Privacy Policy

  1. Overview
  2. What personal data do we collect
  3. Explaining the legal bases we rely on
  4. Consent
  5. Soft opt-in
  6. Contractual obligations
  7. Legal compliance
  8. Legitimate interest
  9. How we use your data
  10. How we protect your data
  11. How long will we keep your data
  12. Where your personal data may be processed
  13. What are your rights over your personal data
  14. How can you stop the use of your personal data for marketing
  15. Contacting the Regulator

OVERVIEW

Citygate Automotive Limited is a company registered in England and Wales (which is referred to as ‘we’ or ‘us’ in this policy)

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, Volkswagen Financial Services who provide finance to our customers.

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 any substantial changes.

This version of our Privacy Statement is live from 19th January 2023.

WHAT PERSONAL DATA DO WE COLLECT

We collect information about you and your vehicle when you engage with our website, applications, speak to our communication centre or come into any of our premises. We only collect information which is necessary, relevant and adequate for the purpose you are providing it for.

We also obtain information about you or your vehicle from some third parties, i.e insurance companies or breakdown companies in the event of a bodyshop repair or vehicle breakdown. Some of this information does not identify you personally, but provides us with information about how you use our services and engage with us (we use this information to improve our services and make them more useful to you). 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 or chassis number, 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 (for more information please see our Cookie Policy);
  13. The website address from which you accessed our website;
  14. Details of any transactions between you and us or our businesses;
  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 (some of which we may obtain from an online or public business directories);
  16. Voice recordings of calls you make to our communication centre;
  17. “Live chat” records;
  18. Social Media engagement or direct message records
  19. Details of any CV and Job application data for as long as we deem relevant for the purpose of our business;
  20. Any employee data is held securely and in line with regulatory requirements;
  21. Any information within correspondence you send to us and
  22. Where you act on behalf of a business, any information we collect as part of business telemarketing activity.

EXPLAINING THE LEGAL BASES WE RELY ON

The law on data protection sets out a number of different bases 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 tick a box to receive email newsletters.

When collecting your personal data, we will obtain your marketing preferences to ensure you only receive communications through consented channels.

SOFT OPT-IN

We will use ‘soft opt-in’ from time to time.  This will only be used for existing customers, on the basis of an individual who bought something from us recently, gave us their details, and did not opt out of marketing messages.  On this basis we would deem they are probably happy to receive marketing from us about similar products or services even if they haven’t specifically consented. However, we will always give a clear chance for our customers to opt out – both when they first collect their vehicle, and in every message you send.

The soft opt-in rule means we may be able to email or text our own customers, but it does not apply to prospective customers or new contacts. It also does not apply to non-commercial promotions (eg charity fundraising or political campaigning).

CONTRACTUAL OBLIGATIONS

In certain circumstances, we need your personal data to comply with our contractual obligations. For example, if you order a new or used car from us, or book a car in for a service or bodyshop repair.

We will also ensure you receive timely reminders for the maintenance and upgrade of your vehicle. We will also provide pricing support but only in line with the relevant message.

LEGAL COMPLIANCE

If the law requires us to, we may need to collect and process your data. For example, we can pass on details of people involved in fraud or other criminal activity affecting us to law enforcement.

It may also be necessary to contact and update you in the event of any national emergencies.

LEGITIMATE INTEREST

In specific situations, we collect and process your data to pursue our legitimate interests in a way which you might reasonably expect, as part of running our business, and which does not materially impact your rights, freedom or interests.

For example, we may use your purchase history with us to make you personalised offers.

We may use your personal data to send you offers by post, email, or contact you by telephone to advise you of offers we think may be of interest to you.

HOW WE USE YOUR DATA

Citygate Automotive Limited 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).

The reasons for processing your data are detailed below;

Vehicle Sales, Servicing, Rental or Body repairs: We collect data in the performance of a contract for the sale, servicing or repair or to provide a service to ensure the contract is fulfilled.

Financing Vehicles: We will process your data in order to obtain finance for you to purchase the vehicle.

