Holt Cars Group Full Privacy Notice
The Holt Cars Group (hereafter “Holt Cars Group”) respects your privacy and is committed to protecting your personal data. This privacy notice explains how we collect, store and use personal information, and tells you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format: we have provided an overview of the policy below, but you can click through to specific areas to find out more about that topic. We will update this policy from time to time so please review it periodically to ensure that you aware of our current data processing arrangements.
Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice. If you have any questions please contact our Data Protection Officer, whose details are included in the “Contact us” section.
Privacy Notice Overview
|Who we are||The Holt Cars Group Limited is the official importer and distributor of Mitsubishi passenger and light commercial vehicles and parts in the UK. Holt Cars Group is made up of a number of legal entities, including the Holt Car Company Limited. Details of the full list of Holt Cars Group legal entities can be found here.|
|The data we collect about you||Depending on the nature of our relationship with you, we will need to collect certain categories of data. We will only collect data which is necessary in the circumstances. We will collect the following categories of data: Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth, gender and driving licence details. Company Data includes job title, company name, company address, phone and fax number, relationship with Holt Cars Group Contact Data includes billing address, delivery address, email address and telephone numbers. Vehicle Data include vehicle ownership, vehicle purchase intention details. Financial Data includes bank account and payment card details. Vehicle Finance Data includes residence history, employment history, nationality, number of dependants, salary, number and type of credit cards, monthly outgoings and credit/debit card details. Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us. Technical Data includes your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses. Usage Data includes information about how you use our website, products and services. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. Find out more.|
|How is your personal data collected||We collect personal data about you in a number of ways. This will include through direct interactions with you (email, telephone or visits to our stores or premises); through purchase of our products or services; through our website; through our network of authorised dealers and from limited third party sources. Find out more.|
|How we use your information||We use your information in connection with supplying Mitsubishi cars, parts and associated products and services. Find out more.|
|Third parties||We will never sell or pass your personal data to organisations not connected with our business. We may disclose your information to Mitsubishi Motors franchise dealers, business partners and to third parties who provide services on our behalf, which necessarily involve processing data. We also use aggregated information, which does not contain information that allows an individual to be identified. This aggregated information is used for monitoring the traffic on our websites, providing business management statistics and helping to improve our advertising and customer communications. Find out more.|
|International transfers||From time to time, we may need to transfer your Personal Information to other companies in the Mitsubishi group that are located outside of the European Economic Area (“EEA”). We also have some suppliers who store personal data outside of the EEA. Where we transfer personal data outside the EEA, we will ensure that our arrangements with them are governed by data transfer agreements, designed to ensure that your personal information is protected, on terms approved for this purpose by the European Commission. Find out more.|
|Security of your information||We have appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We put in place strict confidentiality agreements (including data protection obligations) with our third party service providers and we limit access to your personal data to those employees, agents, contractors and other third parties who have a genuine business need. Your personal data will only be processed according to our instructions and by people who have signed a confidentiality agreement. Find out more.|
|How long do we keep your data||We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Find out more.|
|Your rights||Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights include: Request access to your personal data. Request correction of your personal data. Request erasure of your personal data. Object to processing of your personal data. Request restriction of processing your personal data. Request transfer of your personal data. Right to withdraw consent. Find out more|
|Marketing||We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising and ensure that we only send information which we think will be of interest to you. You may opt-out of our marketing at any time by contacting our DPO. Find out more.|
|Contact Us||If you have any requests or queries regarding our use of your personal data, please contact our Data Protection Officer by e-mail at email@example.com or by writing to Data Protection Officer, the Holt Car Company Limited, Watermoor, Cirencester, Gloucestershire, GL7 1LF. Find out more.|
1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how Holt Cars Group collects and processes your personal data when you use our website, correspond with us, visit our premises, sign up to our marketing emails, purchase a product or service or take part in a competition.
Our website and business is not intended for children and we do not knowingly collect data relating to children.
This privacy notice is the full privacy notice for Holt Cars Group and describes all processing activities for Holt Cars Group. We also provide privacy notices to describe how we use personal data in specific circumstances. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Holt Cars Group is made up of different legal entities, details of which can be found here. This privacy notice is issued on behalf of all the legal entities in Holt Cars Group. When we mention “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in Holt Cars Group responsible for processing your data. Whenever you deal with one of the Mitsubishi companies, the ‘controller’ of your personal information will be the company that you are interacting with or with whom your information has been shared. A ‘controller’ is a company that decides why and how your personal information is processed.
