Sinclair Group Privacy Statement

Sinclair Group ("we" / "us") are committed to protecting and respecting any personal information you share with us. Personal information means any information about an individual from which that person can be identified. It does not include data where that information has been removed (anonymous data).

The Sinclair Group is a "data controller". This means that we are responsible for deciding how we hold and use personal information about you. We are required under the data protection legislation to notify you of the information contained in this notice.

This statement describes what types of personal information we collect from you, how it is used by us, how we share it with others, how you can manage the information we hold and how you can contact us.

We will always give you the option not to receive marketing communications from us. We will never send you unsolicited junk email or communications, or share your data with anyone else who might. We do not sell your information to third parties, but we do work closely with selected partners who help us to provide you with the information, products and services that you request from us. For example, Volkswagen Group UK or Mercedes-Benz UK.

The contents of this statement do not form part of any contract that we may have with you and we may change it from time to time so you may wish to check this page occasionally to ensure you are still happy to share your information with us. Where possible, we will also contact you directly to notify you of these changes.

The Sinclair group is made up of: Mercedes-Benz, Smart, Audi, Volkswagen, Volkswagen Commercial Vehicles, Skoda & SEAT for sales, service & repair including body repair.

What information we collect?

We collect personal information about you and your vehicle when you contact us or engage with our website, applications or a vehicle manufacturer partner. We only collect information which is necessary, relevant and adequate for the purpose you are providing it for.

We collect information about you or your vehicle when you use Sinclair Group’s websites, applications, when you visit one of our businesses and when you are in contact with a member of staff by telephone, email or in person. The information we collect, store and use includes some or all of the following:

• Name (including title);
• Address;
• Phone number;
• Date of birth;
• Email address;
• Vehicle information (including registration number, VIN, service reminders, mileage and warranty repair information);
• Driving licence details
• Your IP address;
• Cookie, Pixels or Beacon information (for more information please see our Cookie Policy);
• Details of any transactions between you and us;
• Where you engage with us in a business context, we may collect your job title, company contact details (including email address), fleet size and company details;
• Voice recordings of calls you make & receive from Sinclair Group;
• "Live chat" records;
• Any information within correspondence you send to us;
• Bank details
• Payment information, when you make a payment to Sinclair Group you may provide payment information such as your payment card or other card details. We use payment card industry compliant third-party payment services and we do not store your credit card information.
• CCTV recordings

How do we use this information?

Sinclair Group will only process information that is necessary for the purpose for which it was collected and how the law allows us to. You will always have the option not to receive marketing communications from us (and you can withdraw your consent or object at any time). We will never send you unsolicited junk email or communications, or share your personal information with anyone else who might.

There are various ways in which we may use or process your personal information. We list these below:

Consent:

Where you have provided your consent, we may use and process your information to:

• Share your personal information with our recommended third-party partners, for example Mercedes-Benz, Audi, Volkswagen, Volkswagen Commercial Vehicles, Skoda & SEAT so they can contact you with marketing information about their products and services (we will, of course, give you details about these third parties before you give permission for us to send information to them).

You can withdraw your consent at any time by contacting the third-party partners on the details provided within their Privacy Statements:

Mercedes-Benz

Audi

Volkswagen

Volkswagen Commercial Vehicles

Skoda

SEAT

In relation to any marketing message you receive, by using the unsubscribe option included in those messages.

Contractual performance

We may use and process your personal information where this is necessary to perform a contract with you and to fulfil and complete your orders, purchases and other transactions entered into with us (or one of our selected partners)

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you, such as the provision of goods or services.

Legitimate Interests

We may use and process your personal information as set out below where it is necessary for us to carry out activities for which it is in our legitimate interest as a business to do so.

Processing necessary for us to support customers with sales, maintenance & repair and other enquires

• To respond to correspondence you send to us and fulfil the requests you make to us (for example: test drives, service requests, brochure requests or information about specific vehicles);
• To provide vehicle support and services (for example maintenance & repair and warranty services);
• Contact you from time to time about promotions, events, products, services or information which we think may be of interest to you (don’t worry, we won’t bombard you);

Processing necessary for us to respond to understanding customers’ and drivers’ needs

• To undertake research (including contacting you with customer surveys) so that we can better understand you as a customer and provide tailored offers, products and services that we think you will be interested in
• In some cases, we may use automated methods to analyse, combine and evaluate information that you have provided to us. We collect and analyse this information in this way so that we can deliver the most appropriate customer experience to you by tailoring and making relevant all our service and communications (for example, when your mileage suggests your vehicle is due for a service)

Processing necessary for us to promote our business, brands and products and measure the research and effectiveness of our campaigns

• To send you marketing information from time to time after you have purchased a product or service from us or made a purchasing enquiry, or requested a test drive, brochure or other information of interest. We will only contact you with the information about our own products and services (and in ways the law allows), which we hope you will like. You have the right to object to us sending you this information at any time.
• To contact you from time to time with marketing information (unless you object) if you have expressly indicated to us that you are acting on behalf of a business or where we have obtained your business contact details from a vehicle manufacturer partner or an online or public business directory. In relation to any such information we send by email or SMS, we include an option allowing you to object to receiving future messages by unsubscribing;
• To contact you with targeted advertising delivered online through social media and other platforms operated by other companies, unless you object. You may receive advertising based on information about you that we have provided to the platform or because, at our request, the platform has identified you as having similar attributes to the individuals whose details it has received from us. To find out more, please refer to the information provided in the help pages of the platforms on which you receive advertising from us;
• To identify and record when you have received, opened or engaged with our website or electronic communications (please see our Cookie Policy for more information);
• To administer competitions and promotions that you enter with us from time to time and to distribute prizes;

Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively

• Use automatic number plate recognition when you visit some of our sites to alert us to your arrival at our premises.
• For network and information security purposes i.e. in order for us to take steps to protect your information against loss, 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 within our management system in order to be able to comply with your request);
• To inform you of updates to our terms and conditions and policies.

