We understand that privacy and the security of your personal information is extremely important. This Privacy statement explains what personal data Downey’s Cars (NI) Ltd collect from you, and how we use that data. We commit to keeping your information secure, as well as informing you of your rights over any personal information we hold about you.
Who are we?
We are Downey’s Cars (NI) Ltd and offer New and Used Car Sales along with ancillary products and Aftersales Services. Our address is 39 Portaferry Road, Newtownards, Co Down BT23 8NN. For purposes of GDPR (General Data Protection Regulations) we are a Data Controller.
What information do we hold about you?
We collect information about you when you register with us or place an order for products or services. We also collect information when you voluntarily complete customer surveys, provide feedback and participate in competitions. This includes personal details for example such as your name, address, e-mail address, telephone number, gender, date of birth, bank details, existing vehicle information, how you like to be contacted, and any other information you choose to submit to us. The above could have been provided to us verbally, by phone, e-mail, letter, Livechat, or when you communicate with us via social media, or our website. We also store call recordings and images taken by CCTV systems that are used on our premises.
Lawful Basis for Processing your Data
Under GDPR (General Data Protection Regulations) and other Data Protection laws we as a dealer can rely on a number of conditions to process your data lawfully.
The processing is necessary for our legitimate interests. This condition does not apply if there is good reason to protect the individual’s personal data which overrides the legitimate interest. Many of the ways we handle and process your personal information fall under the category of legitimate interest. We wish to offer you the best quality service we possibly can, so we have a legitimate interest in relying on selected third-party providers to help monitor and review the performance of our business including our website. We have a legitimate interest in relying on selected third parties to help us to deliver services and contracts to you, for example Credit providers if you have asked us to do so. Also, we have a legitimate interest in processing your data to remind you about service due dates, product updates, MOT due dates, or safety recalls to help protect you and validate any vehicle warranties that may be in place. We may also rely on legitimate interest to let you know about other similar products and services that we think would be of interest and benefit to you.
We are allowed to use your personal data if you have given your permission for us to do so. As far as direct marketing is concerned we would like to send you information about any products and services that we deem would be beneficial and of interest to you, for example, any discount codes we are offering, promotional events we are running, vehicle servicing, product renewals and offers. We will only do this if you have given your consent to direct marketing. We will ask you which method(s) of contact you would prefer i.e. by post, e-mail, text message, or telephone. At any future point, if you have opted-in to all four methods of communication you can opt-out of any single, or all means of communication, at any time by following the process at the foot of this Privacy Notice.
Under this lawful basis of processing your personal data, we will do so to fulfil or prepare a contract with you. You contract with us when you purchase a vehicle, or any associated product such as a Service Plan, Warranty Cover, Asset Protection or book an MOT for example. To perform and deliver on our contracts we require to process your personal information.
This lawful basis to process data is to protect a person’s life or in a medical situation. This would include making sure for example that we can inform you where there are any safety recalls on any of our products.
We have an obligation to process your personal data where we are required to by law. For example, for compliance with legal and regulatory requirements, for activities relating to the prevention, detection and investigation of crime, or when you exercise your rights under data protection law and make requests.
How we use your information
We collect information about you to process your order, manage your requests to us, deliver services to you, help us manage monitor and improve our services to you and, to contact you about other products and services we think may be of interest and benefit to you under one or more of the lawful basis outlined above. This contact by us could be by post, telephone, e-mail or SMS message. Again, having opted in you may opt out of any of these methods of communication at any time using the process outlined at the foot of this Privacy Notice.
For identification purposes we may ask you to provide a copy of your driving licence, passport, utility bills or other legal documents. We use that information to satisfy Test Drive insurance requirements or to complete applications on your behalf for credit facilities to Finance providers where you have asked us to do so. Examples of other information required by Finance providers include your name, address, contact details, employment status, occupation, gender, and Bank details.