We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
DPO Contact Details
Full details are:
Name of DPO: Carolyn Stephenson
Email address: firstname.lastname@example.org
Postal address: Data Protection Officer, the Holt Car Company Limited, Watermoor, Cirencester, Gloucestershire, GL7 1LF
Telephone (switchboard): 01285 655777
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Change to the privacy notice and your duty to inform us of changes
This version was last updated on 25 May 2018.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Holt Cars Group’s website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where your identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data (Category “A”) includes first name, last name, username or similar identifier, marital status, title, date of birth, gender and driving licence details.
- Company Data (Category “B”) includes job title, company name, company address, phone and fax number, relationship with Holt Cars Group
- Contact Data (Category “C”) includes billing address, delivery address, email address and telephone numbers.
- Vehicle and Part Data (Category “D”) includes vehicle ownership, part purchases and vehicle and parts purchase intention details.
- Financial Data (Category “E”) includes bank account and payment card details.
- Vehicle Finance Data (Category “F”) includes residence history, employment history, nationality, number of dependants, salary, number and type of credit cards, monthly outgoings and credit/debit card details.
- Transaction Data (Category “G”) includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data (Category “H”) includes your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile Data (Category “I”) includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data (Category “J”) includes information about how you use our website, products and services.
- Marketing and Communications Data (Category “K”) includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any information about criminal convictions and offences, save that we will process data relating to driving offences for individuals who borrow company vehicles and for our ECOS and business partner scheme members. We process criminal conviction and offence data on the basis of consent.
Special Categories of Personal Data
We may process special categories of personal information, namely personal data relating to your health, in the following circumstances:
- To be able to provide advice on and assess the suitability of Mitsubishi vehicles and services if you have special medical requirements, for example pacemakers, eyesight restrictions;
- To be able to accommodate Dealer employees with special medical requirements when they attend training courses;
- If you participate in the Mitsubishi Motability scheme to purchase a vehicle; or
- If you submit a complaint or make a legal claim against Holt Cars Group which relates to or involves your health.
In categories 1,2 and 3 above, we will ask you for your express consent to allow us to process personal data relating to your health. If we intend to process health data, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You are under no obligation to provide your consent.
For category 4 above, we do not need your consent, if we use special categories of your personal information because it is needed in relation to the defence of legal claims.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- make enquiries about Mitsubishi products or services;
- apply for or purchase Mitsubishi products or services;
- visit our website or submit a form using our website;
- visit our stores or premises;
- create an account on our website;
- subscribe to our publications and newsletters;
- request marketing be sent to you;
- enter a competition, promotion or survey;
- give us a business card (or similar);
- give us some feedback;
- use our Permissions Area;
- Electronic communications: If you exchange emails, telephone conversations or other electronic communications with our employees and other staff members, our information technology systems will record details of those conversations, sometimes including their content.
- CCTV: Some of our premises have closed circuit TV systems which may record you if you visit our premises, for security and safety purposes.
- Business relationships: If we have a business relationship with the organisation that you represent, your colleagues or other business contacts may give us information about you such as your contact details or details of your role in the relationship.
- Dealers: Holt Cars Group operates a network of independent dealers in the UK (“Dealers”). These organisations are independent legal entities who are authorised to act as dealers in respect of Mitsubishi motor vehicles. Our Dealers provide Holt Cars Group with Identity Data, Company Data, Contact Data, Vehicle Data, Profile Data, Marketing and Communications Data, Financial Data and Transaction Data.
- Third parties or publicly available sources. We may receive personal data about you from various third parties [and public sources] as set out below:
- For anti-money-laundering, background checking and similar purposes, and to protect our business and comply with our legal and regulatory obligations.
- Technical Data from the following parties:
- (a) analytics providers [such as Google LLC based outside the EU and Sophus3 who are UK based];
- (b) advertising networks [such as Dennis Publishing Ltd and Haymarket Media Group Ltd who are UK based]; and
- (c) search information providers [such as Google LLC and Microsoft Corporation based outside the EU].
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
- Identity and Contact Data from data brokers or aggregators
- Identity and Contact Data from publicly availably sources [such as Companies House and the Electoral Register based inside the EU].
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where you have given us your express consent to do so. You have the right to withdraw consent at any time by contacting our DPO.
- Where we need to perform a contract to which you are a party or are about to be a party.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
- Where it is necessary in order to protect your vital interests.
Please see out Glossary for a more detailed explanation of some of these terms.
5. Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact our DPO if you need details about how we use your data or the specific legal ground we are relying on to process your personal data.
Where you have provided your consent
|Activity||Mitsubishi company processing data *||Data Categories +|
|To send you emails to keep you up to date with the latest Mitsubishi special offers, events, services and products.||CCC, SDS, SRL||A, C, D, H, K|
|To supply brochures and other marketing materials to you||CCC, SDS, SRL||C, D, H, K|
|To conduct surveys about our products and services||CCC||A, C, D, I, K|
|To register for our Kit 4 Clubs scheme||CCC||A, B, C, H|
Where we need to perform the contract, we are about to enter into or have entered into with you
|Activity||Mitsubishi company processing data*||Data Categories +|
|To process and deliver your orders including managing payments, fees and charges||CCC, SDS, SRL||A, B, C, D, E, F, G, H, I, J, K|
|To enable you to partake in a prize draw or competition||CCC||A, C, D|
|To process vehicle orders under our Employee Car Ownership or Business Partners scheme||CCC||A, B, C, D, E|
|To organise fleet cars for journalists||CCC||A, B, C|
|To organise marketing activity for brand ambassadors||CCC||A, B, C|
|To facilitate the purchase and renewals of vehicle leases and financial agreements||CCC, SDS||A, B, C, D, E, F, G, I, J|
|To process and fulfil our warranty and service obligations to you||CCC||A, B, C, D, G, I|
Where it is necessary for our legitimate interests (or those of a third party)
|Activity||Mitsubishi company processing data*||Data Categories||Legitimate interest|
|General business need|
|To administer and protect our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||CCC, SDS, SRL||A, B, C, D, E, F, G, H, I, J, K||To ensure that our website remains up to date and is secure.|
|To arrange test drives through our website or online sales platform||CCC, SRL||A, B, C, D, H, I||To arrange test drives of our cars for prospective customers|
|To run, maintain and develop our network drives, internal applications, systems and databases to improve business efficiency and ensure that such systems are kept up to date||CCC, SDS, SRL||A, B, C, D, E, F, G, H, I, J, K||To ensure that our IT systems and programs are kept up to date and are secure|
|To undertake the management of backups for network drives, internal applications, systems and databases||CCC, SDS, SRL||A, B, C, D, E, F, G, H, I, J, K||To ensure that information is securely backed up|
|To use data analytics to improve our website, products, services, marketing, customer relationships and experiences||CCC, SDS, SRL||A, C, D, G, H, I||To better understand our customer’s buying habits and preferences|
|To operate, manage, develop and promote our business and, in particular, our relationship with the organisation you represent (if any) and related transactions – this includes, for example, billing / payment purposes||CCC, SDS, SRL||A, B, C, D, E, G, H, I||To maintain business to business relationships|
|To protect our business from fraud, money-laundering, breach of confidence, theft of proprietary materials and other financial or business crimes||CCC, SDS, SRL||A, B, C, D, E, F, G, H, I||To detect and prevent fraud and other criminal activity|
|To collect CCTV footage on and around our premises||CCC, SRL||A||To detect and prevent crime; for the safety of our employees and visitors; and to protect our stock and premises|
|To enforce payment and recover debts owed||CCC, SDS, SRL||A, B, C, D, E, F, G||To allow the business to recover monies which are owed to it|
|To undertake audits and for reporting purposes to help us manage our business effectively and efficiently||CCC, SDS, SRL||A, B, C, D, E, F, G, H, I, J, K||To allow us to monitor the efficiency of our business and to identify areas of improvement|
|To analyse Mitsubishi connected car data||CCC||A, C, D||To provide additional vehicle information to help us build relationships with the wider Mitsubishi Motors group, with customers and to support customers generally.|
|To create and maintain online accounts for our customers||CCC, SRL||A, B, C, D, E, F, G, H, I, J, K||To allow us to provide online services to our customers|
|To handle queries and requests which are made by customers, prospective customers and our dealers||CCC, SRL, SDS||A, B, C, D, E, F, G, H, I, J, K||To allow us to respond to enquiries from customers.|
|To collect and analyse information from recorded calls and webchats when customers, prospective customers and our dealers contact our service centres||CCC, SRL||A, B, C, D, G, H, I, J, K||For training and monitoring purpose and to ensure that we have an accurate record of any information provided|
|To process claims for insurance for damage and accidents under our Employee Car Ownership and Business Partner scheme||CCC||A, B, C, D, J||To ensure that we are able to recover the financial losses suffered due to damages or accidents|
