Richard Sanders Ltd Privacy Policy
Summary
As part of your dealings with any member of the group Richard Sanders Ltd 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 Richard Sanders Ltd Group 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).
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 the website owned and operated
by or on behalf of Richard Sanders Ltd
We are committed to protecting your privacy. We will use your personal information in
accordance with the Data Protection Act 2018 and the UK GDPR (as defined in The Data Protection, Privacy and
Electronic Communications Amendments etc.) (EU Exit) Regulations 2019 both as amended from time to time
(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 Richard Sanders Ltd is the data
controller in respect of your personal information that we collect and process as further described in this
Privacy Policy. All information is stored on a group database so will be shared with other organisations in
the Richard Sanders Group who may act as data processors.
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, payment and bill information, and bank account and credit or debit card details). We may
also obtain copies of your driving licence and other identification, and your vehicle insurance 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:
Information that you provide by filling in forms, including those on our Websites and
those on third-party websites that contain advertisements for our vehicles, and information provided by you
as part of a purchase or potential purchase on our Websites, even if that purchase does not proceed.
A copy of your driving licence when you test drive a vehicle or are provided with a
courtesy car or data provided by an online checking service regarding your driving licence and any
penalties.
When you enquire about or purchase a vehicle or services we collect personal
information to respond to your enquiry and to process and complete your purchase.
Details about the transactions you carry out with us including vehicle support
services and vehicle purchases and purchases of other goods.
CCTV footage in which you feature when you visit our premises.
Information contained in records of communications between us, including e-mails,
letters and text messages. We may also record calls between us for training, monitoring and quality control
purposes. Currently calls made directly to or from dealerships are not recorded, however our telephone
system does note the date, time, telephone number and call duration.
Details of your visits to our Websites, including, but not limited to, traffic data,
location data (including the country and telephone area code where your computer is located), IP (internet
protocol) address, browser and operating system information, and the resources that you access (including
the pages of our Website that you view and the website from which you access our Website). For more details
of how we collect data through the use of cookies, please see the separate cookies policy on our Websites.
You may be able to disable the collection of some of this data through amending the web settings of your
device or browser but doing so may impact the functionality of our website
Details of your device and Google ID if you SMS "sign" or open a document that we
send to you by SMS.
Information concerning your marketing preferences where these rely on consent.
Information relevant to the insurance products that we sell that are provided by
third parties.
Information from you to enable us to propose you for vehicle finance, as required by
the relevant third party finance company. This will include financial and employment information and
verification documents.
Details of diagnostic tests and work carried out on your vehicle including video
footage and records of parts used.
If you follow or comment on social media posts from or shared by the company, we may
collect details that are part of your public profile on social media sites.
Details regarding your family members if they are provided to us as part of a vehicle
purchase, or for example, if another family member is using or collecting your vehicle.
We may be provided with personal information about you by manufacturers or finance
companies if you have purchased a vehicle or enquired regarding a vehicle or work to be done.
Details supplied by you as part of a competition or prize draw entry.
Your details and details of your current vehicle when you provide details to us for
valuation, or obtain a valuation on one of our Websites.
There may be circumstances when we collect special categories of personal data
regarding your health, sexual orientation or criminal convictions, if you provide this information to us as
part of a discussion regarding your vehicle or vehicle enquiry. In particular, if you use the Motability
scheme, we may collect details about your disability and health to administer your application and verify
your eligibility for the scheme.
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 collect and process information we receive about you from third parties. This
information may include your personal and financial information, your employer, companies that you are
connected with (such as a Director) or other person connected with your finance application; information
about the vehicle you are purchasing credit information, such as previous applications, the conduct of
accounts in your and your financial associates' name (this is anyone linked to you for credit or finance
purposes), any business accounts you have and public information such as County Court Judgements,
bankruptcies and the Electoral Register.
