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Vertu Motors Group Privacy Policy (last updated: January 2018)

Summary

As part of your dealings with any member of the group of companies of which Vertu Motors plc is the holding company (each company being a “Vertu entity”) we will collect and otherwise process personal information about you in order to supply vehicles, goods and services to you and to administer our relationship with you. This may involve sharing your personal information with third parties. This Privacy Policy describes in detail how we will use your personal information and how you can exercise your rights with respect to your personal information.

If we decide to change this Privacy Policy, we will post the updated Privacy Policy on our websites so that you are always aware of what personal information we collect, how we use it and under what circumstances we disclose it. The updated Privacy Policy will take effect as soon as it is posted on our Websites.

Introduction

In this Privacy Policy, references to we, us or our (or words of similar import) means the Vertu entity that processes your personal information (as defined below) and interacts with you (for example, the entity from whom you purchase a vehicle or other services).

The documents you receive from any Vertu entity will identify the relevant Vertu entity that you are dealing with in any particular instance.

These include:


and for the purposes of this Privacy Policy Vertu Motors Plc and the Vertu entities in the same group as Vertu Motors Plc (including those listed above) shall constitute the Vertu Group.

In this Privacy Policy, references to you mean the person whose personal information (as defined below) we collect, use and process. This includes anyone who visits our Websites, contacts us in connection with the purchase of a Vehicle and/or any goods or services we provide or otherwise interacts with us (for example, via a dealership).

In this Privacy Policy, references to a Website means any website owned and operated by or on behalf of any Vertu entity including websites of our dealerships

We are committed to protecting your privacy. We will use your personal information in accordance with the Data Protection Act 1998 up to and including 24 May 2018 and the EU General Data Protection Regulation 2016/679 thereafter (GDPR) (together the Data Protection Legislation). and other applicable laws and regulations that relate to data protection and privacy.

Who is responsible for your personal information?

For the purposes of the Data Protection Legislation the relevant Vertu entity is the data controller in respect of your personal information that we collect and process as further described in this Privacy Policy.

We may share your personal information with other organisations that may receive and process your personal information as a data controller in their own right. Please see below for further information.

What information do we collect?

We may collect and process information about you, including your name, date of birth, address, contact details (including email address and mobile phone number), vehicle details, purchase history and data collected as part of any finance application or payment (including previous addresses, employment details and bank account details). This information is referred to in this Privacy Policy as personal information.

In particular, we may collect and process the following personal information about you:


If you provide us with personal information about another person, you must ensure that before you provide us with their personal information, you have their agreement to do so and that they are aware of the ways in which we use personal information as set out in this Privacy Policy.

We may also collect non-identifying information about your preferences in connection with our Websites, for the purposes of enhancing and personalising your experience on the Websites. We may provide our manufacturer partners and our advertisers with aggregate information about Website users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience.

How do we use your personal information?

We use your personal information in connection with our business activities. In particular, we may use your personal information in the following ways:


In accordance with your preferences, we may also use your personal information to provide you with information about vehicles, services, promotions and offers that may be of interest to you. The section below entitled "What choices do I have?" explains how you can change whether to receive this information. Please note that, even if you choose not to receive this information, we will use your personal information to provide you with important services communications, including communications in relation to any purchases you make or vehicle support services as we have a legitimate interest and or contractual obligation to you to do this.

Your personal information may also be used by us, our employees, contractors or agents, and disclosed to third parties, in order to comply with any legal obligation (including in connection with a court order), or in order to enforce or apply the terms of any agreements we have with or otherwise concerning you (including agreements between you and us (or one or more Vertu entity), or to protect our rights, property or safety or those of our customers, employees or other third parties.

With whom do we share your personal information?

In connection with the above uses of your personal information, we may share your personal information with third parties as described below. We will share your personal information with other Vertu entities in the Vertu group) for the purposes set out above and below.

We may disclose your personal information to third parties in connection with our business activities, including in the following circumstances:


We may share non-personal aggregate statistics (group) data about visitors to our Websites, sales and traffic patterns with members of the Vertu Group and other parties.

Protecting your personal information

Our security procedures mean that we may occasionally request proof of identity before we are able to disclose sensitive information to you.

The transmission of information via the internet is not completely secure; this risk is not specific to our Websites and is common across the internet. We cannot guarantee the security of your data (including your personal information) transmitted to our Website; any transmission is at your own risk.

What choices do I have?

If you think the personal information we hold about you is inaccurate or incorrect, you can request that we correct this information (including your marketing preferences) by writing to us using the details below.

You can choose to stop receiving marketing emails or SMS messages from us by following the unsubscribe link and instructions on the respective marketing emails or SMS messages we send you.

You can also choose to change your marketing preferences by writing to us using the details below.

Access to your personal information

The Data Protection Legislation gives you the right to access your personal information. To request access to your personal information, please contact us using the details below.

Right to be forgotten

You have the right to request that Vertu Group delete your personal data in certain circumstances if you would like more information about this please contact us using the details below.

Third Party sites

Our Websites contain links to other websites. This privacy policy applies only to our Websites‚ so visitors should always be aware when they are moving to another site and read the privacy statement of any site which collects personal information. We cannot be responsible for the privacy policies and practices of other sites even if you access those using links from our Websites.

We do not pass on any personal information about our visitors to any other site (unless we have obtained your consent to do so). In addition, if you linked to a Website from a third party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party site and recommend that you check the policy of that third party site and contact the owner or operator if you have any concerns or questions.

Transferring your information outside of Europe

As part of the services offered to you through the Website, the information which you provide to us may be transferred to countries outside the European Economic Area (EEA). By way of example, this may happen if any of our servers are from time to time located in a country outside of the EEA. If we transfer your information outside of the EEA in this way, we will take steps to ensure that it is to a country with data protection laws which are at least as stringent as those in England.

If you use our services while you are outside the EEA, your information may be transferred outside the EEA in order to provide you with those services.

Cookies

Our website uses cookies. A cookie is a small file of letters and numbers that we put on your computer if you agree. These cookies allow us to distinguish you from other users of our website, which helps us to provide you with a good experience when you browse our website and also allows us to improve our Website.

The cookies we use are "analytical" cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the site when they are using it. This helps us to improve the way our website works, for example by ensuring that users are finding what they are looking for easily.

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

How to contact us

If you have any questions, comments or requests regarding this Privacy Policy, please feel free to contact us by writing to us at: Data Protection Officer, Vertu Motors Plc, Vertu House, Fifth Avenue Business Park, Team Valley, Gateshead, Tyne & Wear, NE11 0XA or emailing on [email protected]


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