1. Who we are
We are Turbocentre Car Sales Limited and are Registered in England & Wales, Postal address at P.O Box 7764 Rushden Northants NN10 1BR and Registered Office First Floor 677 High Road, North Finchley, London, N12 0DA:-
Within this policy Turbocentre Car Sales Limited are hereafter referred to as ‘us’ ‘we’ or ‘our’ and visitors/users of this website are referred to as ‘you’ or ‘your’.
- Turbocentre Car Sales Limited (Company Number 3050148) which is authorised and regulated by the Financial Conduct Authority;
We are also registered with the Information Commissioner's Officer with the following registration numbers:
- Turbocentre Car Sales Limited number ZA039601
2. What is Personal Information?
Personal information is any information which we collect about you that can be used to identify you and is stored either electronically or in a usable filing system.
Personal information will include any information, such as your name, address, ip address, vehicle registration number, that is collected about you by us for any reason, whether it be in connection with a purchase, by visiting our website or by contacting us.
It also includes any personal information that we may collect about you that is in the public domain, such as information made public on social media that is available to us when you connect with us on social media.
It is our intention to provide you with as much information as possible about what we do with that personal information, so that when you provide the personal information to us, you do so with an awareness of how it will be used.
3. How we collect your personal information and why
Turbocentre Car Sales will need to collect personal information about you, and there are different ways that we might do so; this privacy notice tells you what to expect when we collect personal information:
(a) from visitors to our website, www.turbocentre.co.uk;
(b) through social media;
(c) anyone referred to us from enquiries made of our brand partners (via their websites or otherwise) or used vehicle websites such as Ebay, Piston Heads or Carwow;
(d) anyone who contacts us;
(e) anyone who purchases a vehicle;
(f) anyone who uses our service and maintenance services;
(g) anyone who subscribes to our marketing.
You can block cookies at any time by activating the setting on your browser that allows you to refuse some or all cookies. However, if you do block cookies there may be parts of our website that you will be unable to access or that will not function properly.
We use the following types of cookies:
(a) Strictly necessary cookies.
These are cookies that are essential for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
|Global||recent_cars||1 month||Used to store cars a site visitor has recently viewed in order to present them back to the visitor on other pages.|
|Global||ASP.NET_SessionId||1 month||At end of visit - General purpose platform session cookie, used by sites written with Miscrosoft .NET based technologies. Used to maintain an anonymised user session by the server. Used by the website to serve the correct data to the site visitor.|
(b) Analytical/performance cookies.
They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
|UK & Worldwide||SC_ANALYTICS_GLOBAL_COOKIE||10 years||Used to track site pages visited|
|UK & Worldwidel||_dc_gtm_UA-324282-13 _dc_gtm_UA-324282-1||1 min||These cookies enables us to manage data in Doubleclick to improve reporting on campaign performance|
(c) Functionality cookies.
These are used to recognise you when you come back to our website so that we can personalise our content for you, greet you by name and remember your preferences (for example, your region).
|UK & Worldwide||optimizelyEndUserId||6 months||Used to track site pages visited|
|UK & Worldwidel||_dc_gtm_UA-324282-13 _dc_gtm_UA-324282-1||1 min||Enables personalised content and allows us to serve different versions of web pages to improve performance
3.2.2 Third party services
Whenever you visit our website, www.turbocentre.co.uk, we will use a third party service, Google Analytics, to collect standard information about your website use, such as internet logs and details of your visitor behaviour patterns. The reason we use this service is that it is within our legitimate interests to find out how many people visit the website and the various parts of the website, it improves the service provided to you and improves customer experience. This information helps us to find out how our website is working and how to improve it. We do not identify anyone, and we do not make or allow Google Analytics to (or attempt to) identify anyone visiting our website.
3.3 Social media
Any information you provide to us via social media (including messaging, "liking", "following" and other communications) is controlled by the social media network. Our website contains links to our social media pages. We currently use:
3.3.1 Twitter, which has its own privacy notice that can be located at https://twitter.com/en/privacy;
3.3.2 Facebook, which has its own privacy notice that can be located at https://www.facebook.com/privacy/explanation;
3.3.3 Instagram, which has its own privacy notice that can be located at https://help.instagram.com/519522125107875?helpref=page_content.
