Winchester Motor Group is committed to protecting your privacy, and at the same time we endeavour to use any data we collect from you to provide the best possible service. This privacy policy (together with our terms of use https://www.winchestermotorgroup.co.uk/site/terms-conditions/ and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

This site is a UK based website and takes reasonable care to comply with requirements of the General Data Protection Regulation (Regulation (EU) 2016/679)with regard to the personal information you supply on this site.

For the purpose of the GDPR (the "Act"), the data controller is Winchester Motor Company Limited of 43 St Cross Street, Winchester, Hampshire SO23 9PU. Our nominated representative for the purpose of the Act is Dan Nilsson.

The site uses a security system that protects your information from unauthorised use. However, as no data transmissions over the Internet can be guaranteed to be 100% secure we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk.

Winchester Motor Group may occasionally modify this Privacy Policy, such variations becoming effective immediately upon posting to the website and by continuing to use the website, you will be deemed to accept any such variations.

Please note that Winchester Motor Group does provide links to other sites, which may not be governed by this Privacy Policy and you should view the particular privacy policies of those sites for further information.

Data collection

We will collect and process the following data about you:

Information you give us. This is information about you that you give us by filling in forms on our site https://www.winchestermotorgroup.co.uk , http://www.wmgleasing.co.uk ( together referred to as "our site") or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, subscribe to our service, search for a product, request marketing information, enter a competition, promotion or survey or other activities carried out on the site from time to time and when you report a problem with our site and when you engage with us to maintain and repair your vehicle or when you demonstrate or purchase a car from us. The information you give us may include your name, address, e-mail address and phone number, date of birth, gender, marital status, copy of driving licence, financial and credit card information, national insurance number, vehicle information (including registration number, VIN, service reminders, mileage and warranty repair information) the time and date you used our services, voice recordings, 'live chat' recordings and information within any correspondence with us. Please note that we record all telephone calls for the purposes of customer service standards and for use in the event of a dispute.

Information we collect about you. With regard to each of your visits to our site we will automatically collect the information set out below under the heading 'Cookie Policy'.

Information we receive from other sources. This is information we receive about you if you use any of the other websites we operate or the other services we provide or information which is provided directly from the car manufacturer or which we obtain from other third parties - such as AutoTrader magazine/website contact forms/ live chat, Facebook Marketplace, WhatCar magazine/website contact forms/ live chat, CarGurus magazine/website contact forms/ live chat, and CarWow website contact forms/ live chat. In some cases, we may receive information about you from the car manufacturers, Skoda, VW, Isuzu, GWM depending on your make of vehicle.

We do not need your consent to process personal data where we have a legitimate business interest in doing so and/or where we are processing your personal data (including sharing it with appropriate third parties) in order to fulfil a contractual obligation with you.

You submit information using these methods voluntarily and agree to the use of the personal data you provide as described in this policy. If you give us personal information about somebody else, such as a colleague, we will assume you have their permission to do so, and their data will also be subject to this policy.

If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you, or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).

Data collection via cookies

Winchester Motor Group may also collect personally identifying information using cookies. Sometimes cookies are required as part of this site’s operation. We will not collect personal data about you using cookies outside of this purpose. If you prefer not to allow the use of cookies, you can change the configuration of your browser to either warn you when you receive a cookie, or to automatically reject them. You may find, however, that disabling cookies means certain areas of the site do not function correctly.

Data usage

We use information held about you in the following ways:

Information you give to us. We will use this information:

to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us directly or through other third parties, such as Facebook Marketplace, AutoTrader. WhatCar, CarGurus or CarWow;

to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;

to provide you, or permit Skoda, VW, Isuzu, GWM (as appropriate) or other third parties to provide you, with information about your existing contract with us, your vehicle's warranty status, your vehicle's MOT, and goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data for non-marketing purposes, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to Skoda, VW, Isuzu, GWM as appropriate for marketing purposes, please tick the relevant box situated on the form on which we collect your data or log into our data portal and amend your privacy settings.We are required to draw your attention to SKODA's Privacy Notice at SKODA.co.uk/privacy but we also recommend that you read the privacy policy of the car manufacturer relevant to you;

to notify you about changes to our service;

to ensure that content from our site is presented in the most effective manner for you and for your computer.

Information we collect about you. We will use this information:

to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

to improve our site to ensure that content is presented in the most effective manner for you and for your computer;

to allow you to participate in interactive features of our service, when you choose to do so;

as part of our efforts to keep our site safe and secure;

to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;

to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

Information we receive from other sources. We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).



