1.1 In this Privacy Notice, "Day’s Motor Group" refers specifically to CEM Day Ltd (Company No. 215538) and Three Cliffs Investments Company Ltd (Company No. 1982656).
1.2 This Privacy Notice explains in detail the personal data we may collect about you when you interact with Day’s Motor Group. We will explain how we use, store, maintain, protect the personal data we have received from you.
2. Privacy notice
2.1 Who are we?
Day’s Motor Group are a multi-dealership franchise dealer group and finance company, based in South Wales. Our registered head office is Swansea Road, Garngoch, Swansea, SA4 4LL.
The business operates Ford, Peugeot, Fiat and Iveco franchises as well as Nissan, Dodge, Alfa Romeo, Jeep, Citroen and Chrysler Aftersales.
Our Data Protection Officer can be contacted directly here:
Or our Data Protection Team:
2.2 Personal Data
The personal data we collect and process on you
When you interact with us, such as when you purchase a vehicle, parts or services, you may provide us with personal information about you, such as your name, address, gender, date of birth, telephone number(s), email address(s), social media user name(s) if you communicated with us via that medium, your comments & reviews via review website(s), occupation or job title, payment and financial information, including
bank details, information about your vehicle including service history and your Motability details.
You may also need to provide us with a copy of identification documents such as your passport, driving licence and/or a utility bill. These documents will include additional personal information about you such as (depending on the nature of the document) your nationality, place of birth, photograph and passport / driving licence number.
To ensure the safety of our staff, customers and suppliers and to protect our business assets, we use CCTV at each of our business locations. This would mean you may appear in CCTV footage if you attended one of our branches.
If you contact us via telephone, we use a telephone system which records the calls to improve our service to you through training and quality improvements. The system also provides clearness on previous conversations between you and our staff to assist with any products or services we provide.
What we use your Information for
The personal data we collect will be used for the following purposes:
* To contact you with important information regarding our obligations to you in respect to current or past orders or requests you have placed with us, such as:
Vehicle order information;
Finance application updates;
Test drives; and
Appointments with staff.
* To comply fully with applicable UK and EU law, such as Anti-Money Laundering regulations, HMRC regulations, DVLA procedures and other legal record keeping purposes.
* To provide you with the information you have consented to receive from us, such as signing up to our Newsletter or Careers pages.
* To satisfy our duty of care to you and protect your vital interests by informing you of vehicle recall information, safety information and to protect your identity from fraud.
* To provide you with the latest offers, discounts and information on customer events.
* To effectively liaise with all companies under the Days Property Holdings Group in order to facilitate the supply of information, products and services to you.
* To process finance applications, either through our own finance company or to third party finance providers.
Our legal basis for processing for the personal data:
For processing your personal data, we rely on the following legal bases:
* Contractual Obligation – This is where we use your personal data in order to satisfy our contract with you, such as arranging a vehicle collection or using a credit reference agency.
* Legal Obligation – This is where we must supply an appropriate body with your information, such as Police information requests.
* Vital Interest – This is where would need to provide personal information where necessary to protect someone’s life.
* Public task – This is where we would need to process your personal information to perform a task in the public’s interest or for official functions.
* Vital Interest – As stated previous, this is where we believe we would be acting in your best and upmost interests, for example, where there has been a safety notice issued on a vehicle which we have either supplied to you or have worked on for you, we would aim to get in touch with you to advise.
* Consent – This is where you give positive intention to agree to us contacting you, such as applying for a job on our website, to enable us to come back in contact with you. You can withdraw consent at any time via contacting either our Data Protection Officer or Data team.
* Legitimate Interest – please see the next paragraph below.
Any legitimate interests pursued by us, or third parties we use, are as follows:
* Day’s Motor Group use the legitimate basis for processing your data in relation to outbound communications. Day’s Motor Group believe that we have appropriate and sufficient safeguards as well as working closely aligned to your expectations as a customer. Day’s Motor Group believes the communications are beneficial for all parties involved.