We may also collect information about your preferences in connection with our
Websites and your activity on 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:
to respond to queries from you regarding the possible purchase of goods or services,
including looking at your searches and history on our Websites prior to an enquiry and combining the data
held on our systems with your activity on our Websites and your Google ID;
to carry out our obligations arising from any contracts entered into between you and
us including purchase of vehicles and provision of services, and to respond to queries from you regarding
those contracts;
if you have asked for a vehicle valuation from us, to contact you regarding feedback
or a potential purchase of that vehicle for up to 6 months afterwards;
to manage and administer the relationships between you and us;
to notify you about changes to our services and to otherwise communicate with you;
for example, we will use your contact details in order to respond to any queries that you submit to us;
and
to obtain feedback from you regarding us and the manufacturer of your vehicle;
to provide you with information regarding other services and products that are
available to you from us or third parties;
to provide you with reminders regarding your vehicle including, for example, when
your vehicle is due to have a service or MOT undertaken;
to contact you when you may be in a position to change your vehicle, including when
your finance agreement is due for renewal. In some cases, we will be asked to contact you by a vehicle
manufacturer or finance company;
to offer assistance with your transactions with us where you have partially, but not
fully, completed an online transaction.
If you enquire about a potential vehicle purchase, lease or hire of a vehicle and/or
any goods or services, we will use your information to contact you for up to 3 months about that potential
purchase, lease or hire and, in the case of potential vehicles, will ask you to agree for us to carry out a
soft credit search (using an external credit reference agency) to enable us to provide you with finance
quotes at a rate that matches your credit history. We may then provide your details and credit score to up
to 3 lenders if you wish to apply for finance for your purchase. If you go ahead and purchase, lease or hire
a vehicle and/or any goods or services from us we will use your information in various other ways, details
of which are provided to you at the time of your purchase, lease or hire. These include:
contacting you to obtain feedback on your purchase or other services provided;
contacting you in the future with MOT and service reminders if you continue to use
our group for servicing/MOT of your vehicle
contacting you in the future if you may be in a position to change your
vehicle.
All of the above are examples of where we believe that we have a legitimate interest
in doing so.
In accordance with your preferences, we may also use your personal information to
provide you with additional 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 information from us that is based on consent/preferences. Please note that, even if you
choose not to receive this information, we may continue to use your personal information in the ways
described above and below.
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 to protect our rights, property or
safety or those of our customers, employees or other third parties.
In addition, where permitted by law, we may combine the information we hold with
information about you or your interests, socio-economic and socio-demographic status, online identifiers and
current contact details collected by third parties such as marketing agencies and from public
sources.
How do we make decisions using your data?
We will use your information to carry out automated decision-making and profiling in
some circumstances. For example, service and MOT reminders will be automatically sent where relevant based
on the vehicle and maintenance information we hold. We will also select customers for marketing campaigns
and offers based on factors such as age of vehicle, type of vehicle finance held and date since last vehicle
purchase as well as previous responses to marketing campaigns and Website activity.
How long do we keep your personal information?
We will not retain information longer than we need to. In general, if you enquire (in
person or online) but do not purchase a vehicle from us, we will keep your information for 2 years to enable
us to deal with future enquiries more effectively and to deal with any concerns regarding the enquiry
process. If you purchase a vehicle from us, or have servicing or repair work carried out, or purchase a part
from us, we will keep your information for 6 years from your last transaction with us. We may keep details
of a vehicle for longer than that but without it being attached to your information.
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 may disclose your personal information to third parties in connection with our
business activities, including in the following circumstances:
We may pass your personal information to third-party organisations that provide
services to us such as web-hosting companies, mailing vendors, analytics providers, prospecting agencies and
marketing agencies, IT and telephone service providers and any third party to whom we sub-contract work
(such as repairs or specialist fitting) or who provide services or offers to our customers on our
behalf.
We may share your name and contact details with Facebook and other social media sites
to enable them to identify you as a customer of the Group and to assess criteria such as age and location to
assist with our marketing on social media.. We do not receive any details from Facebook that we do not
already hold and the data would be used in a generic way only to target advertising.
