About this policy
Greenhous Group Limited is committed to protecting your personal data. We collect personal information about people who come into contact with us for various reasons.
It also explains your privacy rights and how the law protects you including how we comply with the General Data Protection Regulation (“GDPR”) and other related legislation which relates to the use of personal data.
Additional information may be provided on particular pages of this website for example, on any specific pages where we collect personal data and you should also refer to those.
How to contact us
Contact: James Wilkes
Address: Greenhous Group Limited, Greenhous Village, Osbaston, Shropshire, TF6 6RA
Tel: 01743 265400
You have the right to make a complaint to the Information Commissioner’s Office (ICO) which is the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, like the opportunity to assist you with any concerns before you approach the ICO so please contact us in the first instance using the details above.
Your duty to inform us of changes
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.
The data we collect about you
Personal data means any information about an individual from which that person can be identified. It does not include data which has been anonymised such that a person’s identity is removed.
We may collect, use, store and transfer different kinds of personal data. The categories of personal data which we use include:
Identity and Contact Data such as names, addresses, telephone number and email address, or if you contact us in your capacity as a representative of the organisation for which you work, for example if you raise a trade enquiry, then we may take your job title and role.
Technical Data including internet protocol (IP) address, access times, your login data, browser type, 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. This may also include information about how you use our website and our products and services.
Profile Data such as username and password details you use to log in to our trade account or any other online services we might offer from time to time.
Driving Licence Data such as your driving licence number or a copy of your driving licence photocard.
Financial Data such as your bank account numbers, credit history, card and other relevant payment details.
Career Data such as your CV, references and career history information.
Marketing and Communications Data including preferences in receiving marketing from us and our selected partners, and your communication preferences.
Special Categories of Data including data concerning your health, such as any health issues or disabilities you may have.
How we collect your personal data
We collect personal data in a number of ways, for example, if you provide certain identity information when you complete the ‘Enquire Now’ form on our “About/Contact” page. We may also collect data via e-mail, telephone, if you write to us, or through face to face interactions, for example when you visit one of our showrooms. You might also provide information to us via social media or text message.
If you fail to provide personal data
Where we need to collect personal data by law, under the terms of a contract we have with you or where relevant, the organisation you represent or for another lawful reason and you fail to provide that data, we may not be able to fully perform our obligations in accordance with our contract, provide you with the information, vehicle, parts or service you require or otherwise properly deal with your request.
Purposes for which we use your personal data
We will only use your personal data when the law allows us to. The information below explains the purposes for which we use different categories of personal data and the legal basis or bases which we believe applies to those uses. We may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.
Administration of our website
We may process your identity and contact data, technical data and profile data, for the purposes of administering and operating this website. This includes troubleshooting, data analysis, testing, system maintenance and support. This helps us to continually improve this website and the products and services we can offer. We process your data in this way on the basis that this is necessary for our legitimate interests in managing, administering and improving this website and our services.
We may also process your identity and contact data if you are an account manager or similar, where we provide vehicles, parts and services to the organisation which you represent or otherwise on a repeat basis. We process your data in this way for example to maintain your details on our records for future communications, and on the basis that it is necessary for our legitimate interests to ensure that the vehicles and services we provide are properly managed. This will include using information for the proper administration of our business for example in ensuring that we receive payment or for providing after sales services. This kind of data use only applies to representatives of our corporate customers with whom we have a trade account and applies to personal data or relevant personnel within those organisations.
Pre-sales process and test driving
When you visit us in the showroom, we will collect and use your identity and contact data and driving licence data, for example if you want to book a test drive. We process your data in this way on the basis that it is necessary for our legitimate interests in ensuring the identity of and properly documenting information about, the users of our vehicles for test drive purposes and for demonstrating the vehicles to you.
Sales and financing
Depending on the vehicles, parts or services you may wish us to provide to you, we may process your identity and contact data and financial data. For example, if you wish to purchase a vehicle or service from us, we will process your data to process the sale, and to deal with any other matters such as administering payment from you, or the company which you represent. Similarly, if you purchase servicing or repair services from us, we will use contact data and financial data to contact you and to administer our invoices and collect payment. We process your data in this way on the basis that it is necessary to do so for the performance of the relevant contract that you have entered into with us.
Where relevant, we will also use contact data and financial data to arrange vehicle finance arrangements. This is usually done in our showroom and more information will be explained about the finance arrangements by the sales team. We process financial data in this way on the basis that it is necessary for the relevant contractual arrangements which you will enter into with the finance company and therefore this use of data forms part of that initial arrangement in you taking steps with a view to entering into a finance arrangement with the finance company. The finance company will have its own data polices and statements which you should read.
Other services – use of courtesy vehicles, services and MOT
Other services which we offer from time to time might include use of courtesy vehicles while we repair your vehicle. In order to allow use of our courtesy vehicles, we will collect your identity and contact data, and driving licence data. Much like if you take a test drive, we use this data as it is necessary for our legitimate interests in ensuring the identity of and properly documenting information about, the users of our courtesy vehicles.
We offer vehicle servicing, repairs and MOT in our garages and we will use identity and contact data and financial data in administering these services. We process your data in this way on the basis that it is necessary to do so for the performance of the relevant contract that you have entered into with us for these types of service arrangements.
In addition, we will use marketing and communications data in order to send you reminders about when servicing and MOTs are due. This forms part of our marketing activity and we do this on the basis that it is in our legitimate interests in promoting the services which we offer in our garages.
If you send us an enquiry, we may process your identity and contact data to respond to that enquiry. Similarly, if you send us your CV or other information enquiring about employment opportunities with us, we may process your career data in order to assess your suitability for any current or future employment opportunities with us. We process your data in these ways on the basis that it is necessary for our legitimate interests in the operation of our business in order to respond to and deal with new enquiries and to assess potential candidates for employment.
