Gowrings Mobility Privacy Policy

 

Privacy and cookies policy

Last Updated: 20/07/18

At Gowrings Mobility, we are working hard to serve customers a little better every day. Looking after the personal data you share with us is a hugely important part of this. We want you to be confident that your data is safe and secure with us, and understand how we use it to offer you a better and more personalised customer experience.

What this Policy covers

The data controller is Gowrings Mobility Group Limited (referred to in this policy as “we” or “us”).

We are committed to doing the right thing when it comes to how we collect, use and protect your personal data. That is why we have developed this privacy and cookies policy (“Policy”), which:

Sets out the types of personal data that we collect

Explains how and why we collect and use your personal data

Explains when and why we will share personal data within the Gowrings Mobility Group and with other organisations; and

Explains the rights and choices you have when it comes to your personal data

We offer a wide range of products and services, so we want you to be clear about what this Policy covers. This Policy applies to you if you use our services (referred to in this Policy as “our Services”). Using our Services means:

Communicating with us over the phone, or online or otherwise using any of the websites (“our Websites”) where this Policy is posted; or

This Policy also applies if you contact us or we contact you about our Services

Parts of this Policy also apply to our facilities CCTV systems where they might capture footage of you.

Some other parts of our business and Parent company may need to collect and use personal data to provide you with their products and services and other purposes. They have their own privacy policies that explain how they use your personal data.

Our Websites may contain links to other websites operated by other organisations that have their own privacy policies. Please make sure you read the terms, conditions, and privacy policy carefully before providing any personal data on a website, as we do not accept any responsibility or liability for websites of other organisations.

Personal data we collect

This section tells you what personal data we may collect from you when you use our Services and what other personal data we may receive from other sources.

When you register for any of our Services, you may provide us with any of the following:

Your personal details, including your postal and billing addresses, email addresses, phone numbers and date of birth and title

Information relating to your membership to any organisations, charities or groups.

When you use our services or purchase from us online, in person or by phone or simply browse our Websites, we may collect:

Information about your online purchases (for example, what you have bought, when and where you bought it and how you paid for it)

Information about your online browsing behaviour on our Websites and information about when you click on one of our adverts (including those shown on other organisations’ websites)

Information about any devices you have used to access our Services (including the make, model and operating system, IP address, browser type and mobile device identifiers)

When you contact us or if we contact you or you take part in promotions, competitions, surveys or reviews about our Services, we may collect:

Personal data you provide about yourself anytime you contact us about our Services (for example, your name, username and contact details), including by phone, email or post or when you speak with us through social media

Details of the emails and other digital communications we send to you that you open, including any links in them that you click on

Your feedback and contributions to customer surveys or reviews

When you visit our facilities:

Footage of you may be recorded on our CCTV systems

Other sources of personal data

We may also use personal data from other sources, such as specialist companies that supply information, online media channels, our Retail Partners and public registers. For example, this other personal data helps us to:

Review and improve the accuracy of the data we hold; and

Improve and measure the effectiveness of our marketing communications, including online advertising.

How and why we use personal data

This section explains in detail how and why we use personal data. We use personal data to:

Make our Services available to you

This means that processing your personal data allows us to:

Manage the accounts you hold with us

Process your orders and refunds

Why do we process your personal data in this way? We need to process your personal data so that we can manage your customer information, provide you with the goods and services you want to buy and help you with any orders and refunds you may ask for.

Manage and improve our day-to-day operations

Manage and improve our Websites

Why do we process your personal data in this way? We use cookies and similar technologies on our Websites to improve your customer experience. Some cookies are necessary so you should not disable these if you want to be able to use all the features of our Websites. You can disable other cookies but this may affect your customer experience. For more information about cookies and how you can disable them, see the cookies and similar technologies section.

Help to develop and improve our product range, services, stores, information technology systems, know-how and the way we communicate with you

Why do we process your personal data in this way? We rely on the use of personal data to carry out market research and internal research and development, and to improve our information technology systems (including security) and our product range, services and stores. This allows us to serve you better as a customer.

Detect and prevent fraud or other crime

Why do we process your personal data in this way? It is important for us to monitor how our services are being used to detect and prevent fraud, other crimes and the misuse of services. This helps us to make sure that you can safely use our services.