We recommend that you read their privacy notices and contact them directly if you have any concerns regarding their use of your personal information.
3.4 Contacting us
Our website provides you with different ways to contact us. All communications are handled, reviewed and responded to internally by us.
As part of communicating with us, you will also submit personal information about you that we require in our legitimate interest. This includes your name, address and additional contact details.
Any personal information that is provided in and during communications is used only for the purpose of reviewing the communications and conducting the ongoing administration and management of communications. We will not use your personal information in an identifiable manner in any publication without your further explicit consent.
We will delete this personal data when we reasonably consider that we no longer need it for this purpose. Please note that we may need to contact you about the application through any of post, email or telephone. Please can you make sure that you keep us updated of any changes to your contact details.
3.5 Personal information collected when you purchase a vehicle
When you purchase a vehicle, we will need to collect information from you relating to your purchase. This varies depending on whether you are purchasing the car with or without finance.
When collecting personal information from you relating to a purchase (either with or without finance), we will either complete a hard copy order form or an electronic order form when you visit. If you complete a hard copy sales form, one of our personnel will input the information manually in to our electronic system within 24 hours and destroy the hard copy form.
We may also hold personal information related to your purchase in a hard copy file in a secure physical filing system, at the centre that you attended when you made your purchase or at a secure document archiving facility.
All electronic and hard copy files, relating solely to purchase information, will be destroyed after 7 years. If you opt in to receive marketing materials, your contact details will be retained unless and until you opt out of receiving such communications. More details about withdrawing your consent can be found here.
This personal information includes the purchaser's name, address, vehicle registration number and payment details, which are a contractual necessity without which we cannot proceed with your purchase. If you are purchasing on behalf of a business but are not the business owner we will also collect this information about the owner. We will also collect your name, address (if different from the purchaser's), contact details, email, business name (if applicable) and the number of vehicles, operating locations and employees. It is in our legitimate interests to collect this additional information in order to manage and administer your purchase and our relationship with you; for example, we may call you to let you know that your vehicle is ready to be delivered and therefore deliver to the appropriate operating location.
This personal information includes the purchaser's name, address, date of birth, vehicle registration number, salary and expenditure details, employment history, payment details and bank details, which are a contractual necessity without which we cannot proceed with your purchase. If you are purchasing on behalf of a business but are not the business owner we will also collect this information about the owner. We will also collect your name (if applicable) and the number of vehicles, operating locations and employees. It is in our legitimate interests to collect this additional information in order to manage and administer your purchase and our relationship with you; for example, we may call you to let you know that your vehicle is ready to be delivered and therefore deliver to the appropriate operating location.
We process information relating to your finance application on behalf of our finance providers, who are acting as a data controller. Please refer to Section 4 below for further details of our finance providers.
3.6 Vehicle service, maintenance and repair
You may also visit us to have your vehicle serviced, maintained or repaired, and we will process your personal data when you do.
We will collect your and (if different) the vehicle owner's name and address, the vehicle registration number and your payment details as a contractual necessity in order to provide you with a service. If you do not provide these details, we will not be able to provide you with our services.
We will also collect your contact details, date of birth, gender, marital status, identifiers issued by public bodies (e.g. Driving License Number), email address, the business name (if applicable), number of vehicles, your operating locations and number of employees. If you are not the business owner, we will also collect the name and contact details of the business owner, and it will be your responsibility to ensure that such person is provided with a copy of this notice. It is in our legitimate interests to collect this information in order to tailor the service we provide; for example, to call you to give you an update on the progress of the service or on the arrival of an ordered part.
3.7 Subscribing to our marketing
If you are a customer, or have made an enquiry into our products or services, we will provide you with a clear choice to consent to receiving marketing promotional material, updates, reminders and communications by giving you an opt-in to receiving such communications. If you have provided your consent we will collect your contact details (name, postal address and email address) and vehicle details (make and model) to provide you with such communications. You have the right to withdraw your consent at any time. For full details on how to withdraw consent please see below.
