Last edited 04/06/2019 16:00


Group Privacy Statement

The General Data Protection Regulation (or GDPR for short) is a positive step towards people having more
control over how their data is used. On May 25th 2018 this new legislation came into force and we have
changed a number of processes and policies to prepare our business. We are committed to protecting and
respecting any personal information you share with us.
This statement describes what types of information we collect from you, how it is used by us, how we share it
with others, how you can manage the information we hold and how you can contact us.
We will always give you the option not to receive marketing communications from us. We will never send you
unsolicited ‘junk’ email or communications, or share your data with anyone else who might. We do not sell
your information to third parties, but we do work closely with selected partners who help us to provide you
with the information, products and services that you request from us. For example, our manufacture parent
who provide documentation relating your vehicle.
The contents of this statement may change from time to time so you may wish to check this page occasionally
to ensure you are still happy to share your information with us. Where possible, we will also contact you
directly to notify you of these changes.


What information do we collect?

We collect information about you and your vehicle when you engage with our website, applications or
manufacture partners who ask us to contact you when you make a request. We only collect information
which is necessary, relevant and adequate for the purpose you are providing it for.
The information we collect includes some or all of the following:
1. Name (including title);
2. Address;
3. Phone number;
4. Date of birth;
5. Email address;
6. Vehicle information (including registration number, VIN, service reminders, mileage and warranty
repair information);
7. The date and time you used our services;
8. The pages you visited on our website and how long you visited us for;
9. Your IP address;
10. Your GPS location (where you have permitted access to this);
11. The internet browser and devices you are using;
12. Cookie, Pixels or Beacon information
13. The website address from which you accessed our website;
14. Details of any transactions between you and us;
15. Where you engage with us in a business context, we may collect your job title, company contact
details (including email addresses), fleet size and company details;
16. Voice recordings of calls you make to our customer service centre;
17. “Live chat” records; and
18. Any information within correspondence you send to us.
In line with our overall data protection policy we do not collect unauthorised data, we will not allow any
recording devices from vehicles to compromise the security of our workshop equipment or any other
individual vehicle information. All recording equipment inside a customer vehicle if not turned off, will be
switched off by an appropriate member of staff.


How do we use this information?

We will only process information that is necessary for the purpose for which it has been collected. You will
always have the option not to receive marketing communications from us (and you can withdraw your
consent or object at any time). We will never send you unsolicited ‘junk’ email or communications, or share
your personal information with anyone else that might.

There are various ways in which we may use or process your personal information. We list these below:

Consent

Where you have provided your consent, we may use and process your information to provide the latest
information on the offers you enquired on:

Car Van Truck

Prospect Vehicle Customers

Consent (After 6 months)

Consent (After 6 months)

Consent (After 6 months)

Prospect Parts Customers

Consent (After 6 months)

Consent (After 6 months)

Consent (After 6 months)

Prospect Service Customers

Consent (After 6 months)

Consent (After 6 months)

Consent (After 6 months)

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.

Car Van Truck

Prospect Vehicle Customers

Contractual Obligation

Contractual Obligation

Contractual Obligation

Prospect Parts Customers

Contractual Obligation

Contractual Obligation

Contractual Obligation

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 interests as a business to do so.

Car Van Truck

Existing Vehicle Customers

(Purchased up to 6 years ago) Legitimate Interest

(Purchased up to 6 years ago) Legitimate Interest

(Purchased up to 6 years ago) Legitimate Interest

Existing Parts Customers

(Purchased up to 2 years ago) Legitimate Interest

(Purchased up to 2 years ago) Legitimate Interest

(Purchased up to 2 years ago) Legitimate Interest

Existing Service Customers (No contract)

(Up to 2 years from last work) Legitimate Interest

(Up to 2 years from last work) Legitimate Interest

(Up to 2 years from last work) Legitimate Interest

MOT Legitimate interest Legitimate interest Legitimate interest

Where appropriate, we will contact service customers (those who are active within the last two years) with
sales messages regarding our latest offers. Through a legitimate interest assessment we have determined
this is in the best interest of our customers.


Legal Obligation
We may process your personal information to comply with our legal requirements (for example to register
your car with the DVLA).
We will share information upon request with third parties including civil and public authorities in regards to
motor related enforcement notices including parking and speeding fines.


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 do not sell your information to third parties. However, we may 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: our manufacturer partners, roadside assistance service providers, customer
contact centres, mobility and car hire providers, 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. We will aim to
anonymise your information or use aggregated none specific data sets where ever possible.


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. 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.

We do not retain personal information in an identifiable format for longer than is necessary.