Personalise your Gowrings Mobility experience

Use your online browsing behaviour as well as your showroom and online purchases to help us better understand you as a customer and provide you with personalised offers and services.

Why do we process your personal data in this way? Looking at your browsing behaviour and purchases allows us to personalise our offers and services for you. This helps us meet your needs as a customer.

Provide you with relevant marketing communications (including by email, post or online advertising), relating to our products and services, and those of our suppliers, Retail Partners and the Newship Group. As part of this, online advertising may be displayed on websites across the Gowrings Mobility Group and on other organisations’ websites and online media channels (including for example through Motability, https://www.motability.co.uk/). We may also measure the effectiveness of our marketing communications and those of our suppliers and Retail Partners.

Why do we process your personal data in this way? We want to ensure that we provide you with marketing communications, including online advertising, that are relevant to your interests. To achieve this we also measure your responses to marketing communications relating to products and services we offer, which also means we can offer you products and services that better meet your needs as a customer. You can change your marketing choices, both when you interact with us, and at any time after that. You also have choices when it comes to online advertising.

Contact and interact with you

Contact you about our Services, for example by phone, email or post or by responding to social media posts that you have directed at us.

Why do we process your personal data in this way? We want to serve you better as a customer so we use personal data to provide clarification or assistance in response to your communications

Manage promotions and competitions you take part in, including those we run with our suppliers and Retail Partners.

Why do we process your personal data in this way? We need to process your personal data so that we can manage the promotions and competitions you choose to enter.

Invite you to take part in and manage customer surveys, reviews and other market research activities carried out by Gowrings Mobility Group and by other organisations on our behalf.

Why do we process your personal data in this way? We carry out market research to improve our Services. However, if we contact you about this, you do not have to take part in the activities. If you tell us that you do not want us to contact you for market research, we will respect this choice. This will not affect your ability to use our Services.

Claims

In order to resolve legal claims or disputes involving you or us.

Why do we process your personal data in this way? For example if you have any accident or there is an incident at our showroom or facilities. This could include medical reports.

CCTV

To monitor the safety of our facilities in order to prevent and detect crime and anti-social behaviour.

Why do we process your personal data in this way? In order to protect our business, the local community, customers and colleagues.

Legal Basis

In relation to the headings mentioned in the section above (“how and why we use your personal data”), our legal basis for processing your personal data is:

Make our Services available to you

Legal Basis:

  • Contractual Necessity – at the time we collect it:
    • Purchase & transaction data;
    • Contact details;
    • Profile details;
    • Delivery/collection details.

We will not be able to provide you with your products or services if you do not provide us with this data.

  • Legitimate Interests – following fulfilment of your order for the other personal data in that section.

Manage and improve our day-to-day operations

Legal Basis:

  • Legitimate Interests.

Personalise your Gowrings experience

Legal Basis:

  • Legitimate Interests.

Contact and interact with you

Legal Basis:

  • Legitimate Interests.

Claims

Legal Basis:

  • Bringing or Defending Legal Claims.

CCTV

Legal Basis:

  • Legitimate Interests.

Our Legitimate Interests in using your personal data

Where we have mentioned above our use of your personal data is based on our “legitimate interests”, these are:

  • to service our customers’ needs, including delivering our products and services;
  • to promote and market our products and services;
  • to manage complaints and resolve any disputes;
  • to understand our customers including their patterns, behaviours as well as their likes and dislikes;
  • to protect and support our business, colleagues, customers;
  • to prevent and detect anti-social behaviour, fraud and other crime;
  • to test and develop new products and services as well as improve existing ones.

Sharing personal data with Retail Partners and Service Providers

This section explains how and why we share personal data with Retail Partners and Service Providers.

When we share personal data with these companies we require them to keep it safe, and they must not use your personal data for their own marketing purposes.

Service Providers

We work with carefully selected Service Providers that carry out certain functions on our behalf. These include, for example, companies that help us with technology services, storing, combining and analysing data, processing payments, provide us with legal or other professional services as well as delivering orders. We only share personal data that enable our Service Providers to provide their services.