* Examples of personal data processing under Legitimate Interest basis:
Refining the accuracy of the information we have collected on you to improve our services to you;
To protect your personal information against loss, damage, theft or unauthorised access;
To comply with a request from you regarding the exercise of your rights;
To inform you of an update to our terms and conditions and policies;
Carrying out checks to prevent fraud to protect us from dishonest activity;
Reminding you about vehicle services and MOTs which are due to ensure (where applicable) the continued validity of any warranty, that your vehicle remains safe and legal to drive and to maintain our customer relationship with you;
Advising you of your options during and at the end of a finance agreement;
Analysing, evaluating and improving our services so that your visit to our website, applications and customer service centre are more useful and enjoyable;
Operating a CCTV system on our premises to protect the safety and security of our staff and assets;
Storing phone call recordings and other communications and queries received from you for both quality improvement and staff training purposes.
* If you disagree, you can object to any of our communications by exercising your right to object to the processing above by contacting our Data Protection Officer.
Day's Motor Group works closely with a number of third parties in order to operate effectively, to satisfy our contractual obligations in our terms of agreement with certain suppliers such as vehicle and parts manufacturers, acting in the manufacturers legitimate interests, to keep you informed of developments related to both your car and/or vehicle manufacturers; and to inform you of/supply you with our products and services.
We would only provide the minimal information that a third party requires to undertake their specific services and for the exact purposes we have contracted with them for. We have ongoing communication with our third parties to ensure that your personal information is valued and any changes in the circumstances of the third party are informed to us. We inform our third parties to remove your personal information when we believe that our legal basis is no longer applicable.
Our third parties include our close relationships with vehicle and parts manufacturers, such as Ford, Peugeot, Nissan, Fiat and Iveco. Their Privacy Notices can be found below:
The vehicle and parts manufacturers may use your information to inform you of developments in relation to your vehicle such as recalls and offer you additional products and services. The manufacturers may also use your information for statistical analysis and market insight. The manufacturers may also pass on your personal data to their own third parties without first obtaining your consent to assist them with their objectives. If you require further information regarding our third parties and your data, please contact our Data Protection Officer or our Data team.
Day’s Motor Group may share your personal data with other third parties for the legitimate interests of both ourselves and you. These third parties may include:
Finance providers, credit reference agencies and brokers (This would only be the case if you applied for finance with/through us);
Ancillary complimentary product and service providers, such as insurance and warranty providers;
Marketing and research services companies to help us better communicate with our customers;
Professional service firms, such as Legal, Accountancy, Audit service providers;
IT platform providers who may have access to our/your data in order to provide us ongoing products and services, such as Microsoft;
Government or Regulatory bodies, such as DVLA and HMRC.
Data storage and destruction providers in order to securely hold and delete our/your data when appropriate.
2.4 Retention period
Day's Motor Group will process and store your personal data for only as long as our legal bases still exist. The exact length of time will depend on the nature and content of the personal information. The purchase of a vehicle can be a major and long term investment for you but one in which may change rapidly due to your circumstances in a short time. We at Day’s Motor Group would like to retain you as a valued customer and ensure you have information readily available to assist you in your next purchase whether it be for a new or used vehicle or aftersales products and services. We also respect your privacy and have designed our data processes with your privacy at the forefront.
To this end, we have made our options for you to object to any processing or storage of your personal information to be as transparent and easy to enact through visible weblinks on any communication from us and straight forward access to our Data Protection Officer and Data team via email, telephone or in writing.
There is certain personal information which we also need to retain to meet our legal and regulatory compliance obligations. Your information will only be stored for the appropriate lengths of time and the minimum amount of information needed to satisfy these requirements
2.5 Your rights as a data subject
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
* Right of access – you have the right to request a copy of the information that we hold about you.
* Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
* Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
* Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
* Right of portability – you have the right to have the data we hold about you transferred to another organisation.
* Right to object – you have the right to object to certain types of processing such as direct marketing.
* Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
* Right to judicial review: in the event that Day's Motor Group refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain to our Data Protection Officer.
All of the above requests will be forwarded on should there be a third party involved in the processing of your personal data.
In the event that you wish to make a complaint about how your personal data is being processed by Day's Motor Group (or third parties), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Day's Motor Group’s data protection representatives or Data Protection Officer.
The details for each of these contacts are:
Supervisory authority contact details Data Protection Officer (DPO) contact details
Contact Name: Information Commissioners Office The Data Protection Officer
Address Line 1: Churchill House, Day's Motor Group
Address Line 2: 17 Churchill Way Beaufort Road
Address Line 3: Cardiff, Swansea
Address Line 4: CF10 2HH SA6 8HR