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. We
hold your personal information for this period to establish, bring or defend legal claims. Our relationship may
end for a number of reasons including where the vehicle warranty or lease expires, or we have been made
aware that you no longer own or drive that vehicle.

Where we have obtained your personal information following a request for information, test drive, brochure,
quotation or any other information on any of our products or services, we hold your personal information for
1 year and 6 months from the date we collect that information, unless during that period we form a
relationship with you e.g. you purchase or lease a vehicle. We will continue to process your data in line with
your initial enquiry for 6 months to allow us an opportunity to form a relationship with you. After this your
data will remain dormant for 1 year before being removed, unless a relationship is formed within this time.

In addition, so that we are able to continue to comply with GDPR regulations, your data may be held in a
cloud based SFTP server, where it will be held for a maximum of 30 days before being removed.

The only exceptions to the periods mentioned above are where:
• The law requires us to hold your personal information for a longer period, or delete it sooner;
• Where you have raised a complaint or concern regarding a product or service offered by us, in which
case we will retain your information for a period of 6 years following the date of that complaint or
query; or
• you exercise your right to have the information erased (where it applies) and we do not need to hold
it in connection with any of the reasons permitted or required under the law


Employee, Worker, Supplier and Consultant Data

Where we have collected your personal data for the purpose of employment with the company, we will hold on to your data as necessary for the period of your employment with us. We will continue to hold on to yourdata after your employment ends, only as long as is necessary for any contractual or legal obligations.

When you enter a relationship with us as a supplier or consultant we will hold onto your data for the length of
our relationship. When our relationship ends we will only hold onto your data long enough to fulfil any
contractual or legal obligations.


Cookies

We use cookies to record the preferences of visitors, to enable us to optimize the design of our web site.
Cookies are small files which are stored on your hard drive. They ease navigation, and increase the userfriendliness of a web site. Cookies also help us to identify the most popular sections of our web site. This
enables us to provide content that is more accurately suited to your needs, and in so doing improve our
service. Cookies can be used to determine whether there has been any contact between us and your
computer in the past. Only the cookie on your computer is identified.

Most browsers automatically accept cookies. You can prevent cookies from being stored on your hard drive
by setting your browser to not accept cookies. The exact instructions for this can be found in the manual for
your browser. You can delete cookies already on your hard drive at any time. If you choose not to accept
cookies, you can still visit our website, however this may result in a reduced availability of the services
provided by our web site.

Analytics Cookies

These cookies allow us to count page visits and traffic sources so we can measure and improve the
performance of our site, using a service provided by Google Analytics.

Third Party Cookies

We may use a number of social media tools to enhance visitor interaction on our site. If you already use these
platforms their cookies may be set through our website. Data may then be collected by these companies that
enables them to serve up adverts on other sites that they think are relevant to your interests. If you do not
use such platforms, then our site will not place these cookies on your device.

Functional Cookies

These cookies are used to enable core site functionality. They do not contain any personal information and
are automatically deleted when you close your browser.


How can I manage the information we hold about you

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 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
received any request.

You have the right to:
1. Ask for a copy of the information that we hold about you;
2. Correct and update your information;
3. Withdraw your consent (where we rely on it). Please see further How do we use this information;
4. Object to our use of your information (where we rely on our legitimate interests to use your personal
information) 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. 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.

Please be mindful that if you make a request to alter, update or delete your personal details from our system,
we will endeavour to action your request as quickly as possible. However in some rare instances, please allow
up to 30 days for your request to take effect.

In the case of a subject access request or a request for information, please be aware that if your request is
unfounded or excessive, we may still charge a fee or refuse to act on the request.

Please also be aware that when we remove your data from our system, either after the periods of time
mentioned previously in this document or at your own request, your data is permanently removed from our
system and may affect any future subject access requests that you make.

We value your privacy, and as such we implement a clear desk policy, all workstation screens are locked and
any information is stored away in a secure environment.

You can exercise the above rights and/or manage your information by contacting us using the details below:

Post: Database Team, Motus Group (UK) Ltd, Oakingham House, Ground Floor, West Wing, London Rd,
Loudwater, High Wycombe, HP11 1JU

Email: database@pentagon-group.co.uk

If you have any specific data protection concerns or a complaint, you can address it to our Data Protection
Team at data@motusuk.com, or at the above postal address.

If you are unhappy, you have the right to lodge a complaint with Information Commissioner’s Office (ICO), the
data protection regulator in the UK. Our Data Protection Registration number with the ICO is Z6033829.

By Post
Information Commissioner's Office
Wycliffe House
Water Lane Wilmslow
Cheshire SK9 5AF

Call
0303 123 1113


V 030619