Privacy & Legal

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

In certain circumstances, where we intend to use photographs of you for promotional purposes (see point ₍₁₀₎ under Legitimate interests for further details), such photographs may include and/or reveal special categories of personal data about you (for example, religious or philosophical beliefs, information about your health). In such circumstances, we will only process your personal data provided that we have obtained your prior written consent. You should notify us immediately if you feel that any sensitive personal data may be exposed by the sharing or use of your image.

We may use automated systems and tools to support certain business processes, such as risk assessment, fraud prevention, affordability checks, identity verification, or record management.

These tools may analyse personal data using predefined criteria or rules to generate indicators, scores, or recommendations. However, we do not make decisions that have a legal or similarly significant effect on individuals based solely on automated processing. Any such decisions are subject to meaningful human review.

The use of these tools may influence the speed or level of review applied to an application or request, but individuals will not be subject to automatic rejection or adverse decisions without human involvement.

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 Lease, sales, maintenance & repair and other enquires

1. To respond to correspondence, you send to us and fulfil the requests you make to us (for example: Lease enquires, test drives, service requests, or information about specific vehicles);

2. To provide vehicle support and services (for example maintenance & repair and warranty services);

3. 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

4. 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

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

5. 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, 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.

6. 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 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;

7. 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;

8. 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);

9. To administer competitions and promotions that you enter with us from time to time and to distribute prizes;

10. To capture and use images of your interactions with us, and which feature you, for promotional purposes through various mediums including but not limited to our website and social media platforms. You have the right to inform us of your preference not to be photographed and featured in our promotional material.

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

11. 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;

12. 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);

13. To inform you of updates to our terms and conditions and policies.

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

We share your personal data with our affiliate, Sinclair Motor Holdings Ltd (“Sinclair Group”). The sharing of your information is necessary for our legitimate interest in managing and maintaining a centralised customer database which we may use to promote and grow the business, brands and products, as further detailed under the “Legitimate Interests” heading above. We take steps to ensure that Sinclair Group complies with data protection legislation and protects your information just as we do.

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: tyre suppliers, franchised motor dealers who service or repair your vehicle, customer contact centres, direct marketing communications agencies and consultants, market research and market analytics service providers, our legal and other professional advisors.

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.

Your personal information will become the basis of a legal contract should you apply for any of our Finance & Leasing products and will be passed on to recognized credit searching companies which will assist in our decision to grant or decline credit.

Your personal data may be shared with financial services organisations, such as companies who provide hire-purchase funding and banks providing such funding. This is for the purpose of securing such funding on your behalf. We may provide personal data to enable these financial services organisations to carry out necessary searches in order to enable them to make a funding decision for you and meeting their legal and regulatory requirements.

International Transfers

We do not generally transfer your personal information outside the UK. However, there may be instances in which either we, or our third-party suppliers (with whom we share your information as referred to above) have cause to do so. In any instance in which your information is transferred outside of the UK, you can expect a similar degree of protection in respect of your personal information as is applied within the UK under the current data protection legislation. This will be achieved by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; and
• Where we use certain service providers, we may use specific contracts approved for us in the UK which give personal data the same protection it has in the UK.

Should you have any queries regarding this issue or should you wish to obtain a copy of any relevant documentation then please contact:

Post: Data protection Compliance Manager, Sinclair Group, Old Field Road, Bridgend CF35 5LJ

Email: dataprotection@sinclairgroup.co.uk

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, 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:

1. Ask for access to and a copy of the information we hold about you;
2. Correct and update your information;
3. 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;
4. 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;
5. 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;
6. 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;
7. 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.