
- We need to use it to comply with our legal obligations
- The use is necessary for us to protect your vital interests (or another person’s)
- We need to use it to perform a task in the public interest
Generally, we will process data on one of the first two grounds listed above. If we are processing on the basis of consent, you will be presented with an opportunity to consent at the point where we collect your data. You may withdraw your consent at any time through the data preference centre (see further details below). If we are processing on the basis of our need to achieve a legitimate interest, the nature of that interest is set out below.
WHAT INFORMATION DO WE COLLECT?
If you visit our website
When someone visits www.tmcmotors.co.uk we use a third party service, Google Analytics, to collect standard internet log information (your IP address, browser, and type of device) and details of visitor behaviour patterns (where you joined our site from, the path you take through our site and where you leave). We do this for the legitimate business purpose of monitoring the number of visitors to the various parts of the site and engagement levels, which in turn enables us to make improvements. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website.
If you contact us via social media
We use a third party provider, Hootsuite, to manage our social media interactions.
If you send us a private or direct message via social media, this will be received by Hootsuite. Your social media user name and message (including any personal information you choose to include in it) and will be stored by Hootsuite for three months, and used by Thatchers Motor Company Limited for the legitimate business purposes of monitoring our reputation levels and social media engagement (and taking steps to improve this) and responding to any queries raised in the message. It will not be shared with any other organisations.
If you call our contact numbers
When you call Thatchers Motor Company a representative may record your contact number and store in in our CRM. We may collect this for the legitimate business purpose of processing your enquiry (we may collect both email and telephone contact details in case we cannot reach you using one of these). We may use the data to contact you in the future where we have a legitimate interest in doing so (but you may ask for it to be deleted in accordance with the section below on your rights to manage your personal information).
If you email us
Any email sent to us, including any attachments, may be monitored by us for cybersecurity reasons. Email blocking software may also be used. Thatchers Motor Company Limited has a legitimate business interest in using your email address, and any personal data included in your message, to resolve and respond to any issues raised. Your email will be handled in line with our policies, depending on the nature of your enquiry.
Emails sent to named individuals within Thatchers Motor Company Limited (e.g. email@example.com) will be stored on our CRM systems indefinitely for the legitimate business purpose of resolving your enquiry and then checking how enquiries have been dealt with, but will not be processed for any other purposes. Please be aware that you have a responsibility to ensure that any email you send to us is within the bounds of the law.
If you use our enquiry form
When you submit information via our enquiry form, we collect your name, email address and telephone number. We need to collect this for the legitimate business purpose of processing your enquiry (we collect both email and telephone contact details in case we cannot reach you using one of these). We may use the data to contact you in the future where we have a legitimate interest in doing so (but you may ask for it to be deleted in accordance with the section below on your rights to manage your personal information).
If you work for a customer
Our customers provide us with names and contact details (email addresses and phone numbers) of people within their business who are involved in managing Thatchers Motor Company Limited products.
These details are stored within our CRM system for the legitimate business purpose of allowing access to our products. They are retained in the system until the customer chooses to delete them.
The details are also stored indefinitely on our CRM system (see above) and used for the following legitimate business purposes:
- To contact you regarding the running and management of the customer account;
- To send you emails about updates to our products;
- To send you marketing emails about new products (these emails will contain details of how you can opt out of future marketing communications, or you can opt out using our data preference centre);
- To contact you periodically after the end of a contract to see if you are interested in working with us again
If we contact you as part of an email campaign going to all our contacts, we may use a third party e-mail campaign provider. If the provider is based in the US, we will ensure that they are part of the EU-US privacy shield framework.
If you make a complaint to us
When we receive a complaint from a person we make up a manual file containing the details of the complaint and store it. The file normally contains the identity of the complainant (together with any contact details provided) and any other individuals involved in the complaint.
We will only use the personal information we collect for legitimate business purposes, i.e. processing the complaint and checking on the level of service we provide.
We usually have to disclose the complainant’s identity to whoever the complaint is about. This is inevitable where, for example, the accuracy of a person’s record is in dispute. If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis.
We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for three years from closure. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.
HOW CAN YOU MANAGE YOUR PERSONAL INFORMATION?
Under data privacy laws, you have the rights to:
- Request access to your personal data
- Request deletion or correction of your personal data
- Request that your personal data be transferred to another person
Our online data preference centre helps you to exercise the rights that data privacy laws give you and control your personal information. It contains five separate forms, as set out below.
See your data
You can ask to see any personal information that we hold (known as a “subject access request”) by writing to us, addressing it to our Data Protection Officer at the address provided below.
If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.
Transfer your data
You can ask us to provide your data to a third party by writing to the Data Protection Officer.
Delete your data
You can ask us to delete the information we hold about you by writing to the Data Protection Officer
Change your data
If we do hold information about you, you can also ask us to correct any mistakes by writing to the Data Protection Officer
You can tell us how you would like us to send you marketing information, or ask us to stop marketing to you entirely. Just contact the Data Protection Officer at the address below.
Any data collected through the data preference centre is stored indefinitely so that we are able to demonstrate our compliance with data privacy laws.
DO WE SHARE YOUR PERSONAL INFORMATION?
Other than as outlined above (for example where we use third party service providers), we will not usually disclose personal data. However we may disclose your information to third parties in the following circumstances:
- If we are under a legal or regulatory obligation to do so
- If we believe you are or may be a threat to safety, security, property, our rights or the rights of others
- In a merger, acquisition, change of control, joint venture or other business combination involving Thatchers Motor Company Limited
HOW CAN YOU MAKE A COMPLAINT ABOUT OUR USE OF DATA?
Thatchers Motor Company Limited tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.
Any complaints should be addressed to the Data Protection Officer using the contact details below. If we fail to resolve your complaint to your satisfaction, you have the right to contact the UK Information Commissioner. For further information on how to do that, please go to the following webpage: https://ico.org.uk/concerns.
HOW CAN YOU CONTACT US?
FAO Data Protection Officer
The Yard, Oakhanger, Bordon, Hampshire, GU35 9JU
Last Updated: January 2019.