This policy applies to the processing of customer personal data by the CCR Motor Co Ltd (referred to as “CCR “or “we”). The purpose of this policy is to provide our current, former and potential customers (jointly referred to as “customers” or you) with a general understanding of:
- The circumstances under which we collect and process your personal data;
- The types of personal data we collect;
- The reasons for collecting your personal data; and
- How we handle your personal data.
The processing of your personal data forms an important part of our provision of products and services to you. We appreciate the trust you place in us when providing us with your personal data, and consider your privacy an essential part of the services we offer. In order to safeguard your personal data while increasing the customer value and offering enhanced and safer driving experiences, we adhere to the following five general principles.
Freedom of Choice
Your personal data belongs to you. We strive not to make any assumptions regarding your privacy preferences and aim to design our services so that you can choose whether to share your personal data with us.
Balance of Interests
Where the processing of your personal data is necessary for the pursuit of a legitimate interest, and where this interest outweighs the need to protect your privacy, we may process certain personal data without obtaining your express consent. For more information, see the “Consent” section below.
We will assess whether such a legitimate interest exists based on the potential benefits to (including the safety of) our customers and the general public.
CCR Motor Co Ltd endeavours to only process customer personal data that is adequate, relevant and not excessive in relation to the purpose for which it has been collected.
We aim to anonymize your personal data when a function or service can be achieved with anonymized data. If we combine anonymized or non-personal data with your personal data, it will be treated as personal data for as long as it remains combined.
On request, CCR Motor Co Ltd will provide customers with further information regarding our processing of your personal data, which may include excerpts from internal directives and guidelines.
It is CCR’s policy to comply with the applicable laws, rules and regulations governing privacy and data protection in each and every country where we operate. Where necessary, we will adjust our processing of your personal data as described in this policy to ensure legal compliance.
The following terms, used throughout this policy, have the meanings set out in EU Directive 95/46/EC on the protection of individuals with regard to the processing of personal data and on the free movement of such data. Accordingly:
“Data controller” means the natural or legal person, public authority, agency or any other body which alone or jointly with others determines the purposes and means of the processing of personal data;
“Data processor” means a natural or legal person, public authority, agency or any other body which processes personal data on behalf of the controller;
“Personal data” means any information relating to an identified or identifiable natural person ('data subject'); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity;
“Processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction; and
“Sensitive personal data” means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, and the processing of data concerning health or sex life.
You may provide us with information about you or your vehicle when utilising CCR’s services in or outside a vehicle or in other contacts with CCR, for example through our websites or customer centres (in this context, please note that phone calls may be recorded for quality assurance purposes). We may also obtain such data from our authorised dealers and repairers and other third parties. Such data (“Customer-provided personal data”) may include:
- Your contact information (name, address, telephone number, email address, etc.);
- Demographic information (age, marital status, household composition, etc.);
- Vehicle information (vehicle identification number (VIN), model, date of purchase, service history, etc.);
- Data pertaining to your purchase and use of our products and services (customer preferences and settings, purchase history, etc.).
- Your vehicle will also automatically collect data relating to the vehicle and its surroundings, primarily of a technical nature and not directly related to you as a person. Such data (“Vehicle-recorded data”) is typically connected to the vehicle identification number (VIN) of the vehicle and may therefore be traceable to you. Vehicle-recorded data may include:
- System functionality status (of the engine, throttle, steering, and brakes, etc.);
- Location data (the position of the vehicle in case of an accident, etc.); and
- Surroundings data (temperature outside the vehicle, images, etc.).
Information about certain Vehicle-recorded data is also included in the owner’s manual.
We are particularly careful and apply additional measures if and when collecting and processing sensitive personal data, as required by applicable law. To the extent personal identification numbers and credit card numbers are stored by CCR, such information is also considered sensitive. For avoidance of doubt, it is noted that applicable law may require other kind of data to likewise be treated as sensitive personal data. Applicable law may also limit the possibility to process location data in certain countries.
Where reasonably practical or as required by applicable law, we will, in collecting or registering your personal data, provide you with (i) specific information as to the purposes of the processing of your personal data, (ii) the identity of the data controller, (iii) the identities of any third parties to whom the data may be disclosed and (iv) other information which may be necessary to ensure that you are able to safeguard your rights.
Where reasonably practical or as required by applicable law, we will obtain your consent prior to collecting or using your personal data. The request for your consent will be clear and provide you with a reasonable basis with which to make your decision. Your consent could always be revoked, for example by terminating a particular service or contacting CCR at the address indicated in the “Information and Access” section below.
The collection and use of Vehicle-recorded data may be necessary in order for (i) technicians to diagnose and rectify faults in vehicles during the service and maintenance of vehicles, (ii) managing CCR’s warranty undertakings and (iii) fulfilment of legal requirements.