Some of the Service Providers we work with operate online media channels, and they place relevant online advertising for our products and services, as well as those of our suppliers and our Retail Partners, on those online media channels on our behalf. For example, you may see an advert for our products and services as you use a particular social media site or watch television through your pay TV account.

Examples of our Service Providers include Facebook, Adobe, Twitter and LinkedIn

Sharing personal data with other organisations

This section explains how and why we share personal data with other organisations.

We may share personal data with other organisations in the following circumstances:

  • if the law or a public authority says we must share the personal data or for the administration of justice;
  • if we need to share personal data in order to establish, exercise or defend our legal rights (this includes providing personal data to others for the purposes of preventing fraud);
  • where we restructure, sell or transfer our business (or a part of it). For example in connection with a takeover or merger.

How we protect personal data

We know how important it is to protect and manage your personal data. This section sets out some of the measures we have in place.

  • We apply physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personal data;
  • We protect the security of your information while it is being transmitted by encrypting it;
  • We use computer safeguards such as firewalls and data encryption to keep this data safe;
  • We only authorise access to employees and trusted partners who need it to carry out their responsibilities;
  • We regularly monitor our systems for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security;
  • We will ask for proof of identity before we share your personal data with you; and
  • We will reveal only the last four digits of your payment card number when confirming an order.

The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by companies operating outside the EEA who work for us or for one of our service providers. If we do this we ensure that your privacy rights are respected in line with this Policy.

How long we use personal data for

We will not keep your personal data longer than we need to, how long this is depends on several factors, including:

  • Why we collected it in the first place;
  • How old it is;
  • Whether there is a legal/regulatory reason for us to keep it;
  • Whether we need it to protect you or us.

Marketing and market research

This section explains the choices you have when it comes to receiving marketing communications and taking part in market research.

We will send you relevant offers and news about our products and services in a number of ways including by email, but only if you have previously agreed to receive these marketing communications. When you register with us we will ask if you would like to receive marketing communications, and you can change your marketing choices at anytime by contacting us. We also like to hear your views to help us to improve our Services, so we may contact you for market research purposes. You always have the choice about whether to take part in our market research.

Cookies and similar technologies

We and our partners use cookies and similar technologies, such as tags and pixels (“Cookies”), to personalise and improve your customer experience as you use our Websites and to provide you with relevant online advertising. This section provides more information about Cookies, including how we use them and how you can exercise your choices about our use of Cookies.

How we use Cookies

Cookies are small text files containing a unique identifier, which are stored on your computer or mobile device so that your device can be recognised when you are using a particular website or mobile app. They can be used only for the duration of your visit or they can be used to measure how you interact with services and content over time. Cookies help to provide important features and functionality on our Websites, and to improve your customer experience.

When you consent to Cookies on our Services, these may be used to do the following:

Improve the way our Websites work

Cookies allow us to improve the way our Websites work so that we can personalise your experience and allow you to use many of their useful features.

For example, we use Cookies so we can remember your preferences and the contents of your shopping basket when you return to our Website.

Improve the performance of our Websites

Cookies can help us to understand how our Websites are being used, for example, by telling us if you get an error messages as you browse.

These Cookies collect data that is mostly aggregated and anonymous.

Deliver relevant online advertising, including via social media

We use Cookies to help us deliver online advertising that we believe is most relevant to you on our Websites and other organisations’ websites and using social media. Cookies used for this purpose are often placed on our Websites by specialist organisations.

Cookies used for this purpose are often placed on our Websites by organisations providing specialist services to us. These Cookies may collect information about your online behaviour, such as your IP address, the website you arrived from and information about your purchase history or the content of your shopping basket. This means that you may see our adverts on our Websites and on other organisations’ websites. You may also see adverts for other organisations on our Websites.

To help us to deliver online advertising that is relevant to you, we may also combine data we collect through Cookies in the browser of your desktop computer or other devices with other data that we have collected.

Measuring the effectiveness of our marketing communications, including online advertising

Cookies can tell us if you have seen a specific advert, and how long it has been since you have seen it. This information allows us to measure the effectiveness of our online advertising campaigns and control the number of times you are shown an advert.

