GROUP

THURLOW NUNN DATA PRIVACY STATEMENT

Like you, we take your privacy very seriously. This information is therefore designed to provide you with appropriate information, assurance and confidence that we are handling your data in a secure, professional manner. This statement therefore addresses what personal information we collect and how we handle the personal information shared with us. Please read the following carefully to understand our views and internal practices.

For the purposes of the General Data Protection Regulation (GDPR), the Data Controller at Thurlow Nunn is the Data Protection Officer.

This statement was most recently reviewed in August 2023. It is subject to regular reviews and may be updated in accordance with changes to legislation or internal processes.

 

WHAT DO YOU USE MY DATA FOR AND HOW LONG DO YOU KEEP IT?

We use your data for business, regulatory and legal purposes like:

  • Processing an order and an invoice for a new or pre-owned vehicle
  • Processing an order and an invoice to carry out Aftercare services for your vehicle
  • Getting in touch if we need to tell you about a manufacturer upgrade or recall due on your vehicle
  • To undertake both hard and soft credit checks when you apply for a financial product
  • To recover debt, this may also include sharing your information with debt recovery agents, our solicitor, and the Courts
  • Ensuring any manufacturer warranties you may have are recorded against your personal data
  • To meet manufacturer standards
  • To meet Financial Conduct Authority (FCA) regulations
  • To meet HMRC regulations as any history shown on invoices must be kept for 7 years for VAT purposes.

We also use your data, with your permission, to recommend things we think you will like and that includes:

  • Launches of brand new vehicles
  • Special offers about the products and services that we provide
  • Notifying you about events that we hold throughout the year
  • Reminding you about your servicing and MOT intervals

We will normally only keep your data for as long as necessary to give you the services you are using. If you haven't visited us in the last four years, we may have classed your data as dormant or even deleted it.

We will never sell your data.

 

CAN I CHANGE, DELETE OR SEE MY DATA & WHAT ARE MY RIGHTS?

Yes of course you can. You can request to change, delete or see your data held on our database at Thurlow Nunn any time; these are your rights under GDPR.

Please note, we may require proof of identity in order to complete some requests. A copy of your driving licence is the most suitable, however other forms of photographic identity are also acceptable.

There are three ways in which you can do this:

1. You can manage your data preferences on our website: www.thurlownunn.co.uk

2. You can write to us at Data Privacy, Thurlow Nunn, 11 Campbells Meadow, King's Lynn PE30 4YN

Or you can email us at [email protected]

 

 

YOUR LEGAL RIGHTS EXPLAINED

 

Your rights include:

Right to Access/Subject Access Requests – The Right to Access provides you with the opportunity to obtain all the information Thurlow Nunn holds against you as an individual (also known as Subject Access Requests). The GDPR allows Thurlow Nunn one month to provide you with all the information we hold against you, your vehicle and your address. This will solely be in relation to the person making the request. We will review all our manual and electronic data and provide you with everything accordingly. If your request specifies what documentation you require, this will assist us in responding to your request quicker.

Right of Rectification – If you believe that the information that we hold about you is incorrect, inaccurate or incomplete, the right of rectification ensures that you can contact us and we will update it accordingly.

Right to Erasure – Under GDPR, you have the option for all records of your personal information held by us to be erased. There are however, a number of exemptions to this right, given that we may have legal or contractual rights to retain your personal information. If, however it is felt that we hold information about you which is no longer necessary for the initial purpose it was collected, your right to erasure will be granted.

Right to Data Portability - GDPR provides you with the opportunity for your personal information to be provided back to you in a portable format. This means that you can transfer your data to a different provider without the need for you to provide it again to them.

Right to Withdraw Consent – If for any reason, you wish to withdraw consent to prevent us from contacting you, either entirely, or via certain methods, this right can be used. This simply means that we will update your contact preferences within our systems.

Right to be Informed – This right encompasses the need for transparency over how we use your data and is the intention for this entire document. It ensures that we supply appropriate notification about our processing activities and that they are concise, transparent, and easily accessible, written in clear, plain language and free of charge.

Right to Restrict Processing – This allows you the opportunity to let us hold your data but not process it for marketing purposes. If you request this right to be actioned, we will amend your preferences on our database accordingly.

Right to Object – Under GDPR you can object to processing based on legitimate interest or a task classified as being in public interest, direct marketing and processing for purposes of scientific/historical research and statistics.

If you do not want your personal data collected, please do not submit it to us. Some information provided may be legally or contractually required and therefore, if not provided, will limit the services that we are able to provide.