Marketing: We will process your data with your consent or on occasion, if applicable, under the legitimate interest to advise you on of offers or services that we feel you should be informed about.

Employee Information: We collect and store your personal data as part of our legal obligation linked to your contract of employment.

Recruitment: We have a legal obligation to share your personal data with Experian who are a credit reference agency who provide us with financial background checks for specific roles prior to you commencing employment with us.

HOW WE PROTECT YOUR DATA

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 non-specific data sets where ever possible. 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 (like insurance companies in our bodyshops, finance companies, marketing, events and market research agencies) and we take reasonable steps to ensure their data processing policies and procedures are in place to ensure we protect your information.

Third party advertising partners may set cookies on your devices through our site to collect your information. We do not control their use of your data.  Further information about our advertising partners and their use of data can be found via our privacy preference centre under the More Info tab in our cookie policy. 

HOW LONG WILL WE KEEP YOUR DATA

We will not use your personal information for any longer than we deem reasonably necessary. If you are a customer or otherwise have a relationship with us, we will hold and use personal information about you for a longer period than if we have obtained your details in connection with a prospective relationship.

If we have a relationship with you (e.g. you are a customer or the registered driver of a financed/leased or other vehicle purchased from us or another authorised repairer), we hold your personal information indefinitely on our CRM systems however, physical data records are destroyed after 7 years from the relevant date of service received. This is because we may require your personal information to establish, bring or defend legal claims where necessary, but more importantly, to assist you with any future vehicle requirements such as, safety recalls.

Our relationship may end for a number of reasons including where the vehicle warranty or finance/lease expires, or we have been made aware that you no longer own or drive that vehicle.

On most occasions, we will only contact customers up to 7 years from the date our relationship ended. If for any reason we deemed it necessary to contact someone where the relationship ended over 7 years ago, we will do this on a case-by-case basis.

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 will hold your personal information on our enquiry management system from the date we collect that information, however this will be made dormant after 90 days unless during that period we form a relationship with you e.g. you purchase or lease a vehicle or use one of our service departments or bodyshops. Within this 90-day period we will ensure we keep you up to date with any relevant marketing offers and promotions.

The only exceptions to the periods mentioned above are where:

  • The law requires us to delete it sooner;
  • Where you have raised a legal claim, complaint or concern regarding a product or service offered by us, in which case we will retain the information about the complaint or query for a period of 6 years; 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 (see further How can I manage the information we hold about you)

Who do we share your data with?

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 (like insurance companies in our bodyshops, finance companies, marketing, events and market research etc.)

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: 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 will also share your information with our retailers in situations where we need to pass your information to them in order to manage any request or complaint you have made to us. For example, where you have requested a test drive, we will need to share your personal information within our businesses so that they can contact you to arrange for the test drive to take place.

There are circumstances where we share your information within our company in order to fulfil orders, transactions, handle complaints or provide you with a service or information that you have requested.

WHERE YOUR PERSONAL DATA MAY BE PROCESSED

Due to the nature of our business, there may be some instances where your information is processed or stored outside of the EU. In those instances, we will ensure that appropriate safeguards are in place for that transfer and storage as required by applicable law. 

WHAT ARE YOUR RIGHTS OVER YOUR PERSONAL DATA

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 (including any identification documents requested).

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

Post: Data Protection Team, Citygate Automotive Limited, 664 Victoria Road, South Ruislip, Middlesex, HA4 0LN

Email: [email protected]

 

HOW CAN YOU STOP THE USE OF YOUR PERSONAL DATA FOR MARKETING

There are several ways you can stop direct marketing communications from us:

  • Click the ‘unsubscribe’ link in any communication that we send you. We will then stop any further emails from that particular division.
  • Write to Data Protection Team, Citygate Automotive Limited, 664 Victoria Road, South Ruislip, Middlesex, HA4 0LN

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 are unhappy, you have the right to lodge a complaint with a data protection regulator in the United Kingdom. The contact details for the Information Commissioner’s Office, the data protection regulator in the UK, are below:

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

Call: 0303 123 1113

Email: [email protected]