We also use Cookies to measure the effectiveness of our marketing communications, for example by telling us if you have opened a marketing email that we have sent you

Third parties operating through our Websites

Our key partners are listed below with information about the services they provide to us. This list is not exhaustive but it does include those partners with whom we have an established relationship and whose cookie technologies are most frequently deployed through our Services.

Measurement & Personalisation

To analyse how our services are used, including to test different content versions. This data may also be used to enable us to personalise our services and the marketing of our services.

  • Adobe
  • Google

Product recommendations

Online marketing

To personalise Gowrings adverts shown to you via Gowrings Mobility Group and on other websites based on your interactions with Gowrings. For example, by using data about your transactions with Gowrings, what you have purchased and the pages and products you look at. We may also use your

  • Google

Social media

To market to you via social media platforms and to enable social sharing and engagement on our websites. These companies may use your data for their own purposes, including to profile and target you with other advertising.

  • Facebook
  • Twitter
  • LinkedIn

Your choices when it comes to Cookies

Web browser cookies

You can use your browser settings to accept or reject new Cookies and to delete existing Cookies. You can also set your browser to notify you each time new Cookies are placed on your computer or other device. You can find more detailed information about how you can manage Cookies through your browser’s help function.

If you choose to disable some or all Cookies, you may not be able to make full use of our Websites. For example, you may not be able to add items to your shopping basket, proceed to checkout, or use any of our products and services that require you to sign in.

You can also manage advertising related Cookies used on our Services by opting-out through the Service Providers listed in the table above or by visiting the YourOnlineChoices website. Where we display personalised adverts on other organisations’ websites, the AdChoices icon will usually be displayed. Clicking on this icon will provide you with specific guidance on how to control your online advertising preferences. More information is available on the YourAdChoices website.

Subject access rights

You have the right to see the personal data we hold about you. This is called a Subject Access Request.

If you would like a copy of the personal data we hold about you, please write to:

Data Protection Executive, Gowrings Mobility, Daytona Drive, Thatcham, Berkshire, RG194ZD

You can also email us at info@gowringsmobility.co.uk

Other data protection rights

In relation to your personal data, you also have the right to:

  1. have inaccurate information corrected:

Summary of the right:

if you believe we hold inaccurate or missing information, please let us know and we will correct it.

  1. object to our use of it:

Summary of the right:

    • General objection – We will then consider your objection to our use of your personal data. If on balance, your rights outweigh our interests in using your personal data, then we will at your request either restrict our use of it (see section 3 below) or delete it (see section 4 below).
    • Objection in relation to direct marketing – If you make such an objection, we will stop using your personal data for direct marketing purposes.
  1. restrict our use of it:

Summary of the right:

There are several situations when you can restrict our use of your personal data, this includes (but is not limited to):

    • you have successfully made a general objection (listed in section 2 above).
    • you are challenging the accuracy of the personal data we hold.
    • we have used your personal data unlawfully, but you do not want us to delete it.
  1. have us delete it:

Summary of the right:

There are several situations when you can have us delete your personal data, this includes (but is not limited to):

    • we no longer need to keep your personal data;
    • you have successfully made a general objection (listed in section 2 above);
    • you have withdrawn your consent to us using your personal data (and we do not have any other grounds to use it);
    • we have unlawfully processed your personal data.
  1. have us transfer or “port” a copy of it:

Summary of the right:

  1. complain to the data protection regulator:

We’d like the chance to resolve any complaints you have, however you also have the right to complain to the UK data protection regulator (the “ICO”) about how we have used your personal data. Their website is https://ico.org.uk/your-data-matters/raising-concerns/

Their website also contains useful information about your privacy rights https://ico.org.uk/for-organisations/resources-and-support/your-data-matters

More Information on your Data Protection Rights

The ICO website also contains more detail on the data protection rights mentioned above, or if you would like to speak to us about these rights in more detail, see the “how to contact us” section below.

 

If you have any questions about how we collect, store and use personal data please contact us.

Phone: 0345 608 8020
Email: info@gowringsmobility.co.uk
Mail: Gowrings Mobility Ltd

Daytona Drive

Thatcham

Berkshire

RG194ZD

 

Our Data Protection Officer can be contacted by email: info@gowringsmobility.co.uk