PRIVACY POLICY

Updated 25th May 2019
JF&E Hadwin are committed to respecting and protecting your personal data whilst it is in our care. We collect your personal information because it helps us to understand your needs and guides the way in which we interact and communicate with you about our products and services both now and in the future. We have strict policies and procedures in place to protect your data when we acquire it, when we process it in order to provide you with the services you have requested or, where you have given us your permission to do so, to send you information that we think you’ll find interesting, and thereafter when we store your data on our secure servers.
Processing your data lawfully
We will normally process your data strictly in accordance with the EU General Data Protection Regulation (EU) 2016/679) (“GDPR”) under our chosen lawful reason of legitimate interests which means we will only use it for the purposes for which it was collected. For the purpose of the GDPR we are the data controller of information provided through our Site/locations.
Legitimate Interests
We will normally use and process your personal information as set out below where it is necessary for us to carry out activities for which it is in our legitimate interests as a business to do so.
1. To verify the accuracy of information that we hold about you and create a better understanding of you as a customer.
2. To respond to your enquiries and fulfil any requests you make to us.
3. To provide vehicle support and service activities.
4. To analyse, evaluate and improve our sales and service performance so that your visits and use of our website are more useful and enjoyable.
5. To send you marketing information from time to time after you have purchased a product or service from us or made a purchasing enquiry. We will only contact you with information about products or services which we feel are relevant to your needs and may be of interest to you. You have the right to object to us sending you this information at any time.
6. To contact you with targeted advertising delivered online through social media and other platforms operated by other companies, unless you object.
7. To identify and record when you have received, opened or engaged with our website or electronic communications. (Please see our cookie policy for more information).
8. For network and security purposes i.e. in order for us to take steps to protect your information against loss, damage, theft or unauthorized access.
9. To comply with a request from you in connection with the exercise of your rights.
10. To inform you of updates to our terms and conditions and policies.
Under some circumstances we may process your personal information under a different lawful reason:
Legal obligation
We may process your personal information to comply with our legal requirements (for example to register your car with the DVLA).
Vital Interest
Sometimes we will need to process your personal information to contact you if there is an urgent safety or product recall and we need to tell you about it.
Consent
We will only process your personal information to contact you with direct marketing material from time to time about promotions, events, products, services or information which we feel are relevant to your needs and may be of interest to you.
You can withdraw your consent at any time by contacting us on the details at the footer of this page.
Sharing your data with other companies
We may share your data with other group companies, our Franchise partner and other associate companies only within the UK to fulfil the requirements of your purchase or services both now and in the future. We may pass your data to an organisation who may contact you to assist in statistical analysis but will not divulge it to any other organisation unless we are obliged to disclose your data by law. You will be informed at point of sale as to who we will share your data with. This will depend on the actual product or service purchased.
We do not sell your information to third parties. However, we will from time to time disclose your information to our franchisors and third-party suppliers relevant to the products and services you have purchased so they may supply the relevant product or service to you.
We take steps to ensure that any third-party suppliers or franchisor who handle your information comply with data protection legislation and protect your information just as we do. We only disclose personal information that is necessary for them to provide the service they are undertaking for you. In some circumstances the third-party supplier will be the data controller of your personal information (for example a Finance Company).
How long will we keep your data?
Your data will be kept for the length of time specified by whichever current regulation applies to each category after which it will be deleted. We will restrict the length of time any sensitive personal data is held by us to that required for its initial use only. It will be deleted immediately thereafter.
We do not retain personal information for longer than is necessary.
If we have a relationship with you (e.g. you are a customer), we hold your personal information normally for 6 years from the date our relationship ends (10 years for product liability). We hold your personal information for this period to establish, bring or defend legal claims. Our relationship may end for a number of reasons including where the vehicle warranty expires or we have been made aware that you no longer drive that vehicle.
Where we have obtained your personal information following a request for information, test drive, brochure, quotation or any other information on any of our retailed products or services, we hold your personal information for a maximum of three years from the date we collect that information, unless during that period we form a relationship with you e.g. you purchase or lease a vehicle. We hold your personal information for this period to give us an opportunity to form a relationship with you.
The only exceptions to the periods mentioned above are where:
1. The law requires us to hold your personal information for a longer period or delete it sooner.
2. Where you have raised a complaint or concern regarding a product or service offered by us, in which case we will retain your information for a period of 6 years (10 years for Product liability) following the date of that complaint or query; or
3. You exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law.
How do we keep it secure?
We will minimise your data to eliminate any unnecessary duplication and we always ensure that the privacy of your information is paramount when designing new systems for data processing. Our staff are trained in data security, and our policies and procedures help them to understand what is required under their obligations to us, and their responsibilities under the Data Protection Act 2018 and other policy legislation.
Accessing your personal data which is held by us:
We are always happy to continue to tell you what personal information of yours we hold on an informal basis as we have always done in the past and to update it accordingly. However, under the General Data Protection Regulation you may formally ask to see what personal data of yours we hold by means of a Subject Access Request and have the formal rights of rectification and under some circumstances the rights to erasure, to restrict and object to the processing. You will also have the rights to information about any automatic processing. You may exercise these rights or ask any questions regarding our data protection policy by contacting the company secretary.
You have the right to complain to the UK regulatory body the Information Commissioners’ Office who you can find at https://ico.org.uk/concerns. Notwithstanding this, we welcome any input you care to give us in the course of our normal business transactions about changes to your personal data and we will incorporate them into our records straight away.
You have a number of rights in relation to your personal information under data protection law. In relation to most rights we will ask you for information to confirm your identity and, where applicable, to help us search for your personal information. Except in rare cases we will respond to you within 30 days after we have received any request (including any identification documents requested.) There will normally not be any charge for this.
You have the right to:
1. Ask for a copy of the information we hold about you.
2. Correct and update your information.
3. Withdraw your consent (where we rely on it).
4. Object to our use of your information (where we rely on our legitimate interests to use your personal information) provided we do not have any continuing lawful reason to continue to use and process the information. When we do rely on our legitimate interests to use your personal information for direct marketing, we will always comply with your right to object.
5. Erase your information (or restrict its use), provided we do not have any continuing lawful reason to continue to use and process that information.
6. Transfer your information in a structured data file (in a commonly used and machine-readable format), only where we rely on your consent to use and process your personal information.