Competitions and promotions
From time to time, we may run prize competitions or promotions and when you wish to enter a competition or sign up for a promotion, we will also collect identity and contact data from you. We may also require your car registration information which for these purposes will form part of your marketing and communications data in that we use your data in this way to run the relevant competition or promotion. These activities form part of our marketing activity and we will use that information in that way on the basis that it is necessary for our legitimate interests in the operation of our business in order to promote our vehicles and other goods and services and to strengthen the Greenhous brands.
We take part in the Motability scheme which is a way of taking account of adaptations which may need to be made to vehicles for people with particular needs. This means that we may need to use special categories of data about health or disability requirements in order to put appropriate arrangements in place. This data is used alongside identity and contact data in order to put these arrangements in place. We only process special categories of data for such purposes to deal with the Motability scheme with your consent. Where the individual with particular needs is a child, we will obtain the consent of that child’s parent or guardian before processing their data, including special categories of data.
Marketing and promotions
From time to time we may use your data including identity and contact data, technical data and profile data and marketing and communications data, to contact you with our newsletter, information about competitions, prize promotions and other marketing activities about vehicles, services and other news.
You will receive marketing communications from us if you have provided your consent to be included on our marketing database or in some cases where you or the organisation which you represent has purchased vehicles, parts or services from us.
The type and content of marketing messages which subscribers receive, and if it may contain third party content, is outlined at the point of subscribing to receive these types of communication.
Email marketing messages may contain tracking beacons / tracked clickable links or similar server technologies in order to track subscriber activity within email marketing messages. Where used, such marketing messages may record a range of subscriber data relating to engagement, geographic, demographics and already stored subscriber data.
You can ask us to stop sending you marketing messages at any time in a number of ways. You can write to us at the address shown above, can email us, can log into “MyGreenhous” and select your relevant marketing preference or by following the opt-out links on any marketing message sent to you.
Collection of special categories of data
We might in some cases, collect special categories of data from you. We typically process this type of data in relation to our Motability scheme. We may need to collect this type of data from you to understand your vehicle needs. We may also collect this type of data where you require reasonable adjustments to be in place to allow you to attend a job interview with us, or to take a test drive. More information about this is provided above where we outline the purposes for which personal data is used.
We only process special categories of data in this way on the basis that you have given your express consent to us to process it. This data is usually collected in our showroom and we apply special security measures to restrict access to any special categories of data we collect and store.
Disclosure of data to other third parties
From time to time we might also appoint external third parties to help us with our business functions, for example, we use iVendi Limited to provide the Car Finance Checker facility on our website.
We also provide personal data to the vehicle manufacturers. This data is used by them so that they can do things such as administer any warranty arrangements and register you for any services that you might be eligible for or otherwise require. Please refer to their relevant privacy notices in addition to this notice.
We do not transfer personal data outside the EU.
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 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 also 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. If you would like further information about how we use personal data and the purpose which we might use it for, please contact us.
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.
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 retain finance purchase information including finance information relating to a Motability purchase for a period of seven years. We determine retention period for other data in line with the aforementioned criteria.
In some circumstances, we may anonymise personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further policy to you.
Security and standards
We take the issue of data privacy seriously. We have in place appropriate security measures in place which are aimed at helping to keep your data secure and we take reasonable steps to protect the confidentiality of the personal information supplied by you. Additionally, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know it. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We use security software which helps to keep our electronic records secure although this cannot be guaranteed and also have procedures in place to help keep our paper records secure. We also only disclose your details to those individuals within our organisation who have a need to know them for proper performance of their duties. Please note however, that the transmission of information via the internet can never be guaranteed as entirely secure and therefore any transmission of data is at your own risk.
From time to time, we provide links on our website to third party sites, such as links to our social media accounts. We do not control these third-party websites and are not responsible for their privacy policies. We cannot be responsible for any use of your personal data which arises from you disclosing personal data to third parties. We suggest that you review the policies and statements of such sites you visit carefully.
We require our service providers 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.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Those rights are listed below. Please contact us if you would like to exercise any of them. You have the right to:
Request access to your personal data (a “data subject access request”). This means you can receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of your personal data: 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. You can ask us to remove personal data where there is no good reason for us continuing to process it. You also have this right where you have successfully exercised your right to object to processing, where we may have processed your data unlawfully or where we are required to erase your personal data to comply with law. We may not always be able to comply with your request where there are particular legal reasons.
Object to processing of your personal data where we rely on a legitimate interest basis and if the processing impacts on your fundamental rights and freedoms. You can also object to direct marketing. In some cases, we may demonstrate that we have grounds to process your data which override your rights and freedoms.
Request restriction of processing. You can ask us to suspend the processing of your personal data: if you want us to establish the data’s accuracy; where our data use is unlawful but you do not want us to erase it; where you need us to hold the data even if we no longer need it, to establish, exercise or defend legal claims; or you have objected to use of data but we need to verify whether we have overriding legitimate grounds to use it.
Request a data transfer. We will provide to you, or your chosen third party, your personal data in a structured, commonly used, machine-readable format. This only applies to automated information which you provided consent for us to use or necessary to perform a contract with you.
Withdraw consent at any time where we rely on consent to process your personal data. This will not affect the lawfulness of processing carried out before you withdraw your consent.
Exercising your rights
You will not have to pay a fee to access your personal data (or to exercise any 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.
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 personal data is not disclosed to a person who has no right to receive it. We may also contact you to ask you to clarify your request to speed up our response.
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 which case we will keep you updated.