About this policy

This policy describes how we use your personal data when you use our website www.gates.co.uk, our Used car mobile app, buy our goods or when we provide services to you. We have provided this policy to ensure that you understand what personal data we may collect and hold about you, what we may use it for and how we keep it safe. You have legal rights to access the personal data that we hold about you and to control how we use it which are also explained.

Who we are and how you can contact us

We are Frank G Gates Ltd, Company Number 00245843. Our registered head office address is at Gates Corner, Edinburgh Way, Harlow, Essex.

You can contact us in writing at Gates Corner, Edinburgh Way, Harlow, Essex or by emailing data@gates.co.uk. If you would like to speak to us, please call us on 01438 366013.

Please refer to the sections on Our data protection team, Your rights to know what personal data we hold and to control how we use it and How to make a complaint for further contact information.

Our data protection team

We have a dedicated data protection team who oversee our handling of personal data.

You can contact our data protection team in writing at Gates Corner, Edinburgh Way, Harlow, Essex CM20 2EG or by email at data@gates.co.uk or by calling 01438 366013 (see Who are we and how you can contact us) and marking your correspondence for the attention of The Data Protection Team.

What personal data we collect about you

We collect:

• Personal data that you provide to us. There are lots of ways in which you may share your personal data with us, for example, you may register on our website, post on social media sites that we run, use our used car app or contact us in connection with goods or services that you would like to buy, or have already bought from us. The personal data that you provide to us may include your name, address, e-mail address and phone number, financial and credit card information.

• Personal data that we receive from third parties. If we work with other businesses or use sub-contractors, these parties may collect personal data about you which they will share with us. For example, we may have your name and contact details passed to us by Ford Motor Company so that we can provide you with our goods or services or receive feedback. Or we may receive details from a finance company you are using to finance the purchase of a vehicle from us.

• Personal data collected when you use our website. Our website is powered by G-Forces Web Management Limited, our third party web services provider. GForces is committed to ensuring that data is processed in accordance with applicable data privacy laws, and is kept secure. GForces is certified to the standard of ISO27001 (an international standard for information security). GForces uses Amazon Web Services, Inc. as its cloud platform provider. All data processed by GForces is stored on Amazon’s web servers in the EEA.

• When someone visits our website, GForces collects standard internet log information (your IP address, browser, and type of device) and details of visitor behaviour patterns (where you joined our site from, the path you take to our site and where you leave). These are stored against unique ids (which are a string of numbers). GForces collects this information for the legitimate business purpose of monitoring the number of visitors to the various parts of the site, the general geographic location of visitors and engagement levels, which in turn enables it to make improvements to its websites and services and provide business intelligence. This information is only processed in a way which does not identify anyone. It is kept indefinitely.

• When you submit information using an online form, GForces processes the data collected and stores it for 31 days for the legitimate business purpose of enabling us to assess the information and deal with your request (it is then kept for a further 14 days in GForces’ routine back-ups for business continuity purposes). We collect the following information: Name, e-mail address, contact telephone number, your preferred Gates dealership and details of your enquiry.

• For our Live Chat facility, we use a third party provider, Call It Automotive Limited to support our service. Personal information that you volunteer to us via the BoldChat service may be shared with Call It Automotive for the legitimate business purpose of assisting with the handling of customer enquiries and follow ups. Personal information will be stored by Call It Automotive for a maximum of 2 years to enable us to access the information and deal with your enquiry. Call It Automotive stores the information in the EEA.

What we use your personal data for


We use your personal data in the following ways:

Personal data that you provide to us is used to:

• provide you with the information, products and services that you request from us

• provide you marketing communications in accordance with your marketing preferences (see How we use your personal data for marketing)

• manage and administer our business

• review and improve our goods and services

• Personal data that we receive from third parties is combined with the personal data that you provide to us and used for the purposes described above.

Personal data collected during your use of our website is used to:

• provide you with the information, products and services that you request from us if you have submitted an enquiry. Contact details submitted on the enquiry form will be added to our CRM database for follow-up purposes (see How long we keep your personal data)

• administer our website for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes

• improve our website to ensure that content is presented in the most effective manner for you and for your computer or mobile device

• used to allow you to participate in interactive features of our service, when you choose to do so

• keep our site safe and secure

• measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you

• make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and allows us to improve our website. For detailed information on the cookies we use and the purposes for which we use them, see our Cookie policy.

When we need your consent to use your personal data

Whilst we always want you to be aware of how we are using your personal data, this does not necessarily mean that we are required to ask for your consent before we can use it. In the day to day running of our business we may use your personal data without asking for your consent because:

• we are entering into and carrying out our obligations under a contract with you

• we need to use your personal data for our own legitimate purposes (such as the administration and management of our business and the improvement of our services) and our doing so will not interfere with your privacy rights

In exceptional circumstances, we may wish to use your personal data for a different purpose which does require your consent. In these circumstances, we will contact you to explain how we wish to use your data and to ask for your consent. You are not required to give consent just because we ask for it. If you do give consent, you can change your mind and withdraw it at a later date.

Please refer to the section on How we use your personal data for marketing to read about marketing consents.

Personal data you are legally obliged to provide

You are not under a legal obligation to provide us with any of your personal data but please note that if you elect not to provide us with your personal data, we may be unable to provide our goods or services to you.

