1. introduction
This Privacy Notice explains in detail the personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data and keep it safe.
We know that there is a lot of information here, but we want you to be fully informed about your rights and how Busseys and Sabberton Bros Ltd use your data.
We hope the following sections will answer any questions that you may have but if not, please do get in touch with us.
It’s likely that we’ll need to update this Privacy Notice from time to time. We’ll notify you of any significant changes, but you are welcome to come back and check it whenever you wish
2. who is busseys & sabberton bros ltd?
Busseys & Sabberton Bros Ltd – which we will refer to in this document as “Busseys”, is the official registered company name at Companies House to which we trade as Busseys.
For simplicity throughout this notice, “we” and “us” or “Busseys” means Busseys & Sabberton Bros Ltd
3. detailing the legal bases we rely on
The law on data protection (General Data Protection Regulation – GDPR effective 25th May 2018) sets out a number of different reasons for which a company may collect and process your personal data, including:
Consent
In specific situations, we can collect and process your data with your consent, for example when you submit a form on Busseys website requesting contact on a vehicle.
We will always make it clear to you which data is necessary.
Contractual Obligations
In certain circumstances, we need your personal data to comply with our contractual obligations. For example if you order a new vehicle from Busseys we will collect your Title, Full Name and Address details to complete the order of the vehicle with the manufacture
Legal Compliance
If the law requires us to, we may need to collect and process your data. For example, we can pass on the details of people involved in fraud or other criminal activity that has an effect on Busseys to law enforcement
Legitimate Interest
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of the running our business and which does not materially impact your rights, freedom or interests.
For example, we use your previous purchase history with Busseys to send or make available personalised offers to you.
We will use your name and address details to send you direct marketing information by post, telling you about the products and services that we think might be of interest to you.
4. when do we collect your personal data?
When you visit any of our websites and complete and submit a contact form
When you create a Busseys Family account
When you engage with us on social media
When you contact us be any means with enquires, bookings, complaints etc
When you enter prize draws or competitions
When you choose to complete any surveys that we send to you
When you comment and review our services
When you fill in any forms
When our suppliers and partners such as Ford Credit PLC or PSA Finance UK Ltd share information with us about the product that you have purchased
When you visit one of our dealerships which usually have CCTV systems operated for the interest of security for both our employees and customers. These systems may record your image during your visit.
5. what sort of personal data do we collect?
If you have a customer record with us: your name, gender, data of birth, home address, work address, transactional history, email addresses, telephone numbers, vehicles that you own or have owned in the past.
Details of your interactions with us either in dealership, online, via our customer booking team or by telephone.
Copies of documents you provide to prove your age or your identity in line with our contractual obligations with our partners. This will include details of your full name, address, date of birth, and facial image. If you provide your passport, the data will also include your place of birth, gender and nationality.
Details of your visits to our websites, including your IP address, the website from which you visit, the web pages you actually visited, the date and the length of the visit.
Information gathered by the use of cookies in your website browser. Learn how we use cookies and similar technologies.
Your comments, reviews and complaints
Your image may be recorded on CCTV when you visit our dealerships
Your voice via a phone call including the conversation held may be recorded
To deliver a digital experience second to none when you visit our websites, we collect technical information about your internet connection, browser, and type of device you are using as well as the country where your device is located.
Your social media user name, if you interact with us through those channels, to help us repond to your comments, questions and feedback.
Of course, it is always your choice whether you share such details with us.
6. why and how do we use your personal data?
We want to give you the best possible customer experience. One way to achieve that is to get the richest picture we can of who you are by combining the data we have about you.
We then use this to offer you promotions, products and services that are most likely to interest you.
The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.
Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.
Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for
Here’s how we’ll use your personal data and why:
Your name, contact details, purchase history and records of communications | ||
| Purpose | Lawful basis for the processing | How long we keep it |
|---|---|---|
| For adminstrative purposes if you are a current or previous customer to: a) Provide or manage a product or service you have asked for. And / or b) Help us to identify you when you contact us | Necessity to perform our contract with you. Failure to provide such data where we request it may mean we are unable to supply you with the requested product or services. | Seven years from the date on which we supply good or services to you. If you do not purchase from us, 12 months from your last interaction with us |
| To carry out credit checks where you are purchasing products on credit terms. Please note that this only applies to trade account to which we use Credit Safe | Busseys legitimate interest in preventing default of payment | Seven years from the date on which we supply goods or services to you |
| To help us recover debts due to us from you | Busseys legitimate interest in recovery of monies due to us | Seven years from the date on which we supply goods or services to you |
| To bring or defend legal claims | Busseys legitimate interest of bringing or defending legal claims | Where you purchased a product regulated by the FCA, 10 years from the date you bought that product. If not seven years from the date you last dealt with us |
| To contact you about products and services offered by us, using one or more of: Post, Telephone, E-Mail or SMS. This is based on the permissions you have given us. | Your consent | Two years from the date on which you last gave consent to marketing, although we we may retain limted records to the extent required to maintain suppression lists |
Your Purchase History. History about where you have engaged with our emails and or websites | ||
| Purpose | Lawful basis for the processing | How long we keep it |
|---|---|---|
| To help us improve our content, products and services which may include profiling | Busseys legitimate interest as to help us improve our content, products and services | Retained in an anonymised form |
| To identify other products and or services you might be interested in for the purpse of direct marketing which may include profiling | Your consent | |
Your IP address, the website which you visit us, the website pages you actually browsed, the date and length of your visit | ||
| Purpose | Lawful basis for the processing | How long we keep it |
|---|---|---|
| To assist Busseys in secruing and managing the performance of our websites | Our legitimate interest of securing and managing the performace of our websites | Retained in an anonymised form |
Your name, contact details, personal documents to enable us to prove your identity, which may include your driving licence and or passport | ||
| Purpose | Lawful basis for the processing | How long we keep it |
|---|---|---|
| To help us decect and prevent fraud | Busseys legitimate interest in the prevention of loss to the business and others | Seven years from the date on which we supply goods or services to you |
All relevant documents deminstrating the provenance of any values of cash you pay us in excess of £1000. This is likely to include your full name, address, contact details, bank details, and documents in repect of your financial status. | ||
| Purpose | Lawful basis for the processing | How long we keep it |
|---|---|---|
| to help us detect and prevent money laundering | To ensure that Busseys comly with our legal obligation. Failure to supply this information where we request it may result in us being unable to sell you the reqested product or service | Seven years from the date on which we supply goods or services to you |
7. how we protect your data
We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.
We secure access to all transactional areas of our websites using ‘https’ technology.
Access to your personal data is password-protected.
We regularly monitor our system for possible vulnerabilities and attack. We also identify ways to further strengthen security.
8. how long will we keep your personal data?
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.
At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
Your name, contact details, purchase history and records of communications | ||
| Purpose | Lawful basis for the processing | How long we keep it |
|---|---|---|
| For adminstrative purposes if you are a current or previous customer to: a) Provide or manage a product or service you have asked for. And / or b) Help us to identify you when you contact us | Necessity to perform our contract with you. Failure to provide such data where we request it may mean we are unable to supply you with the requested product or services. | Seven years from the date on which we supply good or services to you. If you do not purchase from us, 12 months from your last interaction with us |
| To carry out credit checks where you are purchasing products on credit terms. Please note that this only applies to trade account to which we use Credit Safe | Busseys legitimate interest in preventing default of payment | Seven years from the date on which we supply goods or services to you |
| To help us recover debts due to us from you | Busseys legitimate interest in recovery of monies due to us | Seven years from the date on which we supply goods or services to you |
| To bring or defend legal claims | Busseys legitimate interest of bringing or defending legal claims | Where you purchased a product regulated by the FCA, 10 years from the date you bought that product. If not seven years from the date you last dealt with us |
| To contact you about products and services offered by us, using one or more of: Post, Telephone, E-Mail or SMS. This is based on the permissions you have given us. | Your consent | Two years from the date on which you last gave consent to marketing, although we we may retain limted records to the extent required to maintain suppression lists |
