Connected‑Vehicle Data Policy

Frank G Gates Ltd Last updated: 25.9.26

This annex explains how we handle personal data generated by connected vehicles and associated digital services provided by the manufacturers we represent, including Ford, OMODA, JAECOO, Peugeot, Leapmotor, BYD, and Geely.

It supplements our main Privacy Policy and should be read alongside it.

1. What connected‑vehicle data is collected

Connected vehicles and associated mobile applications may collect and transmit the following categories of data:

A. Vehicle telematics data

• Vehicle identification number (VIN)
• Mileage and usage data
• Diagnostic information
• Service alerts and fault codes
• Battery status (for EVs)
• Tyre pressure and mechanical system status

B. Location and movement data

• GPS location
• Journey history
• Speed and driving behaviour
• Geofencing information
• Charging location history (EVs)

C. Remote services data

• Remote lock/unlock events
• Remote start/stop events
• Remote climate control usage
• Over‑the‑air (OTA) update logs

D. In‑vehicle infotainment and app data

• App usage information
• Voice command logs
• Navigation searches
• Bluetooth device identifiers

E. Safety and incident data

• Airbag deployment
• Crash event data
• Emergency assistance triggers

2. How we receive connected‑vehicle data

We may receive connected‑vehicle data from:

• OEMs (Ford, OMODA, JAECOO, Peugeot, Leapmotor, BYD, Geely)
• OEM mobile applications (e.g., FordPass, MyPeugeot, BYD App)
• Telematics platforms
• Warranty systems
• Diagnostic tools used during servicing

We do not collect connected‑vehicle data directly from the vehicle unless you bring it to us for servicing or repair.

3. How we use connected‑vehicle data

We use connected‑vehicle data for:

A. Servicing and repairs

• Diagnosing faults
• Performing repairs
• Applying software updates
• Validating warranty claims

B. Safety and compliance

• Responding to safety recalls
• Supporting incident investigations
• Ensuring vehicle roadworthiness

C. Customer support

• Providing service reminders
• Advising on vehicle health
• Responding to enquiries

D. Business administration

• Warranty processing
• OEM reporting obligations
• Product improvement feedback

We do not use connected‑vehicle data for marketing unless you have given consent.

4. Lawful basis for processing connected‑vehicle data

5. Who we share connected‑vehicle data with

We may share connected‑vehicle data with:

• OEMs (Ford, OMODA, JAECOO, Peugeot, Leapmotor, BYD, Geely)
• Warranty providers
• Breakdown and roadside assistance partners
• Regulatory bodies (if legally required)

We do not sell connected‑vehicle data.

6. International transfers

Some OEMs store connected‑vehicle data outside the UK/EEA. Where this occurs, OEMs use appropriate safeguards such as:

• Standard Contractual Clauses (SCCs)
• UK International Data Transfer Agreements (IDTAs)
• UK–US Data Bridge (where applicable)

OEMs act as independent controllers for connected‑vehicle data.

7. Retention of connected‑vehicle data

We retain connected‑vehicle data only for as long as necessary for:

• servicing
• warranty
• safety
• legal obligations

OEMs may retain connected‑vehicle data for longer under their own policies.

8. Your rights

You can exercise your data protection rights through:

• Gates (for data we hold)
• The OEM (for data held in connected‑vehicle systems or apps)

Contact details for each OEM are available in their respective privacy policies.