COMPLETE CAR COSMETICS PRIVACY POLICY

1. INTRODUCTION

We are Complete Car Cosmetics limited, a company registered in England and Wales with company no. 06407849 and registered address at Unit 14 Ascot Business Park, Longbridge Lane, Derby, Derbyshire, England, DE24 8UJ (“CCC”, “we”, “our”, “us”). For the purposes of data protection law, we will be a controller of the personal information we hold about you. This means we make decisions about how and why your information is used, and have a legal duty to make sure that your rights are protected when we do so. This policy explains what personal information we collect when you visit www.completecarcosmetics.co.uk (our “Website”), or bring your vehicle in to see us in person. If you wish further detail about how our relationship with you works, please see our Terms and Conditions.

If you have any questions about our Privacy Policy, please contact us by writing to us at our registered address given above, telephoning us on 01332 757676 or contacting us via e-mail at info@completecarcosmetics.co.uk. You can also use the contact form on our Website.

2. THE INFORMATION WE COLLECT

We collect personal information about you in several ways, as discussed below:

Information You Give Us

If you contact us about a vehicle repair, a job or for any other reason, we will keep a record of that correspondence. If you have sent us photographs of the vehicle, we will also retain these – they may show your licence plate number, or include other identifying details e.g. nearby objects or photograph metadata can reveal where the picture was taken.

If we do any work on your vehicle, we will retain the following personal information about you in order to carry out the work, tell you when it is ready, take payment for it, and honour our lifetime warranty:

• your name and contact details;
• your payment information (though we will never store your card details);
• the make, model and licence plate of your vehicle;
• if the vehicle is owned by a company, the name of the company; and
• a description of the work we did.

CCTV Images of You

Our premises may be covered by CCTV cameras in order to discourage theft, vehicle tampering and to keep track of what happens to your vehicle whilst it is in our possession. We may therefore capture images of you when you come to drop off your vehicle or to reclaim it.

Sensitive Personal Information

We will not typically collect information that is particularly sensitive – that is, information relating to your race or ethnic origin, political opinion, religious or other similar beliefs, trade union membership, physical or mental health, sexual orientation or criminal records.

Technical data

When you visit our Website, we may collect technical data about the device you are using, including where available your IP address, operating system and browser type. This is used for system administration and to improve the look and feel of our website. See section 3 for more about the technical data we collect through cookies.

3. USE OF COOKIES

Cookies are small pieces of information that are stored on your browser on the hard-drive of your device.

We use the following types of cookies:

a. Strictly necessary cookies. These are cookies that are required for the operation of our Website.
b. Analytical/performance cookies. These cookies allow us to recognise and count the number of visitors and to see how visitors move around our Website. This helps us to improve the way the Website works, for example, by ensuring that users are finding what they are looking for easily.
c. Social Media Sharing Buttons. We do use sharing buttons in order to make it easier for you to follow our content via your social media pages. These buttons are third-party cookies which are placed onto your device when you visit our Website. Even without you clicking on the relevant sharing button, these sites are aware that you have visited our Website, and may use this information when building their profile of you, and deciding what advertisements you might like to see. You should check the respective policies of each of these social networks to see how exactly they use your personal information. This process does not involve us collecting or storing any of your personal information ourselves.

Google Analytics

Our Website uses Google Analytics for internal analysis of visitor behaviour and trends, to evaluate traffic flow (e.g. busiest times of day/week) and to assess the relative popularity of different parts of our Website. We use the information we collect to monitor the number of visitors to the different sections of our Website, and to help us make it more useful to visitors. We do not share individual data or track user behaviour after you have left our Website.

Any information collected will be used in accordance with our own privacy policy and Google’s privacy policy.

If you do not wish to participate, you can:

opt out of Google’s use of cookies through Google’s Ads Settings; or
refuse the use of cookies by downloading and installing the Google Analytics Opt-out Browser Add-on.

4. OTHER SITES

Our Website may contain links to other sites. These are outside of our control and are not covered by this Privacy Policy. If you access other sites using the links provided, the operators of these sites may collect information from you, which will be used by them in accordance with their own privacy policies, which may differ from ours.

