Please read this document carefully as it sets out important information about how we look after the personal data we collect when you visit our website or otherwise interact with us (such as when you make an enquiry or purchase products from us) and also explains important information about your privacy rights. You should also read this Privacy Policy in conjunction with particular information which we may also provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. 

OUR ROLE AS CONTROLLER

Peter Roberts Caravans Ltd (PRC) is the controller for the purpose of the data protection legislation which means that it is the entity responsible for your personal data.  In this Privacy Policy, PRC is referred to as "we", "us" or "our".

We have appointed a data protection manager who is responsible for overseeing questions in relation to this Privacy Policy and any data protection enquiries which you may have. If you have any questions about this Privacy Policy or is you wish to exercise any of your rights, please contact the us using the details set out below. 

Peter Roberts Caravans Ltd

Address: Steps Industrial Park, Unit 5 Magdale, Honley, Huddersfield West Yorkshire HD9 6RA

Email address: office@peterrobertscaravans.co.uk
Telephone number: 01484 662 774

CHANGES TO THIS POLICY AND CHANGES TO YOUR DATA 

We keep this Privacy Policy under regular review and it may change from time to time.  Please revisit this page from time to time to make sure that you are kept up to date with how we use personal information.   

It is important that the personal data we hold about you is accurate and current so please keep us updated if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

This website may include links to third-party websites and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you.  We do not control such third-party websites and are not responsible for their privacy statements.  When you leave our website, we encourage you to read the privacy policy of the websites that you visit.

THE TYPES OF DATA WE COLLECT ABOUT YOU

Personal data includes any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you.  That data is categorised into the following groups:

• Identity Data includes first name, last name, former names, username or similar identifier and title, and in the case of hire arrangements will also include identification evidence such as passport, driving licence, utility bills or similar.
  

• Contact Data includes address information, email address and telephone numbers.
  

• Financial Data includes bank account, payment card information and information which relates to your finances where you arrange a finance deal for your purchase.
  

• Transaction Data includes details about payments to and from you and details of vehicles you have purchased or hired from us, as well as the information required in connection with that purchase or hire including driving licence details, logbook details, CRIS and VIN numbers, insurance information and national insurance numbers (hire only). Where relevant, transaction data may involve us holding data about offences and convictions such as an endorsement on a driving licence. This may also include details about your party in the case of a hire such as the number of people in your party.
  

• Technical Data includes internet protocol (IP) address, login data, browser type and version, 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.
  

• Profile Data includes information about purchases or reservations made by you, your interests, preferences, feedback and any feedback you might provide to us as well as information about how you use our website, vehicles and services.
  

• Employment Data includes data about employment status including details of salary and benefits. It may also include information about current or former employment. Employment Data is relevant when you apply for a role with us.
  

• Marketing and Communications Data includes your preferences in receiving marketing from us, any third parties we may work with from time to time and your communication preferences.
  

From time to time, we may also collect, use and share Aggregated Data such as statistical or demographic data. Aggregated Data may be collated from personal data but is not itself, personal information. An example of Aggregated Data use would be where we establish where visitors to our website are based.

Please note that we do not routinely collect any Special Categories of Personal Data. This includes information about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health information and genetic and biometric data.  The exception to this is where it is relevant to an employment role which you may apply to us for. 

We may however collect information in connection with offences which are relevant to our transaction with you.  This includes details of any motoring offences (such as endorsements on a driving licence).

This website is not intended for children and we do not knowingly collect data relating to minors.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you or with a view to entering into such a contract, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with a vehicle or hire  service). In this case, we may have to cancel a reservation, sale or hire with us.

HOW WE COLLECT PERSONAL DATA 

We collect personal data in a number of different ways, including: 

• Through direct interactions. This includes when you contact us by post, phone, text, email or in person when you visit our showroom. These contacts include when you make an enquiry with us, buy from us and transact with us, ask for marketing or similar information from us, respond to a survey or give us feedback or contact us for any other reason. As a minimum, this will involve the collection of Identity Data and Contact Data so that we can interact with you.

This would also include the provision of Employment Data to us if you apply for a position with us, for example. 

• By using automated technologies or interactions. As you interact with our website or other systems we make available, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data if you visit other websites using our cookies. Please see our Cookies Policy for further details.
  

• From third parties or publicly available sources. This may include where we receive personal data from various third parties such as from analytics providers, advertising and our service providers or professional organisations who we may work alongside (such as our insurers). The type of data we receive from these parties will vary according to the particular relationship we have with you, but it is possible that personal data is provided to us by such third party organisations.
  

