
We are Frank G Gates Ltd, Company Number 00245843, with our registered office at: Gates Corner, Edinburgh Way, Harlow, Essex CM20 2EG
You can contact us by email, data@gates.co.uk, or by post:
Data Protection Team, Frank G Gates Ltd, Gates Corner, Edinburgh Way, Harlow, Essex CM20 2EG
We have a dedicated data protection team who oversee our handling of personal data.
You can contact our data protection team in writing at Frank G.Gates Ltd, Registered Office, Gates Corner, Edinburgh Way, Harlow, Essex CM20 2EG or by email at data@gates.co.uk.
We collect personal data in several ways:
1. Personal data you provide to us
Examples include:
2. Personal data we receive from third parties
Examples include:
3. Personal data collected through our website
Examples include:
4. Recording and monitoring communications
We may record telephone calls, emails, and live chat interactions for:
We use your personal data for the following purposes:
We use the following lawful bases under UK GDPR:
Processing Activity | Personal Data | Lawful Basis | Notes |
Handling enquiries | Contact details, enquiry info | Legitimate interests | Necessary to respond to your enquiry |
Vehicle sales & servicing | Contact details, transaction info | Contract | Required to provide goods/services |
Test drives | Driving licence details | Legal obligation & legitimate interests | Required to ensure eligibility and safety |
Courtesy vehicles | Driving licence details | Legal obligation | Insurance and regulatory requirements |
Finance applications | Identity, financial info | Contract | Required to submit finance applications |
Marketing communications | Contact details | Consent or soft opt‑in (email/SMS only) | PECR‑compliant; opt‑out always available |
Website analytics | IP address, device info | Consent | Non‑essential cookies require prior consent |
Anti‑spam protection | Device fingerprinting | Legitimate interests | Strictly necessary for fraud prevention |
Call recordings | Voice recordings | Legitimate interests | Quality, training, compliance |
CCTV (if applicable) | Video footage | Legitimate interests | Security and crime prevention |
Our website uses cookies and similar technologies. Non‑essential cookies (analytics, advertising, functionality) are only used with your consent.
Please see our Cookie Policy for full details.
We will ask for your consent when:
You can withdraw consent at any time.
You are not legally required to provide personal data, but if you choose not to, we may be unable to provide certain goods or services (e.g., test drives, finance applications).
You have the following rights under UK GDPR:
To exercise your rights, contact: data@gates.co.uk
We do not make automated decisions about you. However, finance companies may use automated decision‑making when assessing your creditworthiness. You have the right to request human review from the finance provider.
We share your data with:
We may also share your personal information with third parties on a one-off basis, for example, if:
Controller/Processor Roles:
Third Party | Role | Purpose | Location |
Keyloop | Processor | CRM, Website hosting, analytics, forms | EEA |
AWS | Sub‑processor | Cloud hosting | EEA/Global |
Migogo | Processor | Live chat | UK |
FingerprintJS | Processor | Anti‑spam | USA |
Stripe | Processor | Payments | EU/USA |
Codeweavers | Controller | Finance eligibility | UK |
Mailchimp | Controller | Email marketing | USA |
OEMs | Joint controllers | Vehicle data, customer relationship | Global |
Finance companies | Controllers | Credit assessment | UK |
We use:
We will add your details to our marketing database if:
We use MailChimp for email marketing and so your information is transmitted to MailChimp. Mailchimp is an online marketing platform operated by The Rocket Science Group LLC, a company headquartered in the State of Georgia in the United States. MailChimp is prohibited from selling your data and from using it for purposes other than sending email. More information can be found here. When you give us permission to store your personal information and email address and to send you marketing emails, this consent can be revoked at any time via the unsubscribe link in every mailing.
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.
Retention Schedule:
Data Type | Retention Period | Notes |
Financial records | 7 years | Legal obligation |
Customer contact details (marketing) | 7 years from last transaction | Soft opt‑in applies |
Enquiry contact details | 3 years | Legitimate interests |
Customer sales files | 7 years | Contractual necessity |
Complaints | 7 years | Regulatory requirement |
Job applications | 6 months | Legitimate interests |
Driving licence (courtesy vehicle) | 7 years + current year | Insurance requirement |
Driving licence (test drive) | 3 years | Legitimate interests |
CCTV | 30 days (typical) | Security |
Call recordings | 12 months | Training & compliance |
Website analytics | 26 months (GA4 default) | Consent required |
Visitor Chat logs | 2 months to contract end + 3 months | Processor retention |
Stripe payment logs | 31 days + 14 days archive | Processor retention |
Codeweavers finance data | As required for finance assessment | Controller retention |
We may retain data longer if legal proceedings are anticipated.
Some providers store data outside the UK/EEA. Where this happens, we use appropriate safeguards:
International Transfer Mechanisms:
Provider | Country | Safeguard |
Mailchimp | USA | UK–US Data Bridge / SCCs |
FingerprintJS | USA | SCCs |
Stripe | USA/EU | SCCs |
AWS | Global | SCCs / IDTA |
OEMs | Global | OEM contractual safeguards |
If you are unhappy with how we use your personal data, contact our Data Protection Team at data@gates.co.uk.
You can also complain to the ICO: www.ico.org.uk
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.
We may update this policy from time to time. You can request a copy at any time by emailing data@gates.co.uk.