5. HOW WE USE YOUR PERSONAL INFORMATION

We will only use your personal information when the law allows us to. Most commonly, we will use it in the following circumstances:

• where we need to perform a contract with you e.g. when you bring in a vehicle for repair;
• 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 (see the “Legitimate Interests” section below); or
• where we need to comply with a legal or regulatory obligation.

We do not sell, rent or trade email addresses to any third party for marketing purposes.

We may use personal information held about you in the following ways:

• to link your vehicle to you and to keep you updated as to the progress of a repair;
• to honour any warranty we have given you as to the quality, durability or longevity of a repair;
• to deal with your enquiries, comments or requests;
• to contact you via telephone or e-mail no more than once a year following your repair to offer to conduct a free annual inspection; and
• to send you an annual Christmas card.

If you wish to opt out of the annual inspection or Christmas card, you can do so by either contacting us directly, or clicking the appropriate link at the bottom of the e-mail we send you.

6. LEGITIMATE INTERESTS

We may rely on legitimate interests to process your personal information, provided that your interests do not override our own.

Where we rely on legitimate interests, these interests are:

1. to keep our records updated and to study how our Website and other services are used;
2. to administer and protect our business and web presence (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting);
3. to inform our marketing strategies; and
4. to grow our business.

7. KEEPING YOUR PERSONAL INFORMATION SAFE

We employ a variety of physical and technical measures to keep your personal information safe and to prevent unauthorised access to, use or disclosure of it. We control who has access to your data (using both physical and electronic means). Our staff receive data protection training and we have a set of detailed data protection procedures which they are required to follow when handling personal information.

8. STORAGE AND RETENTION

We typically store your personal information on servers located within the European Economic Area (“EEA”). However, if we need to transfer it outside of the EEA, We will take all steps reasonably necessary to ensure that any personal data transferred is treated securely and in accordance with applicable data protection laws.

How long we keep it

We collect and store personal information for purposes connected with our business. As such, we will only retain your personal information for as long as necessary for those purposes. We will retain personal information about the repairs we undertake for a period of 6 years, in order to be able to honour the warranty we have with you. We will retain all other personal information for a period of 6 years.

9. DISCLOSING YOUR PERSONAL INFORMATION

Except for as described in section 10 below, we will not disclose your personal information to a third party without your consent.

We may wish to take pictures of your vehicle for marketing purposes e.g. to showcase our craftsmanship, and we will ask your permission before we do so.

10. DISCLOSURES REQUIRED BY LAW

We are subject to the law like everyone else. We may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.

We also may need to retain and disclose certain personal information about you to regulatory authorities and to appropriate agencies to conduct anti-money laundering and trade sanction checks, or to assist with fraud prevention. We will disclose this information as is required by law.

11. ACCESS TO YOUR PERSONAL INFORMATION

We want you to remain in control of your personal information. Part of this is making sure you understand your legal rights, which are as follows:

• where your personal information is processed on the basis of consent, the right to withdraw that consent;
• the right to confirmation as to whether or not we are holding any of your personal information and, if we are, to obtain a copy of it;
• from 25 May 2018, the right to have certain data provided to you in a portable electronic format (where technically feasible);
• the right to have inaccurate personal information rectified;
• the right to object to your personal information being used for marketing or profiling, or on the basis of our or a third party’s legitimate interests;
• the right to restrict how your personal information is used; and
• the right to be forgotten, which allows you to have your personal information erased in certain circumstances (though this is not an absolute right and may not apply if we need to continue using it for a lawful reason).

If you would like further information about any of your rights or wish to exercise them, please contact us using the details given in section 1.

Please keep in mind that there are exceptions to the rights above and, though we will always try to respond to your satisfaction, there may be situations where we are unable to do so (for example, because the information no longer exists or there is an exception which applies to your request).

If you are not happy with our response, or you believe that your data protection or privacy rights have been infringed, you should contact the UK Information Commissioner’s Office, which oversees data protection compliance in the UK. Details of how to do this can be found at www.ico.org.uk.

12. UPDATING THIS POLICY

We may update this Policy at any time. When we do, we will post a notification on the main page of our Website and we will also revise the updated date at the bottom of this page. We encourage users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we hold.

This policy was last updated on 21 June 2018