Disclosure of your information

We have the right and legitimate interest to share your personal information with:

Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 and which includes Garland Motors Limited and trading entities Garland Used Car Centre, Solent Used Cars;

Selected third parties including:

Skoda, (a trading name of Volkswagen Group United Kingdom Ltd), VW, Isuzu, Subaru, GWM (as appropriate) in order for such companies to process and maintain any warranty applicable to your vehicle and (where you have consented) to send you marketing materials where you have consented to receive them.Please see SKODA.co.uk/privacy in order to understand how SKODA protects your personal data and also https://www.isuzu.co.uk/legal/privacy to understand how Isuzu protects your personal data.Please also be aware that the Volkswagen Group United Kingdome Limited reviews our calls on a monthly basis to ensure that we are maintaining expected customer service standards;

business partners such as Autoprotect Limited (in connection with your warranty), Pinewood Limited (outsourced providers of our internal Pinnacle CRM systems), other software suppliers and providers of outsourced IT solutions (including but not limited to Vital Software Limited in respect of our supply of customer data to Isuzu as set out above; GForces in respect of our website, see below), car part suppliers, and sub-contractors for the performance of any contract we enter into with you;

advertisers and advertising networks that require the data to select and serve relevant adverts to you and others.We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience;

analytics and search engine providers that assist us in the improvement and optimisation of our site;

credit reference agencies and third party financial institutions for the purpose of assessing your credit score or organising finance for you where this is a condition of us entering into a contract with you.

MOT/Service Reminders to our customers – we use a third party to assist us such as Interactive Marketing LTD.

We will disclose your personal information to third parties:

In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.

If any company within the Winchester Motor Group or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Website Terms and Conditions of useand other agreements; or to protect the rights, property, or safety of the Winchester Motor Group, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.



G-Forces Web Management Limited ("GForces")

Our website is powered by GForces, our third party web services provider.GForces is committed to ensuring that data is processed in accordance with applicable data privacy laws and is kept secure.GForces is certifies to the standard of ISO27001.GForces uses Amazon Web Services Inc. as tis cloud platform provider.All data processed by GForces is stored on Amazon's web servers in the EEA.

If you visit our website

When someone visits our website, GForces collects standard internet log information (your IP address, browser, and type of device) and details of visitor behaviour patterns (where you joined our site from, the path you take through our site and where you leave). These are stored against unique ids (which are strings of numbers). GForces collects this information for the legitimate business purpose of monitoring the number of visitors to the various parts of the site, the general geographic location of visitors and engagement levels, which in turn enables it to make improvements to its websites and services, and provide business intelligence. This information is only processed in a way which does not identify anyone. It is kept indefinitely.

GForces also uses Google Analytics to collect standard internet log information and details of visitor behaviour patterns, which are stored against unique ids (i.e. strings of numbers). We collect this information for the legitimate business purpose of monitoring website traffic and engagement levels, which in turn enables us to make improvements to our website and the way we sell our cars and services. This information is only processed in a way which does not identify anyone. It is kept indefinitely.

If you use our enquiry forms

When you submit information using an online form, GForces processes the data collected and stores it for 31 days for the legitimate business purpose of enabling us to access the information and deal with your request (it is then kept for a further 14 days in GForces’ routine back-ups for business continuity purposes). We collect the following information:

If you enter your post code, GForces stores the first part of it (e.g. ‘ME14’ or ‘SW1’) and links it to standard internet log information already collected (it is used for the same purposes as that information, as outlined above).

If you use our LiveChat service

We use a third-party provider, Gubagoo Inc.to supply and support our LiveChat service. If you use the LiveChat service we will collect your name and email address if you provide this and any other personal information that you volunteer to us. This is used for the legitimate business purpose of handling customer enquiries in real time and then following up. This data is stored by Gubagoo for 2

years to enable us to access the information and deal with your enquiry. Gubagoo stores the information in the US under the EU-US privacy shield framework. Please see Gubagoo’s privacy policy for more information on how they use your data. https://www.gubagoo.com/about/policy.

Where we store your personal data

Your data is stored on our internal IT systems which include (but is not limited to) POLK (our marketing system), Pinnacle (our CRM system), Rapid Response (our web enquiry system operated by DMT Development Systems (UK) Limited), VMS (our vehicle management system) and SLI (our new vehicle system).

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may be processed by staff operating outside the EEA, who work for us or for one of our suppliers. This includes staff engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy and confirm that we only undertake such transfers under the EU/US Privacy Shield.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.



Data usage links to external websites

Our website may contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, Winchester Motor Group cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.



DATA RETENTION

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, contractual, marketing, accounting, or reporting requirements. 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 the applicable legal requirements. If we have a relationship with you (e.g. you are a customer or the registered driver of a leased or other vehicle purchased from us) we hold your personal information for 6 years from the date that our relationship ends. We hold your personal information for this period to establish, bring or defend legal claims or because other legislation or regulation requires us to do so.

Where we have obtained your personal information following a request for information, test drive, brochure, quotation or other information on any of our products or services, we hold you personal information for 1 year and 6 months from the date we collect that information, unless during that period we form a relationship with you.

In respect of our recordal of telephone conversations, these are kept for a period of 1 year and 6 months.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.



Your rights

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data.You can also exercise the right at any time by contacting us at:

informationofficer@winchester.skoda.co.uk.

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

• Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request the erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no lawful reason for us continuing to process it. You also have the right to ask us to stop processing personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.

Fee usually required

You will normally have to pay a £10 fee to access your personal. However, after 25 May 2018, we may charge a reasonable admin fee.If your request for access is clearly unfounded or excessive, we may refuse to comply with the request in such circumstances.

Right to withdraw Consent to marketing

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact Dan Nilsson on 01962 866331 or email dan.nilsson@winchester.skoda.co.uk. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Changes to our privacy policy

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to informationofficer@winchester.skoda.co.uk.