|To undertake credit checks to assess creditworthiness, confirm identity, manage your account effectively and where necessary trace and recover debts and prevent criminal activity||SDS,SRL||A, B, C, D, E, F, G, I, J||To ensure that financial products are suitable for customers and that the business will be able to recover monies advanced|
|For general business administration and service notifications||CCC, SDS, SRL||A, B, C, D, G, I, J, K||To provide essential administrative services to the business|
|To provide for restructures or reorganisations or to prepare for the sale of all or part of our business||CCC, SDS, SRL||A, B, C, D, E, F, G, I, J, K||To allow the business to make changes in preparation for a sale, in order to achieve the best value|
|To organise events such as dealer trips, conferences and major sponsorship events||CCC||A, B, C, I||To build goodwill with and to reward our dealers, staff and business contacts|
|To conduct surveys about our products and services||CCC||A, C, D, I, K||To collect feedback about our products and services in order to improve satisfaction|
|To send postal or electronic marketing to you where we consider such marketing relevant to you and where we are satisfied that we have a legitimate interest in doing so||CCC, SDS, SRL||A, B, C, D, G, I, J, K||To allow us to market our products to customers who have expressed an interest in those products|
|To analyse our marketing strategy and create customer profiles, in order to allow us to adjust strategy accordingly in order to best promote our business||CCC, SDS, SRL||A, D, G, H, I, J, K||To build accurate profiles of our customers in order to influence marketing strategy|
|To conduct market research to better understand our existing and potential customer base||CCC, SDS, SRL||A, B, C, D, G, H, I, J, K||To better understand our customer’s buying habits and preferences|
|Creation of social media customer audiences||CCC||A, B, C, D, G, H||To build custom audiences to deliver relevant, interesting marketing communications to audiences that may otherwise be difficult to reach.|
|B2B and Dealer Management|
|To process reimbursements to dealers for financial incentives||CCC, SDS||A, C, D, G, I||To reimburse dealers with incentive values they’ve provided to customers|
|To administer our plug-in vehicle grant scheme||CCC||A, B, C, D, G, I||To obtain reimbursement of plug-in vehicle grants|
|To assess the suitability of applications for potential new franchise dealers||CCC||A, B, C, E, F||To ensure that any new dealers meet our required standards|
|To support dealers with the resale of finance plans to customers||SDS||A, B, C, D, G, I||To ensure our dealers have the support and information required to enable them to resell finance plans|
|Onward transmission of customer details to Fleet Alliance where initial application for finance was declined, in order to try to secure business contract hire for the customer||SDS, SRL||A, B, C, D, E, F, I||To try to obtain finance for customers who have been declined from their initial application|
|To provide training for the employees of Dealers, including apprentices||CCC||A, B, C||To increase the skillset of the employees of our Dealers|
Where we need to comply with a legal or regulatory obligations
|Activity||Mitsubishi company processing data*||Data Categories +|
|To assist HMRC, the police, the Driving and Vehicle Licencing Agency (DVLA) or any other regulatory entity||CCC, SDS, SRL||A, B, C, D, G|
|To comply with our legal, regulatory and tax obligations and to bring and defend legal claims.||CCC, SDS, SRL||A, B, C, D, E, F, G, H, I, J, K|
|To complete the first registration of a new vehicle with the DVLA||CCC, SRL||A, B, C, D|
|To comply with any request you make to enforce any of your legal rights||CCC, SDS, SRL||A, B, C, D, E, F, G, H, I, J, K|
|To notify you of any non-urgent safety or product recall notices||CCC, SRL||A, B, C, D, G, I, K|
Where it is in your vital interests
|Activity||Mitsubishi company processing data*||Data Categories +|
|To contact you to notify you of any urgent safety or product recall notices as such processing is in your interests and is necessary to ensure that we prevent potential harm to you.||CCC||A, B, C, D, G, I|
* Please see “About Holt Cars Group” for full names of Mitsubishi companies
+ Please see “The Data We Collect About You” section above for a description of each category of personal data
We will tell you, when we ask you to provide information about yourself, if provision of the requested information is necessary for compliance with a legal obligation or, on the other hand, if it is purely voluntary and there will be no implications if you decline to provide the information. Otherwise you should assume that we need the information for our business or compliance purposes (as described above).
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising and ensure that we only send information which we think will be of interest to you. You may opt-out of our marketing at any time by following the opt-out links on any marketing message sent to you, by contacting our DPO.