 

 

DO YOU SHARE MY DATA WITH ANY THIRD PARTIES?

 

We keep your data inside Thurlow Nunn and use it to give you services or to do our best to improve your experience with us.

We only share your data where we have a legitimate reason to do so, where there is a statutory requirement or contractual need, where you ask us or give us your permission, or to give you a service you have specifically asked for, such as:

  • An extended warranty
  • A financial agreement you have signed up to when purchasing a vehicle
  • Becoming a member of a service plan
  • Registering as a service club member
  • Registering RAC cover

If we do share your data outside of Thurlow Nunn for any of the above, we will where required:

  • Make sure we have obtained your permission to do so
  • Share it in a secure way
  • Never allow these companies to use it to contact you with their own marketing.
  • We will only disclose your information if it is required or permitted by law (for example governing bodies and law enforcement agencies) or where we have a legitimate business purpose to do so. Examples include debt recovery, civil, criminal and private enforcement such as, but not limited to, moving traffic offences, parking tickets and emission zone enforcement

THIRD PARTY DATA SHARING We currently share data safely and securely with the following businesses to provide various services to our customers:

  • Vauxhall Motors, Pinley House, Coventry CV3 1ND
  • Peugeot Motor Company, Pinley House, Coventry CV3 1ND
  • Stellantis Financial Services UK Limited, CF15 7YT
  • Black Horse Finance, St William House, Tresillian Terrace, Cardiff, CF10 5BH
  • Financial Services Authority, ITC, Monarch Court, Emersons Green, Bristol, BS16 7FH
  • Experian The Sir John Peace Building, Experian Way, NG2 Business Park, Nottingham, NG80 1ZZ
  • Paint Protection Jewelultra Ltd, Diamondbrite House, Ewell Lane, West Farleigh, Maidstone, Kent, ME15 0NG
  • Cosmetic Warranty Car Care Plan, Jubilee House, 5 Mid Point Business Park, Thornbury, West Yorkshire BD3 7AG
  • Used Car Warranty administrator, TWG Services, Twenty Kingston Road, Staines upon Thames, Surrey TW18 4LG
  • Guaranteed Asset Protection Warranty - GardX Assure Ltd, Lake House, 2 Port Way, Port Solent, Portsmouth, PO6 4TY
  • Vehicle Aftercare Service Plans, EMaC House, Southmere Court. Crewe Business Park. Crewe. Cheshire. CW1 6GU
  • RAC Motoring Services, RAC House, Brockhurst Crescent, Walsall, WS5 4AW
  • Marketing Agency - MB Advertising & Marketing Ltd, MB House,248 Shepcote Lane, Sheffield S9 1TP
  • Marketing Agency – The Whole Caboodle, 1 Park View, Harrogate HG1 5LY
  • Marketing Services - Direct Affinity Europe, Suite 2D, Sutton House, Ashville Point, WA7 3FW


SOFTWARE COMPANIES THAT PROCESS DATA ON OUR BEHALF: We also use the following software providers that process data on our behalf but have no rights to use your data:

  • The Whole Caboodle, 1 Park View, Harrogate, HG1 5LY, United Kingdom
  • Eight Technology Ltd, Turing Building Babbage Way Exeter Science Park EX5 2FN United Kingdom
  • Pinewood Technology, 2960 Trident Court, Solihull Parkway, Birmingham Business Park, Birmingham B37 7YN

 

HOW CAN I TRUST YOU WITH MY DATA?

We have carried out stringent checks throughout our organisation to ensure that your data is handled in a secure manner. Some key security measures that Thurlow Nunn abides by include:

  • A strict clear desk policy which ensures that no personal documentation is ever left unattended as well as lockable cabinets throughout the organisation.
  • Password protected, security encrypted security systems, including firewalls and antivirus protection systems for additional security.
  • Internal data privacy audits.
  • Restricted use of portable IT methods including USB’s and laptops.
  • Internal Data Retention Policy and approved shredding contractor for disposal of protected documents.
  • GDPR security training for all our existing employees and mandated training for all new recruits.


We also promise to process your data lawfully, fairly and in a transparent manner:

  • We will check that consent is the most appropriate lawful basis for processing.
  • We will make the request for consent prominent and separate from our terms and conditions.
  • We will ask you to positively opt in.
  • We don’t use pre-ticked boxes, or any other type of consent by default.
  • We use clear, plain language that is easy to understand.
  • We specify why we want the data and what we’re going to do with it.
  • We have named our organisation and any third parties.
  • We tell you how you can withdraw your consent.
  • We ensure that you can refuse to consent without detriment.
  • We don’t make consent a precondition of our services to you.
  • We keep a record of when and how we obtained consent from you.
  • We regularly review consents to check that the relationship, the processing and the purposes have not changed.
  • We have processes in place to refresh consent.
  • We make it easy for you to withdraw your consent at any time, and publicise how to do so on our website.
  • We act on withdrawals of consent as soon as we can.


