Privacy Policy

This policy describes how we use your personal data when you use our website, 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.

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 Frank G.Gates Ltd, Registered Office, 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 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, Drivers licence details, 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. We receive personal data whilst checking that you have a valid driver’s license, if you will be using one of our courtesy cars.
• 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.
• Recording and monitoring communications. We may monitor and record communications with you, such as telephone conversations and emails, for the purpose of the provision of goods and services, quality assurance, training, fraud prevention and compliance.

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.

If you conduct a vehicle search on our website, GForces deposits a record of the search on your device. If you visit our website again, GForces accesses that record and offers you the option to replicate your previous search to save you time repeating it. It also uses that record to present recommended alternatives to the vehicles you previously viewed. In order to do this, GForces sends details of your previously viewed vehicles (without any personal information) to Amazon Web Services, which produces the recommendations using machine learning. If you don’t want search records to remain on your device, you can clear local storage in your browser. To find out how to manage website data (Local Storage) on popular browsers, see the links below. For information relating to other browsers, visit the browser developer's website.

• Google Chrome

• Microsoft Edge

• Mozilla Firefox

• Microsoft Internet Explorer

• Apple Safari

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.

We use a third party provider, Gubagoo Inc.to supply and support our LiveChat service. If you use the LiveChat service we will collect your name and email address if you provide this and any other personal information that you volunteer to us. This is used for the legitimate business purpose of handling customer enquiries in real time and then following up. This data is stored by Gubagoo for 2 years to enable us to access the information and deal with your enquiry. Gubagoo stores the information in the US under the EU-US privacy shield framework. Please see Gubagoo’s privacy policy for more information on how they use your data. https://www.gubagoo.com/about/policy

We use a third party provider, FingerprintJS Inc.to supply and support our anti-spam service. If you use this service we will collect information relating to a user's device, operating system, browser, browser configuration, IP address, and approximate location. This data is stored by Fingerprint indefinitely. Fingerprint stores the information in the US under Standard Contractual Clauses which provide appropriate safeguards. Please see Fingerprint's privacy policy (https://dev.fingerprint.com/docs/privacy-policy) and DPA (https://dev.fingerprint.com/docs/dpa-gdpr) for more information on how they use your data.

For our online payment facility we use a third party provider, Stripe Payments Europe Ltd. Stripe collect contact details submitted by you along with vehicle deposit values and payment transaction references, for the purposes of providing an online payment solution. Stripe keep data for 31 days, plus a further 14 days in archive.

When you submit a motor finance eligibility check, or apply for finance, we use a third party provider named Codeweavers. Codeweavers collect your personal details such as, name, address, email, date of birth, gender, marital status, dependents, employment details, salary and bank details and send securely to us for the purposes of establishing credit eligibility. Codeweavers privacy policy can be found by visiting https://customerportal.codeweavers.net/app/Codeweavers/gates/privacy-policy/Codeweavers/5uj3bG05Y3Bk02CiEF/policy/FINANCEAPPLY

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
  • check that you have a valid driver’s license and are eligible to drive if you will be using one of our courtesy cars or test driving one of our sales vehicles.
• 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 interests (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, Registered Office, Gates Corner, Edinburgh Way, Harlow, Essex CM20 2EG or by email to data@gates.co.uk. 

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 www.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 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 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

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 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: 

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:

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.

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
• Your drivers licence details for 7 years plus current year if you have used one of our courtesy vehicles.

The above are our standard retention periods. We may keep personal data for an extended period of time where circumstances at the usual deletion date require, such as in the event that legal proceedings are anticipated or ongoing.

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.