Where you apply for a role with us, we may also collect information from referees or previous employers but we will only do so with your consent. 

HOW WE USE YOUR PERSONAL DATA

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

• Where we need to perform a contract we are about to enter into or have entered into with you.

• 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 including for marketing and promotional purposes.

• Where we need to comply with a legal obligation.

• Where you have given your consent although we do not routinely rely on consent as a legal basis for processing your personal data. This usually only applies where we will usually get your consent before processing any special category personal data or personal data relating to driving offences.
  

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

In accordance with the requirements of the data protection legislation, we have identified the basis which we rely on in order to use personal data for the various purposes for which we use and collect personal data.  We set out below, the ways in which we use personal data, and which of the legal bases we rely on to do so for each of those purposes. We have also identified what our legitimate interests are where appropriate.  We may use your personal data for more than one lawful basis depending on the specific circumstances. 

Purpose 1:  To provide vehicles and services including for vehicle hire

This covers all uses of personal data which are necessary for a vehicle sale or hire as the case may be. This includes dealing with administration of any contract or reservation which you have with us and includes the use of personal data to deal with reservations/orders, payments and collection and delivery arrangements.  It also includes as relevant for sale, number plate arrangements and warranty administration.  We may also process personal data for identity check purposes and DVLA driver checks where relevant and for insurance purposes in connection with vehicle hire as well as for sending you reminders and general updates for the proper administration of our arrangement with you.  

Types of Personal Data 

The types of personal data used for this purpose will usually include Identity Data, Contact Data, Financial Data and Transaction Data. 

Lawful Basis for Processing 

The use of personal data for this purpose is in our legitimate interests to ensure that the vehicles and services as relevant, are supplied to our customer, to deal with the administration of invoices, to ensure that we are paid and to deal with any queries we might receive relating to our goods, services and business.  It is also in our legitimate interests to communicate with you as a customer or potential customer and ensure that we administer accounts properly for the operation of our business. 

In many instances, data use for this purpose is also necessary for the performance of our sales or hire contract with you or for the purpose of entering into such a contract. 
 

Purpose 2: Marketing  

This includes communicating with you for the purposes of the promotion of our business and sending details about the company and the vehicles and services which we make available.   This includes sending newsletter and other marketing literature which we may make available from time to time and for events and promotions which we may run.  It also includes sending information about our vehicles and services such as brochures and catalogue information. 

Types of Personal Data 

We usually use Identity Data and Contact Data for this purpose as well as Marketing and Communications Data.  This purpose may also involve the use of Technical Data and Profile Data.

Lawful Basis for Processing 

It is in our legitimate interests to use personal data for these purposes for the marketing and promotion of our business and the vehicles and services which we offer, and for developing our profile, understanding our customer base and inform our business strategy. 

Purpose 3: After sales and customer care 

This includes using personal data to deal with any after sales issues such as follow up enquiries, dealing with problems, warranty issues and any other questions which may arise following a sale or hire.  It may also include using personal data in accordance with our complaints process.  We may also from time to time, request feedback such as if we undertake a feedback survey or similar as part of our approach to customer care.

Types of Personal Data 

This usually includes Identity Data, Contact Data, Financial Data and Transaction Data.

Lawful Basis for Processing 

The use of personal data for this purpose is in our legitimate interests to ensure that any after sales queries or other issues are appropriately dealt with and to ensure customer care and after sales/hire services.   

The use of personal data for this purpose may also be necessary for the performance of our sales contract with you such as where we deal with an after-sales warranty issue or similar.

Purpose 4: Website administration 

This covers the use of personal data for the administration of our website including troubleshooting, testing and maintenance.   It may also involve the use of personal data to ensure that our website content is presented in the most appropriate ways.  (You should also refer to our Cookies Policy about the use of cookies which we make on our website.)

Types of Personal Data 

The types of personal data used for this purpose will usually include Technical and Profile Data.  This may also on occasion, include Identity and Contact Data. 

Lawful Basis for Processing 

The use of data for this purpose is in our legitimate interests in order to ensure that we can operate our website properly, ensure that its features are properly used and in some cases, to undertake market research and for website and network security.  From time to time, we may also use this data for legal reasons to comply with a legal obligation which we are subject to. 

Purpose 5:  Employment applications 

If at any time, you send personal data to us for the purpose of applying for a role with us, we will process the personal data which if you send to us.  This includes if we advertise a position on our website, if we advertise in a different way or if you contact us speculatively. 