We will either collect your personal information, in a hard copy form or an electronic form at one of our computer points or over the telephone or via our website. If we use a hard copy form, one of our personnel will within 24 hours manually input the information into our electronic system and destroy the hard copy. All electronic files are stored on our Dealer Management System,
If you ever decide you no longer wish to receive our marketing communications, you can opt out at any time by using the contact details below. If you do opt out, please note that we will still keep your details in our system marked as ‘denied’ so that we can make sure that you do not receive our marketing communications again in the future.
4. Your data and third parties
We do use third parties to provide services to us from time to time; therefore, we will need to share data with them that it is in our legitimate interests for business administrative needs. A list of third parties that we use and how they process personal information is set out in the table below. Part I of the table refers to such third parties that are located within the EEA. Part II of the table refers to such third parties that are located outside of the EEA and sets out what additional safeguards we have in place to protect your personal information when transferring personal information outside of the EEA.
|Third Party||What Data||Why do we share this data||Data retention by third party|
|Finance Providers and Regulatory Compliance For Finance|
|Black Horse Limited (trading as Black Horse Motor Finance)||Name, title, address, email address, phone number, date of birth, age, sex, identifiers issued by public bodies (e.g. Social Security / National Insurance, Passport number), marital history / status, salary and expenditure, family and household members, housing status (e.g. privately owned, rented, living with parents), employment and career history, employment termination details, income, payments, loans or grants, bank details.
||Sales and finance||For information on how Black Horse Limited use your personal data please refer to their privacy notice at: https://www.blackhorse.co.uk|
|Mann Island finance||Sales and finance||For information on how Mann Island Finance Limited use your personal data please refer to their privacy notice at: www.mannisland.co.uk|
|ITC Compliance||Regulatory Compliance Requirements for Finance||For information on how ITC Compliance use your personal data please refer to their privacy notice at: www.itccompliance.co.uk|
5 . Disclosure of personal information
We will not usually disclose your personal information other than as already explained in Section 2 and 3 above. However, there may be circumstances where we need to share personal information other than as anticipated in Section 2 and 3 above. These include:
5.1.1 where we are legally required to disclose the information. This includes sharing the personal information with tax authorities and law enforcement agencies for the purposes of the prevention and detection of crime;
5.1.2 where we need to disclose the personal information for the purpose of or in connection with any legal proceedings, or for the purpose of obtaining legal advice, or the disclosure is otherwise necessary for the purposes of establishing, exercising or defending legal rights;
5.1.3 disclosure is required to protect the our interests, or someone else's interests (for example, to prevent fraud);
5.1.4 disclosure is necessary to protect your vital interests (for example if you are unwell at our premises, we may need to seek medical assistance);
5.1.5 it is to a third party for the purposes of providing administrative or processing services on our behalf. If such disclosure is required we will take steps to ensure that the third party protects the personal information in the same way that we do and notify you of any changes to this privacy notice; and
5.1.6 to any prospective purchaser of our business assets or organisation.
6 . Keeping personal information secure
We know that you provide your personal information in good faith and expect it to be looked after. This is why we take the security of your personal information seriously. This means that we have taken steps internally in order to ensure that our systems adequately protect your personal information. This includes:
(a) keeping special categories of data in a separate password protected file to all other personal information;
(b) locating all personal information that we control on internal servers located in the United Kingdom;
(c) ensuring strict access controls on a need to know basis; and
(d) monitoring access to the personal information.
7. Your rights
You have rights in respect of your personal information and this Section explains a bit more about those rights that are applicable to what we do with your personal information and when you can exercise them. If you would like more information about any of your rights, please contact us on the details set out below.
7.1. Withdrawing consent
Where you have explicitly consented to us processing special categories of data, you can withdraw consent to our processing the special categories of data at any time during the application process. If you wish to withdraw consent, please do so by sending your request in writing to our contact details below.