Legal Obligation

We may process your personal information to comply with our legal requirements (for example to register and tax your car with the DVLA)

If you fail to provide certain information when requested, we may be prevented from complying with our legal obligations.

Vital Interest

Sometimes we will need to process your personal information to contact you if there is an urgent safety or product recall notice and we need to tell you about it.

How do we share this information?

We will share your personal information with third parties or within the Sinclair Group where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

We do not sell your information to third parties, but we do work closely with our vehicle manufacturer partners:

Mercedes-Benz

Audi

Volkswagen

Volkswagen Commercial Vehicles

Skoda

SEAT

and third-party suppliers who fulfil business activities for us, which necessitates the sharing of information.

We may also from time to time disclose your information to the following categories of companies or organisations to which we pass the responsibility to handle services on our behalf: customer contact centres, direct marketing communications agencies and consultants, market research and market analytics service providers, our legal and other professional advisors.

We will also share your information with our vehicle manufacturer partners in situations where we need to pass your information to them in order to manage any requests or complaint you have made to us. For example, where you have made a complaint to ourselves and we need to liaise with the manufacturer customer care department.

We take steps to ensure that any third-party partners who handle your information comply with data protection legislation and protect your information just as we do. We only disclose personal information that is necessary for them to provide the service that they are undertaking on our behalf.

There are circumstances where we share your information with our vehicle manufacture partners (or other companies within their Group or finance companies) in order to fulfil orders, transactions, handle complaints or provide you with a service or information that you have requested. For example, we will share information with the above organisations where you enquire about their services through us or where you make a complaint to us and later make the same or similar complaint to them. These organisations may use your information to provide you with information and carry out their obligations arising from contracts you enter into with them. For more information, please see their privacy statements.

Volkswagen Financial Services UK Limited

Mercedes-Benz

Black Horse Finance

MotoNovo Finance

Mann Island Finance

iVendi

How long do we keep your information for?

We will not hold your personal information in an identifiable format for any longer than is necessary, including for the purposes of satisfying any legal, accounting or reporting requirements. If you are a customer or otherwise have a relationship with us we will hold personal information about you for a longer period than if we have obtained your details in connection with a prospective relationship.

Save as may be otherwise required, if we have a relationship with you (e.g. you are a customer or the registered driver of a leased or other vehicle purchased from us), we hold your personal information for 6 years from the date our relationship ends (which we deem to be either 3 years since your last workshop visit or you haven’t taken delivery of a vehicle from us in the last 4 years). We hold your personal information for this period to establish, bring or defend legal claims.

Save as may be otherwise required, where we have obtained your personal information following a request for information, test drive, brochure, quotation or any other information on any of our products or services, we hold your personal information for 1 year after the last contact with you, unless during that period we form a relationship with you e.g. you purchase or lease a vehicle. We hold your personal information for this period to give us an opportunity to form a relationship with you.

How can I manage the information we hold about you?

It is important that the personal information that we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

You have the right as an individual to access your personal information we hold about you and make corrections if necessary. You also have the right to withdraw any consent you have previously given us and ask us to erase information we hold about you. You can also object to us using your personal information (where we rely on our business interests to process and use your personal information)

You have a number of rights in relation to your personal information under the data protection law. In relation to most rights, we will ask you for information to confirm your identity and, where applicable, to help us search for your personal information. Except in rare cases, we will respond to you within 30 days after we have confirmed your identity.

You have the right to:

• Ask for access to and a copy of the information we hold about you;
• Correct and update your information;
• Withdraw your consent (where we rely on it). Please see further information in "How do we use this information" section. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purposes you originally agreed to, unless we have another legitimate basis or requirement for doing so in law;
• Object to our use of your information (where we rely on our legitimate interests to use your personal information or where we are processing your personal information for direct marketing purposes) provided we do not have any continuing lawful reason to continue to use and process the information. When we do rely on our legitimate interests to use your personal information for direct marketing, we will always comply with your right to object;
• Erase your information (or restrict the use of it), provided we do not have any continuing lawful reason to continue to use and process that information;
• Request the restriction of processing of your personal information which enables you to ask us to suspend processing, where for example you want us to establish the accuracy or the reason for processing the information concerned;
• Transfer your information in a structured data file (in a commonly used and machine-readable format), where we rely on your consent to use and process your personal information or need to process it in connection with your contract.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is an appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

You can exercise the above rights and / or manage your information by contacting us using the details below:

Post: Data protection Compliance Manager, Sinclair Group, Swansea, SA4 9GW

Email: dataprotection@sinclairgroup.co.uk

If you have any specific data protection concerns or a complaint, you can address it to our Data Protection Manager at dataprotection@sinclairgroup.co.uk

If you are unhappy, you have the right to lodge a complaint with a data protection regulator in Europe, in particular in a country you work or live or where your legal rights have been infringed. The contact details for the Information Commissioner’s Office, the data protection regulator in the UK, are below:

Post:
Information Commissioner’s office, Wycliffe House Water Lane, Wilmslow, Cheshire, SK9 5AF

Call: 0303 123 1113

Email: casework@ico.org.uk