Updates to this Privacy Policy
We will update this Privacy Policy from time to time to reflect changes in technology, law, our business operations or any other reason we determine is necessary or appropriate. When we make changes, we will update the “Effective Date” at the top of the Privacy Policy. We encourage you to check back periodically to review this Privacy Policy for any changes since your last visit. This will help ensure you better understand your relationship with us, including the ways we process your personal information.
If you have questions, comments or complaints about this Privacy Policy or our privacy practices or if you would like to exercise your rights and choices, please contact us at the addresses below:

Company Secretary
Ref: Data Protection
Lakeland Land Rover
Torver
Coniston
Cumbria
LA21 8BJ
United Kingdom
Telephone: 015394 41317
If you have any specific data protection concerns or a complaint, you can address it to our Data Protection Team at privacylakeland@gmail.com

If you are unhappy, you have the right to lodge a complaint with The Information Commissioner’s office whose contact details are:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone: 0303 123 1113
Email: casework@ico.org.uk
What about the Cookies?

“Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing a website. JF&E Hadwin uses cookies for several reasons:
1. To provide you with a more personal and interactive experience on our sites.
2. For statistical purposes to track how many users we have, and how often they visit our websites.
3. We use organisations to collect anonymous user information, so they can analyse how the website is being used and the number of visitors. To show you adverts that you may be interested in and to control the number of times you see them and measures the effectiveness of the ad campaign.

Cookie Policy

Cookies are small pieces of data that websites store on a device. Cookies can improve your browsing experience because they help websites remember preferences and understand how people use different features - most major websites use cookies. Cookies alone cannot be used to identify you.
A cookie will typically contain the name of the domain from which the cookie has come; the "lifetime" of the cookie; and a value, usually a randomly generated unique number.
Two types of cookies are used on this website:
• Session Cookies, which are temporary cookies that remain in the cookie file of your browser until you leave the site.
• Persistent Cookies, which remain in the cookie file of your browser for much longer (though how long will depend on the lifetime of the specific cookie).
How cookies are used on this site and what information is collected
Session Cookies are used:
• To allow you to carry information across pages of our site and avoid having to re-enter information.
• Within registration to allow you to access stored information.
Persistent Cookies are used:
• To help us recognise you as a unique visitor (using a number, you cannot be identified personally) when you return to our website.
• To allow us to tailor content or advertisements to match your preferred interests or to avoid showing you the same adverts repeatedly.
• To compile anonymous, aggregated statistics that allow us to understand how users use our site and to help us improve the structure of our website. We cannot identify you personally in this way.
To learn more about cookies in general and how to manage them, visit aboutcookies.org
Managing Cookies, Disabling, Enabling & Deleting Cookies

You have the ability to accept or decline cookies by modifying the settings in your browser. However, you may not be able to use all the interactive features of our site if cookies are disabled.
Other Information Collected During Your Visit to Our Site

Whenever you browse the www.lakeland-landrover.co.uk website, read pages, or download information, our computers automatically record certain information about your visit from the computer you use to access our site.
The information includes the following:
• This information does not identify you personally. It just tells us how many visitors come to our site and the types of computers they use. With this information, we can improve our site for all our visitors and make it more useful to you.
• The date and time you access our site.
• How many and which pages you visit during a 'session' on our site and how long you were on the site.
• Your Internet domain name (this might be your internet service provider such as BT, Sky, TalkTalk or your place of work) and the 'IP' address (this is a number assigned to your computer whenever you are surfing the web) which allows you to access our website.
• The Internet browser you use (e.g. Google Chrome, Microsoft Edge, Mozilla Firefox) and your computer's operating system (e.g. Windows 10, macOS).
• The site you were on before you linked to www.lakeland-landrover.co.uk (e.g. Google or Bing if you found us from a search engine).
Protection of Email Addresses

Your email address is only used for the purposes of replying to you unless you have given consent as detailed above.
Data Protection on Pixel Tags
We may use "pixel tags," which are small graphic files that allow us to monitor the use of our websites. A pixel tag can collect information such as the IP (Internet Protocol) address of the computer that downloaded the page on which the tag appears; the URL (Uniform Resource Locator) of the page on which the pixel tag appears; the time the page containing the pixel tag was viewed; the type of browser that fetched the pixel tag; and the identification number of any cookie on the computer previously placed by that server. When corresponding with you via HTML capable e-mail, we may use "format sensing" technology, which allows pixel tags to let us know whether you received and opened our e-mail.