This Policy was last updated on 18 May 2018 to take into account new requirements under the General Data Protection Regulation regarding how we inform you about the ways in which we use your personal data, and your rights in relation to that data. Any changes we may make to this Policy in the future will be posted on this page. You can also obtain an up to date copy of this Policy from any dealership or by contacting us using the details set out in section 1 below.
This Policy applies only to personal data processed by or on behalf of the Rybrook Group. We represent a number of vehicle brands and we share some of your information with the relevant manufacturer. For details of the manufacturers’ privacy policies please visit their websites.
1. About us and how to contact us
In this Policy “Rybrook Group”, “we” or “us” refers to each of Rybrook Holdings Limited and its subsidiary companies. Our operating companies are:
You can find the details of the Rybrook Group company that you are dealing with using the information set out in Appendix A.
You can contact us on any matters relating to your personal data by emailing email@example.com or by writing to Data Compliance, Rybrook Holdings Limited, 6 Athena Court, Athena Drive, Tachbrook Park, Warwick, CV34 6RT.
2. What personal data do we collect and why
We collect information from you when you visit our website or dealership locations, purchase something from us, enquire in person about our products (vehicles, parts and accessories) or services, contact us by telephone, email or other means, or respond to a communication from us. We may also receive information about you from the relevant manufacturer. The provision of information to us is largely voluntary; however, if you do not provide us with Transaction information or Preference information, we may not be able to fulfil your order or provide you with updates.
Test Drive information
Vehicle Finance information
Details of your online browsing activities on our website, such as the pages, products or areas of our website that you visit, or which link has brought you to our website from our email communications or thirdparty websites. This includes the new and used vehicle searches that you perform on our website.
This information may be identifiable to you because you are logged in to your account, or because we have collected details of your IP address or the device that you have used to access the website. This may also give us the geographic region which your device reports that you are located in. CCTV footage at our dealership premises.
We use the data we collect about you for various purposes. European data protection legislation sets out specific “lawful bases” for processing personal data. The basis on which we process different information about you and the purpose of that processing are explained below.
Lawful basis and purpose What personal data do we use
Consent: To send you direct marketing in accordance with the preferences you select when you sign up to receive updates, purchase products, or via our preferences centre https://www.rybrook.co.uk/update-personal-information.
Entering into and performance of our contract with you: To discuss and negotiate a transaction (including arranging test drives), fulfil your order, take payment and deliver your products or services to you, to deal with any complaints or any after sales services, including for warranty purposes.
To share information with financial providers should you require vehicle finance for your purchase.
Should you require a specially enabled vehicle, we will process your Sensitive information to ensure that you receive the correct vehicle.
Complying with legal obligations: To confirm your identity, keep records required by law or to evidence our compliance with laws, including tax laws, consumer protection laws and data protection laws. To provide information to law enforcement agencies or other authorities where we are required to do so, including in the event of any offences committed while driving one of our vehicles.
Our legitimate interests: For our internal business administration, to manage customer accounts, including keeping general records of customers, sales, customer care and other interactions, and to protect genuine customers and our business from fraud. This is necessary in order for us to operate efficiently, deal with any issues which may arise and to protect ourselves against any future legal claims and ourselves and others against fraudulent transactions.
Where you are an existing customer or have been in discussions to purchase products or services, to provide you with updates and promotional offers about our products and/or services, MOT/Service reminders and invitations to events, where you have not opted out of receiving such communications from us. This is necessary to support our commercial objectives. We will ensure that we are providing you with relevant details of our products and services where these are of interest to you. They will only ever be sent in line with your stated preferences and interests and you can update your preferences at any time.
Similarly, if you are not an existing customer but have previously enquired about our products or services, to market to you by post or telephone unless you have asked us not to do so.
To manage any competitions or other promotions that you have chosen to participate in.
To improve our marketing activity more generally: This means we use information about you and about our other customers to work out what is working and what is not in terms of our marketing activity or our sales performance, so that we can develop our websites and offers to be more relevant to our customers generally, to improve your online experience and the services we offer. We will also use information provided by your device to recommend the intended geographic website for the location it reports you as being in. Where possible, we will use statistical or pseudonymised data for these purposes.
To safeguard our premises and property.
Your vital interest: To contact you if there are urgent safety or product recall notices to communicate to you or where we otherwise reasonably believe that the processing of your personal information may prevent or reduce any potential harm to you.
3. What are your rights?
You have certain legal rights, which are summarised below, in relation to any of your personal data which we hold.
Where our processing of your personal data is based on your consent, you have the right to withdraw your consent at any time. If you do decide to withdraw your consent we will stop processing your personal data for that purpose. Your withdrawal of your consent won’t impact any of our processing up to that point.
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue to process your personal data.
Your right What does it mean? Limitations and conditions of your right
Right of access
Right to data portability
Rights in relation to inaccurate personal or incomplete data
Right to object to or restrict our data processing
Right to erasure
Right to withdrawal of consent
If you wish to exercise any of your rights please contact firstname.lastname@example.org. Please contact us if you have any concern about how your personal information is processed and we will try to resolve your concerns. If you are not satisfied with our response or you consider that we are in breach of our obligations under data protection laws you may make a complaint to the Information Commissioner’s Office. Please see the Information Commissioner’s website https://www.ico.org.uk for more information.
4. Who do we share personal information with and where are they?
Information collected by one Rybrook Group company may be shared with other companies in the Rybrook Group for the purposes of administrative efficiency. In order to make certain products and/or services available to you we sometimes share your data with trusted third parties.
As explained above, we represent a number of vehicle brands and we share some of your information with the relevant manufacturer. If your enquiry leads to the purchase of a vehicle your information will be shared with the relevant manufacturer for warranty, registration and safety recall purposes. We may also share your information to ensure that you receive the appropriate aftersales support for your vehicle. We will ask for your consent to pass your information to the manufacturer for marketing purposes.
To ensure that the data that we hold remains up to date we periodically cleanse our databases using consumer credit reporting agencies to check contact information. We may use third party service providers such as events management companies, call centres and mailing houses to support our marketing activities. We may also use service providers in less direct ways, such as in the provision of our payment and finance systems, or fraud verification.
We may share any of your personal data with a prospective purchaser of all or any part of our business, on the basis of our legitimate interests and the interests of our purchaser, so that they can appropriately value the business and assess any risks and continue doing business with you after the acquisition.
5. How long do we keep your information for?
We will only retain your personal information for the purposes set out in this Policy and for as long as we have a legal or business requirement to do so. By law, different retention periods apply to different types of records and data, however the longest we will normally hold any personal data is 7 years from the date of your last transaction, for taxation, accounting and risk management purposes. This may be extended in the event of a query, investigation or dispute until fully resolved.
APPENDIX A – LIST OF DEALERSHIPS
Company and Brand (Dealership)
Rybrook Cars Limited
Rybrook Motors Limited
Rycliff Cars Limited