When collecting or using Vehicle-recorded data for these purposes, and for similar legitimate interests pursued by CCR, we will generally not seek your consent unless this is deemed necessary in the individual case or required by applicable law.
Third Party Applications
You may be able to access applications and other services connected to a vehicle but provided by a third party, which, for example, may require transfer of location data and other Vehicle-recorded data to the third party. CCR is not responsible for the collection or use of personal data in third party applications or services, and recommends that you carefully review the applicable terms and conditions of (and any privacy statement related to) such applications or services prior to use. If you have questions concerning a certain third party’s use of your personal data, please contact the third party directly. CCR will however carry out necessary due diligence when taking out contracts with third parties to ensure to the best of our ability that they comply with data protection law.
Full details of all third parties can be found in the CCR Data Inventory published on our website.
The personal data which CCR Motor Co Ltd collects about you and the vehicle will be used:
- To provide you with products and services, including to verify your eligibility for certain purchases and services as well
- To inform you of updates to, or changes in, our products and services, including but not limited to changes to our terms and conditions and policies;
- To inform you of new products, services and events;
- To provide vehicle support and services (warranty service, recall information, etc.);
- For product development purposes, for example to improve vehicle performance, quality and safety;
- To evaluate and improve our offering to and communication with customers; and
- To comply with legal requirements.
For most processing acts, you are able to opt out of our use of your personal data by updating your preferences, terminating a particular service, revoking your consent to the processing by contacting CCR at the address indicated in the “Information and Access” section below or as otherwise instructed by us. However, and unless otherwise follows from applicable law, you may generally not opt out of the processing of your personal data:
- In relation to certain acts of collection and further processing of your Vehicle-recorded data (see the “Consent” section above);
- Which we perform in order to send you important notices, such as changes to our terms and conditions and policies or in case of product recalls; and
- Which we perform in order to comply with our legal obligations.
We will only retain your personal data for as long as it is necessary to fulfil the purposes outlined in this policy or the purposes of which you have otherwise been informed.
This means that once you have consented to our processing of your personal data, we will retain your data in accordance with the consent given and/or until you revoke your consent. If you have revoked your consent, we may nevertheless retain certain personal data for the period required in order for us to meet our legal obligations and defend ourselves in legal disputes. If we have not obtained your consent to the processing, the data will only be retained for as long as such a period of time as permitted by law.
Full details of retention periods for specific records can be found in the CCR Data Inventory published on our website.
Where we process your personal data, we strive to ensure that it is accurate and up-to-date. We will seek to erase or rectify personal data that is inaccurate or incomplete. For more information regarding your right to ensure the accuracy of your personal data held by us, please see the “Information and Access” section below.
Information and Access
As stated in the “Notice” section above, we may provide you with specific information concerning our processing of your personal data when collecting or registering such data.
Once per year you have the right to request, and receive free of charge, information on (i) what personal data relating to you we process, (ii) where the personal data is collected, (iii) the purpose of the processing, and (iv),with which recipients or categories of recipients the personal data is shared. Requests for such information must be made in writing and be personally signed by you, and include information on name, address and, preferably, your e-mail address. You also have the right to request that we rectify any incorrect information we hold for you, the right to request that we erase data held on you (please note exemptions may apply under the GDPR or for legal purposes), the right to data portability and the right to restrict the processing of your information. Requests should be sent to: Data Protection Officer, CCR Motor Co Ltd, 1 Vernon Court, Meteor Business Park, Cheltenham Road East, Staverton, GL2 9QG
Your requests will be dealt with in a prompt and proper manner. Requests to delete personal data will be subject to any applicable legal requirements. Where the applicable law provides for an administrative fee for complying with such a request, such a fee may be charged by CCR Motor Co Ltd.
CCR Motor Co Ltd strives to implement appropriate technical and organisational measures in order to protect your personal data against accidental or unlawful destruction, accidental loss or alteration, unauthorised disclosure or access and any other unlawful forms of processing. We aim to ensure that the level of security and the measures adopted to protect your personal data are appropriate for the risks presented by the nature and use of your personal data.
Data Processing on our Behalf
We restrict access to your personal data to CCR employees and suppliers who need to use the information in order to process it on our behalf, and who are contractually required to keep your personal data secure and confidential. We aim to choose the option for data processing services that best safeguards the integrity of your personal data towards any third party.
We will not sell or trade your personal data with third parties unless we have your consent to do so. We will not share your personal data with third parties for their marketing purposes, unless we have received your consent for such disclosures. If you have provided such consent, but wish to stop receiving marketing materials from a third party, please contact that third party directly.
We may provide you with information regarding new products, services, events or similar marketing activities. If you wish to unsubscribe to a particular e-mail newsletter or similar communication, please follow the instructions in the relevant communication. You may contact your local CCR dealership to change previously submitted preferences.