Promotional offers from us
We may use your Identity, Contact, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside the Mitsubishi group of companies for marketing purposes.
You can ask us or participating third parties to stop sending you marketing messages at any time by logging into the Permissions Area and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting our DPO at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of your purchase of a product or service, your reported experience of a product or service experience, warranty registration or other transactions.
Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our DPO.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
7. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in section 5 above.
- Internal Third Parties as set out in the Annex 1
- External Third Parties as set out in the Annex 1.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
- Your colleagues within the organisation that you represent;
- Service providers who host our website or other information technology systems or otherwise hold or process your information on our behalf, under strict conditions of confidentiality and security;
- A person who takes over our business and assets, or relevant parts of them;
- In exceptional circumstances:
- competent regulatory, prosecuting and other governmental agencies, or litigation counterparties, in any country or territory; or
- where we are required by law to disclose
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
8. International Transfers
We share your personal data within the Mitsubishi Group. This will involve transferring your data to countries outside the European Economic Area (EEA), which do not have similarly strict data privacy laws. Where we transfer personal data to other members of the Mitsubishi Group, we will ensure that our arrangements with them are governed by data transfer agreements, designed to ensure that your personal information is protected, on terms approved for this purpose by the European Commission.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
Please contact our DPO if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
9. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a genuine business need. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. Data Retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We have a data retention policy in place which provides guidance to our employees on data retention.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. We will also consider whether there are legal reasons why we may need to contain data for longer than we would otherwise keep it.
Note that we may retain some limited information about you even when we know that you have left the organisation that you represent, so that we can maintain a continuous relationship with you if and when we are in contact with you again, representing a different organisation.
Details of retention periods for different aspects of your personal data can be obtained from us by contacting our DPO.
11. Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
No Fee Usually Required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time Limit to Respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting our DPO.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Annex 1: Third Parties
- Internal Third Parties
- Within the Holt Cars Group Limited, where necessary.
- Other companies in the Mitsubishi Group, who are based Japan and to whom we undertake leadership reporting
- External Third Parties
- Mitsubishi authorised dealers, acting as controllers, to supply Mitsubishi cars, parts and associated products and services
- Service providers acting as processors who provide:
- IT, software and system administration services (please note that one of our IT providers is based in the USA); customer survey services; social media services; data management services; logistics, vehicle preparation and auction services; after-sales care plan provider; recall campaign coordinators; event planners; electric vehicle charging providers; e-Learning and training providers; apprenticeship programme managers; the Institute of the Motor Industry; Security service providers; and credit reference agencies
- Professional advisers acting as controller including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services
- HM Revenue & Customs, DVLA and other regulators and other authorities acting as controller based in the United Kingdom who require reporting of processing activities in certain circumstances
- Lloyds Banking Group and Fleet Alliance Limited, acting as controllers, who provide finance for our customers to enable the purchase of vehicles
- Allianz Insurance plc, acting as a controller, who provide Mitsubishi Assistance Package/Roadside Assistance, MOT protection, Extended Warranty, Extended Mileage Warranty services to our customers
- Original Insurance Services , acting as a controller, who provide Mitsubishi Insurance, Mitsubishi First and Excess Return products
- Car Care Plan Limited, acting as a controller, who provide gap insurance for our customers
- Zurich Insurance plc, acting as a controller, who provide motor insurance for our ECOS drivers
- Office for Low Emission Vehicles acting as a controller, who administer the plug-in vehicle grant
- The Motoring Ombudsman, acting as a controller, who provide automotive dispute resolution services
- Equifax Limited, acting as a controller, who run an Electronic Watch List check to obtain an anti-money laundering report if you choose the cash payment method
- Retention UK Ltd, acting as a controller, who provide our customers with an excess return voucher service
- Facebook Ireland Limited, acting as a joint controller, for the creation of customer audiences. Annex 2: Your Legal Rights
Annex 2: Your Legal Rights
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Annex 3: About Holt Cars Group
|Holt Cars Group company||Abbreviation||Registered Address||Company Registration number||Trading names|
|The Holt Car Company||CCC||Watermoor, Cirencester, Gloucestershire, GL7 1LF||01163954||Mitsubishi Motors in the UK|
|Spitalgate Dealer Services Limited||SDS||Watermoor, Cirencester, Glos, GL7 1LF||01646788||Shogun Vehicle Leasing|
|Shogun Retail Limited||SRL||Watermoor, Cirencester, England, GL7 1LF||10910706||Mitsubishi Buy Online|