We may pass personal information to external agencies and organisations (including
the police and other law enforcement agencies) for the purpose of preventing and detecting fraud (including
fraudulent transactions) and criminal activity. We may also disclose personal information to the police and
other law enforcement agencies in connection with the prevention and detection of crime. We may also
disclose your personal data to the police and other law enforcement agencies in connection with driving
penalties and or parking fines we receive if you are test driving a vehicle or have the use of a loan car at
the time oof the offence.
We may pass your personal information including your credit score to third party
finance companies for the purposes of them providing you with finance. Those organisations may carry out
further credit checks and may disclose your data to credit reference agencies for that purpose.
We will pass your personal information to third-party providers of insurance products
that we offer, if you take up the option of purchasing one of those products.
We will provide your information to the DVSA if you buy a vehicle from us to record
you as the registered keeper and to obtain road tax on the vehicle.
If you take out a an extended warranty with a third party provider, we will pass your
information to them to enable them to provide the breakdown insurance if included with that warranty.
We may pass your personal information to third parties if we are under a duty to
disclose or share your personal information 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 members of the Richard
Sanders Group); or to protect our rights, property or safety or those of our customers, employees or other
third parties;
We may pass your personal information to the relevant franchise manufacturer partner
relating to your vehicle, and in some cases whether or not you go ahead and purchase the vehicle. We may
also pass your information to them in connection with servicing and repair of your vehicle, and any warranty
claim you may have, or feedback that you have provided to us. They may use this to register your ownership
of the vehicle and to contact you directly regarding your vehicle and to obtain feedback and/or to provide
offers. Most manufacturers will share your information within their group and this may include information
being transferred outside of the EEA. For some manufacturers we will also ask you whether you consent to
further contact from the manufacturer and pass this consent (or lack thereof) to the manufacturer.
If you purchase a Motability vehicle we will provide your details to Motability
Operations Limited to enable them to contact you regarding your vehicle.
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 third 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 ask us to stop including you in marketing campaigns using profiling by writing to us using
the details below.
You can also choose to change your marketing preferences by writing to us using the
details below. These changes will not prevent all uses of your information (where we believe we have
legitimate interests to use it) but if you are concerned about this you can ask us to stop all contact with
you.
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 Richard Sanders Ltd deletes your personal data in
certain circumstances if you would like more information about this please contact us using the details
below. If you have purchased goods or services from us we will retain details of your purchase for 6 years.
If we are unable to delete your data as we believe that we are required to retain it, we will delete as much
information as we are able to and will also stop sending you any further information.
Third Party sites
Our Website may contain links to other websites. This privacy policy applies only to
our Website, 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 Website.
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 United Kingdom and 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 or we will put in place appropriate safeguards in accordance with our legal obligations to ensure
that your personal information is adequately protected irrespective of the country to which it is
transferred. These safeguards may include obtaining contractual assurances from any third party given access
to your personal information that your personal information will be protected by standards which are
equivalent to those that protect your personal information when it is in the EEA.
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 use 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. You will be asked to set cookie preferences when you access one of our Website for the
first time.
You can 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, Richard Sanders Ltd, Brunel Close, Northfield
Avenue, Kettering, Northants, NN16 9HU or emailing on customerservices@richardsandersgroup.co.uk
You also have the right to make a complaint at any time to the Information
Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We
would, however, appreciate the chance to deal with your concerns before you approach the ICO so please
contact us in the first instance.
Manufacturer-specific information
We will share your information with the manufacturer of your vehicle when you purchase a new
vehicle, and in certain other circumstances. We act as a separate data controller from the manufacturers and
on occasion may act as a data processor for the manufacturers. If you want to update your communication
preferences with the manufacturers, you will need to do this separately to any request made to us, unless
you specifically ask us to communicate with the manufacturer on your behalf by email to customerservices@richardsandersgroup.co.uk