Retention of Information
We will retain your personal information only for as long as necessary to fulfil the purposes for which the information was collected and meet any of our statutory legal obligations. Once information is no longer required to fulfil these purposes it will either be destroyed, deleted or made anonymous.
Who might we share your information with
We share your personal information with service providers who are crucial in assisting us to provide our services to you, for example Credit Facility providers (Finance Companies) and the DVLA. We also share your personal data with KMUK (Kia Motors (UK) Ltd. to perform our contract with you and provide services to you.
KMUK Transfer of Data outside of the EEA (European Economic Area)
The majority of personal data provided to KMUK will be hosted in the UK and Germany (within the EEA). Any data passed outside the EEA will be covered by adequate safeguards. Any of your personal data which is transferred to Kia Motors Corporation (KMC) in the Republic of Korea (for example for Global Warranty Management purposes) will be safeguarded by them under standard data protection clauses.
We may share your personal data with Downey’s Rentals Ltd (SIXT) a Downey Group Company.
When someone visits our website www.downeys.co.uk we use Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is processed in a way which does not identify anyone.
To provide web-based services to you our website is managed by Bluecubes Enterprises Ltd and our internal computer systems are maintained by Rightclick-IT Ltd. Our internal Dealer Management System which stores customer data is driven by CDK Global Automotive Systems.
Other Downey service providers with whom we share your data include: Finance Companies, Warranty Providers, Marketing Companies linked to our Kia Franchise, marketing companies who work directly with Downey’s, and Asset Protection (GAP) partners.
Any selected partners or third-party service providers that we share your personal data with, are obligated by Data Protection Legislation to protect that data. We only disclose information that is necessary for them to provide the services that they are undertaking on our behalf.
We will share your information If we are required to by law, under any code of practice by which we are bound, or we are asked to do so by a public or regulatory authority such as Police or Department of Work and Pensions.
Accuracy of Information
We strive to ensure that any personal information we retain, and use is accurate, complete and up to date as necessary for the purposes for which we collected it. We do not routinely update personal information unless necessary for these purposes. However, if our records regarding your information are inaccurate or incomplete, we will amend that information at your request.
Right to Access to your personal information
You have the right to access the personal information that we hold about you in many circumstances. This is called a ‘Subject Access Request’. If we agree that we are obliged to provide personal information to you (or someone else on your behalf), we will provide this to you free of charge.
If you would like to exercise this right, please contact us as set out at the foot of this Privacy Notice.
Right to stop or limit our processing of your data
You have the right to object to us processing your personal information, if we are not entitled to use it any longer. You have the right to have your information deleted if we are keeping it too long, or have its processing restricted in certain circumstances.
If you would like to exercise this right, please contact us as set out at the foot of this Privacy Notice.
How long will we keep your information for?
We will retain a record of your personal information. This is done to provide you with a high quality and consistent service. We will always retain your personal information in accordance with law and regulation. We will also ensure that your personal information is stored in a secure manner.
If you would like to exercise one of your rights as set out above, or you have a question or complaint about this policy, or the way your personal information is processed, then please contact us by one of the following means:
By email: email@example.com
By Post : Data Privacy Downey’s Cars (NI) Ltd. 39 Portaferry Road Newtownards BT23 8NN
Should you not be satisfied with any response we provide to you with regards to how we have used your personal data you have the right to complain to the Information Commissioners Office (ICO) on the following website http://ico.org.uk/concerns/ or by writing to the ICO at the following address:
Information Commissioner’s Office
Wycliffe House Water Lane
Wilmslow Cheshire SK9 5AF
Tel: 0303 123 1113
Policy Notice Changes
This privacy notice is available on our website www.downeys.co.uk where the latest version will be available for you to review at any time. If you do not use or do not have access to electronic communications, then you can request a copy of our latest Privacy Notice by writing to Data Privacy Downey’s Cars (NI) Ltd 39 Portaferry Road Newtownards Co. Down BT23 8NN
Version Date May 2018