Your Purchase History. History about where you have engaged with our emails and or websites | ||
| Purpose | Lawful basis for the processing | How long we keep it |
|---|---|---|
| To help us improve our content, products and services which may include profiling | Busseys legitimate interest as to help us improve our content, products and services | Retained in an anonymised form |
| To identify other products and or services you might be interested in for the purpse of direct marketing which may include profiling | Your consent | |
Your IP address, the website which you visit us, the website pages you actually browsed, the date and length of your visit | ||
| Purpose | Lawful basis for the processing | How long we keep it |
|---|---|---|
| To assist Busseys in secruing and managing the performance of our websites | Our legitimate interest of securing and managing the performace of our websites | Retained in an anonymised form |
Your name, contact details, personal documents to enable us to prove your identity, which may include your driving licence and or passport | ||
| Purpose | Lawful basis for the processing | How long we keep it |
|---|---|---|
| To help us decect and prevent fraud | Busseys legitimate interest in the prevention of loss to the business and others | Seven years from the date on which we supply goods or services to you |
All relevant documents deminstrating the provenance of any values of cash you pay us in excess of £1000. This is likely to include your full name, address, contact details, bank details, and documents in repect of your financial status. | ||
| Purpose | Lawful basis for the processing | How long we keep it |
|---|---|---|
| to help us detect and prevent money laundering | To ensure that Busseys comly with our legal obligation. Failure to supply this information where we request it may result in us being unable to sell you the reqested product or service | Seven years from the date on which we supply goods or services to you |
9. who do we share your personal data with
We sometimes share your personal data with trusted third parties
Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:
- We provide only the information they need to perform their specific services.
- They may only use your data for the exact purposes we specify in our contract with them.
- We work closely with them to ensure that your privacy is respected and protected at all times.
- If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
Examples of the kind of third parties we work with are:
- IT companies who support our website and other business systems.
- Operational companies such DVLA, Ford Motor Company, Peugeot Motor Company
- Marketing companies who help us manage our communications with you.
- Data insight companies to ensure your details are up to date and accurate.
To help personalise your journey through our websites we currently use the following companies, who will process your personal data as part of their contracts with us:
- Netmatters
We will share your information with the vehicle manufacture and they will process it in order process vehicle sales, replacement parts and accessory sales, manufacture and deliver your vehicle, for servicing, to manage warranty claims. For analysis, reporting and to record your vehicle history. For more information about how the manufacture will use your information.
Please click here for Ford Motor Company Fair Collection Notice
10. where your personal data may be processed
The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway. We may transfer personal data that we collect from you to third-party data processors in countries that are outside the EEA.
If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA. For example, our contracts with third parties stipulate the standards they must follow at all times. If you wish for more information about these contracts please contact our Data Protection Officer.
11. what are your rights over your personal data?
You have the right to request:
- Access to the personal data we hold about you, free of charge in most cases.
- The correction of your personal data when incorrect, out of date or incomplete.
- For example, when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end.
- That we stop using your personal data for direct marketing (either through specific channels, or all channels).
- That we stop any consent-based processing of your personal data after you withdraw that consent.
You have the right to request a copy of any information about you that the Busseys holds at any time, and also to have that information corrected if it is inaccurate. To ask for your information, please contact Data Protection Officer, Busseys Ltd 95 Whiffler Road, Norwich, NR3 2EU or email [email protected].
If we choose not to action your request we will explain to you the reasons for our refusal.
Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where we rely on our legitimate interest
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
Direct marketing
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
Checking your identity
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
12. how can you stop the use of your personal data for direct marketing?
There are several ways you can stop direct marketing communications from us:
- Click the ‘unsubscribe’ link in any email communication that we send you.
- Write to Busseys Ltd, 95 Whiffler Road, Norwich, Norfolk, NR3 2EU
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated
Contacting the regulator.
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
You can contact them by calling 0303 123 1113.
Or go online to www.ico.org.uk/concerns (opens in a new window; please note we can’t be responsible for the content of external websites)
13. any questions?
We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.
If you have any questions that haven’t been covered, please contact our Data Protection Officer who will be pleased to help you:
- Email us at [email protected]
- Or write to us at Data Protection Officer, Busseys Ltd, 95 Whiffler Road, Norwich, Norfolk NR3 2EU
This notice was last updated on 03/05/2018