Privacy Policy from 5th January 2021

Hawco & Sons Limited trading as Hawco Group, Hawco Volkswagen, Hawco ŠKODA, Hawco Van Centre, Hawco Millburn, Hawco Paint & Body, Highland Audi and Highland Campervan Hire 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, the AA who provide roadside assistance on our behalf.

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.


What information do we collect?

We collect information about you and your vehicle when you engage with our website, or staff in our dealerships. 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 the manufacturers we represent. 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, 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. Cookies (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;
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 dealerships;
17. “Live chat” records when this digital service is enabled;
18. CCTV recorded images from our dealerships; and
19. Any information within correspondence you send to us.
20. Your social media names and identification numbers, any information you post on our social media pages, posts in which you include a hashtag or mention relating to us and information regarding your activities on our social media pages generally (for example, the time and date of your posts and your 'likes').
21. Where your vehicle purchase or vehicle repair is financed by one of our approved lenders such as Volkswagen Financial Services or Northridge Finance we may collect basic agreement information (agreement end date, parity date, service plan details, extended warranty information and finance agreement length).


How do we use this information?

Hawco Group 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 who might.

There are various ways in which we may use or process your personal information:

Consent:

Where you have provided your consent, we may use and process your information to:


1. 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);

2. To share your personal information with our manufacturers and recommended third party partners, so that they can contact you with marketing information about their products and services

You can withdraw your consent at any time by contacting us at dataprotection@hawcogroup.co.uk or, in relation to any marketing messages you receive, by using the unsubscribe option included in those messages.


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.

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.

Processing necessary for us to support customers with sales and other enquiries


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

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

Processing necessary for us to respond to understanding customers’ and drivers’ needs

3. To analyse, evaluate and improve our products and services so that your visit and use of our dealerships and website are more useful and enjoyable (we will generally use data amalgamated from many people so that it doesn’t identify you personally);

4. To undertake market analysis and 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. We will only send marketing communications to you if you have provided your consent for us to do so or which we have obtained in the ways mentioned in the paragraph below;

5. For product development purposes (for example to improve vehicle quality, performance and safety);

6. In some cases we may use automated methods to analyse, combine and evaluate information that you have provided to us (We collect and analyse this information in this way so that we can deliver the most appropriate customer experience to you by tailoring and making relevant all our service and communications (for example, when your mileage suggests your vehicle is due for a service);

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

7. To send you marketing information from time to time after you have purchased a product or service from us or made a purchasing enquiry, closed your browser with items in your shopping basket or requested a test drive or other information of interest. We will only contact you with 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;

8. 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 our manufacturers or an online or public business directory. In relation to any such information we send by email or SMS, we will include an option allowing you to object to receiving future messages by unsubscribing;

9. 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);

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

11. To contact you if your local Hawco Group dealership, were to move premises or close.

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

12. To verify the accuracy of information that we hold about you and create a better understanding of you as a customer;

13. 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;

14. 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 on our suppression lists in order to be able to comply with your request);

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

Legal Obligation

We may process your personal information to comply with our legal requirements (for example to register your car with the DVLA).

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, but we do work closely with our manufacturers and with third party suppliers who fulfill business activities for us (like roadside assistance, 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 manufacturers in situations where we need to pass your information to them in order to manage any request or complaint you have made to us.

There may be some instances where your information is processed or stored outside of the EU, due to the location of some data system suppliers. In those instances, we will ensure that appropriate safeguards are in place for that transfer and storage as required by the applicable law.

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.




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 or an authorised dealer), 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, quotation or any other information on any of our products or services, we hold your personal information for 18 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 hold your personal information for this period to give us an opportunity to form a relationship with you.

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;
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);

-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


How can you 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 (including any identification documents requested).

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.

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

By post: The Data Protection Officer, Hawco Group, 48 Harbour Road, Inverness, IV1 1UF
By email: dataprotection@hawcogroup.co.uk
By phone: 01463 236111

If you are unhappy, you have the right to lodge a complaint with a data protection regulator in Europe, in particular in a country you work or live or where your legal rights have been infringed. 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: casework@ico.org.uk