7.2. Accessing your personal information
We want you to fully understand and be comfortable with how we use your personal information. You can contact us at any time to ask whether we process any personal information about you. If we do hold or use your personal information in any way, you have the right to access that personal information. All we ask is that:
7.2.1 you make your request to access in writing to the contact details below;
7.2.2 you verify your identity; and
7.2.3 you are fair and reasonable with how often you make this kind of request (otherwise we may be entitled to charge a fee for handling excessive requests). Please allow us up to one month from receipt of your request in order to provide a response.
7.3. Requesting more information
We hope that you can understand that it is very difficult to cover all the possible ways in which we collect and use personal information. We have tried to be as clear and as open as we can and will continue to update this privacy notice as our use of personal information develops. However, if you have any questions regarding our use of your personal information, we will be happy to give you peace of mind by answering any questions or providing any additional information that we can. If you do have any specific questions, or need anything explaining, please get in touch on the contact details below.
7.4. Additional rights
You also have some additional rights that you may exercise as set out here. We may publish a policy, from time to time, to explain how we will handle such requests and what you can expect from us when you make a request to exercise your rights. If we do publish any such policy, we will provide a link to it here. In each instance we may ask you to make your request in writing to the contact addresses below and provide verification of your identity.
7.4.1 You have the right to request that we rectify any inaccuracy about you that we may hold, in which case we may ask you to verify the corrected information (for example, we may ask for a recent utility bill for proof of change of address)
7.4.2 You have the right to request that we erase your personal information. Please be aware that we can only comply with such a request if
(a) your personal information is no longer required for the purposes it was collected for (for example, we need your personal information to respond to a communication);
(b) the collection, storage or use of the personal information by us is prevented by law;
(c) your personal information is not required for the purposes of establishing, exercising or defending a legal claim such as in the conduct of legal proceedings.
7.4.3 You have the right to request that we restrict or refrain from processing your personal information:
(a) for the time it takes us to verify the accuracy of your personal information where you have disputed its accuracy;
(b) where the collection, storage or use of the personal information by us is unlawful but you decide not to ask for erasure;
(c) where, we no longer need your personal information but you need them for the purposes of establishing, exercising or defending a legal claim;
(d) for the time it takes to determine whether we have an overriding legitimate ground to continue to process your personal information, where you have exercised your right to object to processing.
7.4.4 You have the right to data portability in respect of information we have collected from you based on consent or for the reason of entering into a contract. If you exercise this right, we will transfer a copy of the information that you have provided to us at your request.
7.4.5 You have the right to object to our use of your personal information:
(a) where we are using that information based on our legitimate interests, and where we do not have compelling overriding grounds to continue to use your personal information; or
(b) at any time, where we use your personal information to send you the newsletter or any other type of direct marketing, in which case it will no longer be used for that purpose, but may use it for another lawful purpose.
You are important to us, and so is protecting your personal information. We have high standards when it comes to collecting and using personal information. For this reason, we take any complaints we receive from you about our use of your personal information very seriously and request that you bring any issues to our attention.
Where you are communicating with us for the purpose of making a complaint, we will only use your personal information to handle, investigate and respond to the complaint and to check on the level of service we provide. Where the complaint is about a member of our team, we may have to disclose your identity to whoever the complaint is about. You may let us know that you don't want information that identifies you to be disclosed and we will try to respect your request; however, it may not be always possible to handle a complaint on an anonymous basis. If you are unhappy, you can also contact the Information Commissioner's office to make a complaint directly.
9. Updating this privacy notice
We keep our privacy notice under regular review in order to ensure that it properly reflects our use of personal information. This privacy notice was last updated on 22 May 2018.
10. Contacting Us
You can contact us by:
Post: PO Box 7764 Rushden, Northants NN10 1BR | Email: firstname.lastname@example.org | Telephone: 0345 873 1444
Limited Company No. 3030148 | Authorised and regulated by the financial conduct authority FRN 652927 | VAT number 656896274