Types of Personal Data 

The types of personal data used for this purpose will include Identity Data, Contact Data and Employment Data.  We do not routinely request any special categories of personal data (see above) but we will process that kind of information if you decide to disclose it to us.

Lawful Basis for Processing 

We will use your personal data for this purpose as it is in our legitimate interests to review employment applications for recruitment purposes.   Where we process special category information for this purpose such as where we need to make particular arrangements for interview purposes, we will do so on the basis that we have your consent to do so which we will rely on by virtue of the disclosure of information to us by you.

Purpose 6: Dealing with suppliers, contractors and other third parties

This will apply where we need to administer arrangements with third party organisations including regulators.  It will include dealing with any external contractors who we may appoint from time to time to assist us for service fulfilment and operation of our business.  It includes our bankers, professional advisors such as accountants, auditors, bankers who deal with payments and other business service providers such as our IT service providers. 

Types of Personal Data 

The types of personal data used for this purpose will include Identity Data and Contact Data.  It may also include Financial Data and Transaction Data. 

Lawful Basis for Processing 

In some instances, we may need to pass personal information to our suppliers, for example to deal with financial arrangements such as payment processing.   This may be necessary for the performance of a contract which we have in place with you. 

It is also in our legitimate interests for the operation of our business to process personal data in this way for the proper appointment of our third party suppliers who assist us in the operation of our business and to source services from them. 

When we refer to our legitimate interests above, we refer to the interest we have in conducting and managing our business. We consider and balance any potential impacts on relevant individuals in assessing our legitimate interests. 

MARKETING

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need or what may be of interest to you. You may receive marketing communications from us if you have requested information from us or purchased or hired vehicles or services from us or made enquiries with us and you have not opted out of receiving that marketing.

We will not share your personal data with any third party for marketing purposes.

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you by contacting us at any time.

COOKIES

Our website uses cookies and you can find out more information in our Cookies Policy, including information about how to change your cookie settings and how to refuse the use of cookies.  Our Cookies Policy can be found here.

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 you require an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above or where this is required or permitted by law.

DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with third parties for the different data usage purposes referred to above.  This includes sharing data with our suppliers such as our IT service third parties, administrative service providers, delivery service providers, installers and contractors and any professionals who we may use from time to time such as insurers, bankers and accountants and where relevant to regulators and other authorities. 

We require all third parties 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.

In addition, we may disclose information about you to the extent that we are required to do so by law or for the purpose of legal proceedings or prospective legal proceedings, in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk) and where we may otherwise do so in accordance with applicable data protection legislation.

We do not routinely transfer your personal data outside the UK. If on any occasion we do transfer your personal data out of the UK such as in connection with an overseas hire, we ensure a similar degree of protection is afforded to it by ensuring that we put in place particular and approved contract provisions which give personal data a comparable level of protection as it has in the UK.

DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. We require that contractors only process your personal data on our instructions. 

We also have procedures in place to deal with any personal data breach incidents. These vary according to the nature of the data and matters such as risk assessments but by way of example only, some of the measure we take include restricted data access including restricted access to servers (including remote access to appointed IT consultants only), restrictions on copying any databases is limited to specified individuals and passwords are changed regularly. 

DATA RETENTION

We will retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, contractual, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or claim or for insurance purposes. 

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 applicable legal, regulatory, tax, accounting or other requirements.

For some categories of information, in particular where we have entered into a contract with you as a customer, we may keep the data for six years after a relevant relationship comes to an end.  This period usually also applies where we retain data for tax reasons. 

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for market research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Where we use data for marketing purposes, we will stop using the data for that purpose if you request us to do so (allowing a reasonable period of time for us to update our system). 

YOUR LEGAL RIGHTS

In some circumstances, you have rights under data protection laws in relation to your personal data.   An explanation of these is provided below.   You have the right to: 

Request access to your personal data (commonly known as a data subject access request). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. 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. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your data unlawfully or where we are required to erase your personal data to comply with local law.  Note however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data's accuracy.

• Where our use of the data is unlawful but you do not want us to erase it.

• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you and in many instances will not be relevant to us.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. Please refer above to the lawful bases which we rely on for the processing of personal data – in most instances, we do not rely on consent in any event but this does not affect your right to object to the use of personal data for marketing purposes. 

If you wish to exercise any of the rights set out above, please contact us using the details provided. 

DEALING WITH A REQUEST

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could 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 that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

OTHER RIGHTS 

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so we would ask you to please contact us in the first instance .