Your rights to know what personal data we hold, and to control how we use it

You have a legal right to know what personal data we hold about you – this is called the right of subject access. You can exercise this right by sending us a written request at any time. Please mark your letter “Subject Access Request” and send it to The Data Protection Team at Frank G Gates Ltd, Gates of Stevenage, Arlington Business Park, Gunnelswood Road, Stevenage, Hertfordshire. SG1 2BE or by email to data@gates.co.uk or by post or email using the details in the Who we are and how you can contact us (see the section on Our data protection Team for contact details).

You also have rights to:

• prevent your personal data being used for marketing purposes (see How we use your personal data for marketing for further details)

• have inaccurate personal data corrected, blocked or erased

• object to decisions being made about you by automated means or to your personal data being used for profiling purposes

• object to our using your personal data in ways that are likely to cause you damage or distress

• restrict our use of your personal data

• require that we delete your personal data

• require that we provide you, or anyone that you nominate, with a copy of any personal data you have given us in a structured electronic form such as a CSV file

You can find full details of your personal data rights on the Information Commissioner’s Office website at ww.ico.org.uk.

Automated decision making and profiling

We do not make use of automated decision making however, if you are requiring us to propose your details onto a finance company you need to be aware that in most cases they will use automated decision-making software.

When we will share your personal data with others

We share your data with the following people in the day to day running our business:

• any business partners, suppliers and sub-contractors we work with to provide you with goods or services that you have requested from us

• Other companies that are part of Ford Motor Company

• analytics and search engine providers that assist us in the improvement and optimisation of our site and app

• · Finance houses for the purpose of assessing your credit score where this is a condition of us entering into a contract with you

We may also share your personal information with third parties on a one-off basis, for example, if:

• we sell or buy any business or assets (including our own), in which case we will disclose your personal data to the prospective seller or buyer of such business or assets

• · we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our website terms of use, our app terms of use or our terms and conditions or other agreements; or to protect the rights, property, or safety of our customers, ourselves or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction

How we keep your personal data safe

We take every care to ensure that your personal data is kept secure. The security measures we take include:

• only storing your personal data on our secure servers

• encrypting any payment transactions made through our website and used car app using SSL technology.

• ensuring that our staff receive data security awareness training

• keeping paper records to a minimum and ensuring that those we do have are stored in locked filing cabinets on our office premises

• maintaining up-to-date firewalls and anti-virus software to minimise the risk of unauthorised access to our systems

• enforcing a strict policy on the use of mobile devices and out of office working

Unfortunately, sending information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of personal data sent to our website therefore, you send us personal data at your own risk. Once we have received your personal data, we will use strict procedures and security features (some of which are described above) to try to prevent unauthorised access.

How we use your personal data for marketing

• We will add your details to our marketing database if:

• you make an enquiry about our goods or services

• you buy our goods or services

• you have told a third party that you would like them to pass us your contact details so that we can send you updates about our goods and services

• you have registered an interest on our website or our app regarding the goods or services we provide, and have indicated during the sign-up process that you are happy to receive marketing communications

We may send you marketing communications by email, telephone, text message, and post.

You can ask us to only send you marketing communications by particular methods (for example, you may be happy to receive emails from us but not telephone calls), about specific subjects (for example Service reminders) or you may ask us not to send you any marketing communications at all.

We may ask you to indicate your marketing preferences when you first register an account on our website, used car app, visit one of our dealerships or telephone us. You can check and update your current marketing preferences at any time by calling or emailing us using the details set out in the Who we are and how you can contact us section above.

We will only share your personal data with third parties for marketing purposes if you provide us with your consent to do so by ticking a box on a form we use to collect your personal data.

How long we keep your personal data

We only keep your personal data for as long as we actually need it. In practice, this means that we will keep:

• Financial records of transactions for 7 years

• Your name and contact details for marketing purposes for 7 years from the last point we have supplied you with goods or services

• Your name and contact details for marketing purposes for 3 years in the event of you making an enquiry

• A record of the goods and services (including a copy of your full customer file) we provide to you for 7 years

• Complaint records for 7 years

• Your name and contact details will be kept on file for 6 months if you apply for a job vacancy

Please note that we may anonymise your personal data or use it for statistical purposes. We keep anonymised and statistical data indefinitely, but we take care to ensure that such data can no longer identify or be connected to any individual.

When we will send your personal data to other countries

Your personal data may be transferred to, and stored at, a destination outside the European Economic Area ("EEA") by us or by our sub-contractors. We send data to Ford Motor Company Europe who in turn may send on to Ford Motor Company in the United States. Where we, or our sub-contractors, use IT systems or software that is provided by non-UK companies, your personal data may be stored on the servers of these non-UK companies outside the EEA. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

How you can make a complaint

If you are unhappy with the way in which we have used your personal data, please contact our Data Protection Team to discuss this using the contact details set out in the section above. See Who we are and how you can contact us

You are also entitled to make a complaint to the Information Commissioner’s Office which you can do by visiting www.ico.org.uk. Whilst you are not required to do so, we encourage you to contact us directly to discuss any concerns that you may have and to allow us an opportunity to address these before you contact the Information Commissioner’s Office.

How we keep this policy up to date

We will review and update this policy from time to time. This may be to reflect a change in the goods or services we offer, a change to our internal procedures or to reflect a change in the law.

You can request a copy of this privacy policy by contacting our Data Protection Team.