//Privacy Policy

PERSONAL DATA

PROCESSING PERSONAL INFORMATION

We use your personal information in relation to our business activities. In particular, we may use your personal information in the following ways:

1. To respond to your query regarding the possible purchase of goods or services
2. To carry out our obligations arising from any contract between you and us including the purchase of vehicles and provision of services, and to respond to query from you regarding those such contract
3. To manage and administer the relationship between you and us
4. To obtain feedback from you regarding us
5. To provide you with reminders regarding your vehicle including, for example, when your vehicle is due to have a service or MOT undertaken
6. To provide you with information about vehicles, services, promotions and offers that may be of interest to you

OUR LAWFUL BASIS FOR PROCESSING PERSONAL DATA

At E S Hartley Limited we may lawfully process your personal data under one of three options:

Art. 6 (1) (a) Consent: In circumstances where you have provided us with a freely given, informed and specific choice to allow E S Hartley Ltd Limited to process your data, consent will be the lawful basis under which we process your data.

Art. 6 (1) (b) Contract: If you have entered or are in the process of entering into a contract with E S Hartley Limited, your personal data may be processed if it is necessary for performance of the contract or is in order to take steps at your request prior to entering into a contract.

Art. 6 (1) (f) Legitimate interest: If you have completed or negotiated a sale with E S Hartley Limited, you may have your personal data processed for the purposes of the legitimate interests pursued by E S Hartley Limited or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data.

To balance your fundamental rights and freedoms with E S Hartley Limited's commercial interests, you will be informed that you may receive marketing communications for similar products and services at the point enquiry or purchase and will be given the ability to opt-out.

SHARING PERSONAL DATA

We may disclose your personal information to third parties in connection with our business activities, including in the following circumstances:

1. To third parties that provide services to us such as marketing activities
2. To external organisations for the purposes of detecting and preventing fraud and criminal activities
3. To third party finance companies for the purposes of them providing you with finance. These organisations may carry out credit checks and may disclose your data to credit reference agencies for that purpose
4. To third party providers of insurance products if you take up the option of purchasing one of those products
5. We may pass your personal information to third parties if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply the terms of any agreements we have with or otherwise concerning you or to protect our rights, property or safety or those of our customers, employees or other third parties
6. We may contact you as advised by our suppliers (a full listing can be found via the link at the foot of this notice) to ensure the ongoing safety and care of your vehicle and any policies are maintained, and the replacement of your vehicle and car care related products

We will register your vehicle keeper details and will cross check your data with DVLA to ensure accurate and timely communications can be made.

SUPPLIERS

In the course of making an enquiry on our website, buying a car from E S Hartley Limited or applying for finance through us, we may share your information with the following suppliers.

OUR FINANCE PROVIDERS:

Black Horse

Evolution Funding

CA Auto Finance

OUR WARRANTY PROVIDERS:

Warranties2000

The Motoring Organisation (TMO)

OUR SERVICE PROVIDERS:

SmarTrack - Vehicle Tracking

Scorpion Automotive - Vehicle Tracking

OUR MARKETING PROVIDERS:

Dragon2000- Dealer Management System

Yell - Marketing

Anvil Consulting - Marketing

Azizi Media - Lead Management

ADMINISTRATION:

DVLA

YOUR RIGHTS

Under the Data Protection Legislation, you have several rights available to you in respect of your personal information. These are the rights to:

1. Request copies of your data
2. Rectification of your data
3. Erasure of your data
4. Object to us or restrict the processing of your data
5. Where our systems allow, give electronic access to copies of your data in a digital format

Except as required by law, we will not use or disclose your personal information for any purpose for which you have not given us your consent or have requested to no longer be communicated to on a legitimate interest basis. If you object or ask to restrict the processing of your data, you agree that despite this we may continue to use the personal information previously provided to us to the extent that we are contractually obligated to do so and to the extent necessary to enforce any contractual obligations you may have, for example a finance agreement.

To learn more or to exercise any of these rights you can contact our Data Protection Officer whose contact details are provided at the bottom of this page.

DATA STORAGE

We retain your personal information for seven years from the point of purchasing a vehicle from us, or two years from the point of last communication. We take steps to ensure any business we work with has security protocols and policies in place to manage and record your data privacy and preferences correctly and that your data is stored securely. The security of your data is paramount. Documentation can be supplied on request from our Data Protection Officer, details of whom can be found below.

E S Hartley Limited reserves the right to update or amend this data privacy notice in line with customer feedback or updates in legislation and it will be published at: https://www.eshartleygroup.co.uk/privacy

Data Protection Officer

Name: General Manager

Address: E S Hartley Limited, Ings, Kendal, Cumbria, LA8 9PY

Email: AndrewPilkington@eshartleygroup.co.uk

If we are unable to resolve any issues you raise within 30 days you have you have the right to complain to the Information Commissioners Office