PROTECTING YOUR PRIVACY
Flear & Thomson
CONTENTS OF PRIVACY NOTICE
1. Introduction
This Privacy Notice explains in detail the types of 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’s a lot of information here, but we want you to be fully informed about your rights, and how Flear & Thomson Ltd uses your data; for example we will explain things such as how we combine data across Flear & Thomson Ltd to build a picture of you.
We hope the following sections will answer any questions you 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’re welcome to come back and check it whenever you wish.
2. Who are Flear & Thomson Ltd?
Flear & Thomson Ltd – which we’ll refer to as ‘Flear & Thomson’ in this document – is made up of a number of related businesses:
For simplicity throughout this notice, ‘we’ and ‘us’ means Flear & Thomson Ltd & Flear & Thomson (Stirling) Ltd & Flear & Thomson (Perth) Ltd
3. Explaining the legal bases we rely on
The law on data protection 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 request an online vehicle valuation.
When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.
Contractual obligations
In certain circumstances, we need your personal data to comply with our contractual obligations.
For example, if you order a vehicle from us for home delivery, we’ll collect your address details to deliver your purchase, and pass them to our transport company.
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 Flear & Thomson 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 running our business and which does not materially impact your rights, freedom or interests.
For example, we will use your purchase history (eg. Finance payment data) to send you or make available personalised offers.
We will also use your address details to send you direct marketing information by post, telling you about products and services that we think might interest you.
4. When do we collect your personal data?
5. What sort of personal data do we collect?
For example, we collect notes from our conversations with you, details of any complaints or comments you make, details of purchases you made, items viewed, vehicle models you show interest in, web pages you visit and how and when you contact us.
For example, which of our dealerships you prefer to visit.
For example, you might tell us your preferred vehicle transmission, which we’ll use to guide our suggested items.
We’ll only ask for and use your personal data collected for recommending items of interest and to tailor your buying experience with us. Of course, it’s always your choice whether you share such details with us.
6. How and why do we use your personal data?
We want to give you the best possible customer experience. One way to achieve that is by getting the best possible 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. In the case of Flear & Thomson loyalty scheme members, we’ll also offer you relevant rewards.
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.
For example, if you’ve asked us to let you know when a vehicle accessory comes back into stock, we can’t do that if you’ve withdrawn your general consent to hear from us.
Here’s how we’ll use your personal data and why:
For example, your details may need to be passed to a third party to supply or deliver the product or service that you ordered, and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds, guarantees and so on.
Of course, you are free to opt out of hearing from us by any of these channels at any time.
You are free to opt out of hearing from us by post at any time.
For example, we might offer you recommendations based on your purchase history and any other data you’ve shared with us.
For example, when a court order is submitted to share data with law enforcement agencies or a court of law
Of course, you are free to opt out of receiving these requests from us at any time by updating your preferences in your online account.
7. Combining your data for personalised direct marketing
We want to bring you offers and promotions that are most relevant to your interests at particular times. To help us form a better, overall understanding of you as a customer, we combine your personal data, for example your car purchase history at Flear & Thomson. For this purpose we also combine the data that we collect directly from you with data that we obtain from third parties to whom you have given your consent to pass that data onto us.
8. How we protect your personal 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 and apps using ‘https’ technology.
Sensitive data (such as payment card information) is secured by SSL encryption.
We regularly monitor our system for possible vulnerabilities and attacks.
9. 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.
Some examples of customer data retention periods:
Orders
When you place an order, we’ll keep the personal data you give us for seven years so we can comply with our legal and contractual obligations. In the case of certain products, we’ll keep the data for 10 years.
Warranties
If your order included a manufacturer or dealer warranty, the associated personal data will be kept until the end of the warranty period.
10. Who do we share your personal data with?
We sometimes share your personal data with trusted third parties.
For example, delivery couriers, manufacturer, finance suppliers, for fraud management, to handle complaints and so on.
Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:
Examples of the kind of third parties we work with are:
Sharing your data with third parties for their own purposes:
We will only do this in very specific circumstances, for example:
To help personalise your journey through Flear & Thomson websites we currently use the following companies, who will process your personal data as part of their contracts with us:
11. Where your personal data may be processed
UK
12. What are your rights over your personal data?
An overview of your different rights
You have the right to request:
You have the right to request a copy of any information about you that Flear & Thomson 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, Flear & Thomson Ltd, 128-140 Pittencrieff Street, Dunfermline, KY12 8AN, or email dataprotection@flearandthomson.co.uk. To ask for your information to be amended, please contact our Service or Sales team.
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.
13. 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:
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.
14.2 How our providers use your personal data
When you then apply for a product or service from one of our chosen providers, your data will be collected and used by them under the terms of their own separate privacy policies.
Here are a list of companies:
• Kia Finance
•Santander Consumer Finance
• ITC Compliance
• Barclays Partner Finance
• Blackhorse Finance
• GardX
• The Warranty Group
• Auto Protect Warranties
• Reynolds & Reynolds
• ALD
• First Response
• Gforces
• Car Care Plan
• Kia Motors UK
• Motability
• Vital Software
• Evolution Finance
• VMC
14.3 Joint use of your personal data
We will share data with our providers to bring you relevant offers, updates, products and services, and discounts that reward your loyalty to our brands.
15. 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)
If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence. Details can be found in Section 16.
16. If you live outside the UK
For all non-UK customers
By using our services or providing your personal data to us, you expressly consent to the processing of your personal data by us or on our behalf. Of course, you still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes.
Sometimes we’ll need to transfer your personal data between countries to enable us to supply the goods or services you’ve requested. In the ordinary course of business, we may transfer your personal data from your country of residence to ourselves and to third parties located in the UK.
By dealing with us, you are giving your consent to this overseas use, transfer and disclosure of your personal data outside your country of residence for our ordinary business purposes.
This may occur because our information technology storage facilities and servers are located outside your country of residence, and could include storage of your personal data on servers in the UK.
17. 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:
Cookies
Cookies are tiny text files stored on your computer when you visit certain web pages. We use cookies to keep track of what you are looking at and to remember you when you return to our site.
To purchase and shop at Flear & Thomson you need to have all cookies enabled, though you can still use the website for browsing and research purposes without them.
We also use banner advertising on other websites to present you with offers, services and products we think may be of interest to you, based on your browsing history.