HOW DO YOU COLLECT DATA FROM ME?

We collect data on a vehicle sales order form about you, but don’t worry, you sign it so you will see exactly what data we are collecting about you.

We also collect data from you when you book your vehicle in to our Service Workshop, as we ask you for your name, your address, a contact number, an email and the registration number of your vehicle. You sign this too so again, you will see exactly what data we are collecting about you.

Sometimes you provide some data yourself. For instance, when sending us an email enquiry, we receive your email address.

If you visit our website, our web provider collects some data automatically, like your IP address, what browser and device you are using and your unique identifier. They also know what webpage directed you to Thurlow Nunn by looking at information from your browser.

 

ALL ABOUT OUR COOKIES

  • We want you to know that on the Thurlow Nunn website, cookies record information about your online preferences and allow us to tailor our website to your interests.
  • A cookie is a small amount of data, which often includes a unique identifier that is sent to your computer, tablet or mobile phone - all referred to as a 'device'.
  • Each website can send its own cookie to your web browser if your browsers’ preferences allow it. Many websites do this whenever a user visits their website in order to track online traffic flows.
  • Similar technology is also often used within emails to understand whether the email has been read or if any links have been clicked.
  • When visiting the Thurlow Nunn website, if you continue without changing your settings, we will assume that you are happy to receive all the cookies on the Thurlow Nunn website. However, please remember that you can change your cookie settings at any time.

 

IS THERE ANYTHING ELSE I NEED TO KNOW ABOUT MY PRIVACY?

We would like you to know about our CCTV

  • We have CCTV at our Dealerships in order to:
  • prevent, deter and detect crime
  • apprehend and prosecute offenders, and provide evidence to take civil action in the courts
  • help provide a safer environment for our staff
  • protect public safety
  • help to provide improved customer service
  • monitor operational and safety related incidents
  • assist with the verification of claims


We would like you to know about our Call Recording

We have Telephone Call recording at our Dealerships to:

  • use during staff training sessions
  • provide improved customer service
  • monitor operational performance
  • assist with the verification of conversations held


We would like you to know that we welcome your views too

Finally, if there is anything you think we can explain better or any questions you feel we have failed to answer regarding data privacy, we would welcome your views.

There are two ways in which you can do this:

1. You can email us at [email protected]

2. You can write to us at Data Privacy, Thurlow Nunn, 11 Campbells Meadow, King's Lynn PE30 4YN

 

WILL I BE CONTACTED FOR MARKETING PURPOSES?

We will only send you emails, SMS messages or contact you by phone or post where you have agreed to this. We may personalise the message content based upon any information you have provided to us.

However, if you fall out of love with us at any stage, you can change your marketing preferences with us in three ways:

1. You can email us at [email protected]

2. You can write to us at Data Privacy, Thurlow Nunn, 11 Campbells Meadow, King's Lynn PE30 4YN

3. Or you can visit www.thurlownunn.co.uk and manage your data preferences on our website

If you have signed up to the Vauxhall Owners Centre and you have provided consent for marketing purposes, you may receive something in the post from Vauxhall showing our address. Vauxhall do this for all their customers to highlight the nearest dealership to your postcode. Some customers think the material comes from us here at Thurlow Nunn, whereas it actually comes from the Manufacturer. Therefore, if you do want to stop all marketing material associated with Vauxhall, it is always best to check your preferences with them via the Vauxhall Owners Centre. www.my.vauxhall.co.uk

 

HOW LONG WILL WE RETAIN YOUR DATA?

In most situations we will only retain your data for up to 7 years after our last contact with you. There may be some circumstances where we are required to retain data for longer. This may be where there is a statutory requirement for us to do so or where we have a legitimate reason in doing so. In view of the claims being brought against manufacturers for diesel vehicle emissions, we are retaining customer records for vehicles purchased from us that fall within the scope of a potential claim until further notice. We are reviewing our position on the retention of these records on a regular basis and will update this privacy notice to reflect any change in retention time.

VAUXHALL DATA PRIVACY STATEMENT

To read the Vauxhall Privacy Policy please follow the following link: http://www.vauxhall.co.uk/tools/privacy.html