Sandles Ltd. (trading as Sandles Car Supermarket) is committed to protecting and respecting your privacy and will take appropriate measures to protect the processing of an individual’s personal data.
This policy is to explain what personal data we collect from you, how it will be used by us and why.
For the purpose of Data Protection Laws, the data controller is Sandles Limited, and we can be contacted by telephone on 01553 630052 or email sales@sandles.co.uk.
Our Data Protection Officer can be contacted by email at: laura@sandles.co.uk or by post at our registered address; Sandles Ltd. Leziate Drove, Pott Row, King's Lynn, Norfolk PE32 1DD. Our registration number is ZA024102.
What We Will Do with Your Data When You Apply
Before we provide services, goods or credit broking to you, we will need to collect certain details from you for the purpose of entering into an agreement with you, (for example, a service plan agreement), goods (for example, a sale agreement relating to a vehicle) or credit broking; administering any agreement with you; and in order to undertake checks for the purposes of preventing money laundering or to verify your identity.
If you access our website we collect information about your browsing experience, for the purposes of understanding and improving our website, customer experience and our products and services.
What We Share and Process
We will collect and process the following personal data about you:
Submitted Information: information you give us when making an application, this comprises of your name, date of birth, residential address and address history for the last three years, contact details such as an email address and telephone numbers, financial information, and employment details, to include your salary, employer name, address and duration of employment.
Device Information: information we collect about you and your device. Each time you use our website we will automatically collect technical information about your computer or other internet connected device including your internet protocol (IP) address browser type, domain names, access times and referring web site addresses. You may be able to disable the collection of some of this data through amending the web settings of your device or browser but doing so may impact the functionality of our website. Full details of our cookie policy can be found at www.sandles.co.uk.
Third Party Information: information we receive about you from third parties. This information may include your personal and financial information, your employer, or other person connected with your finance application), information about the vehicle you are purchasing which could include HPI and other security checks, credit information, such as previous applications, the conduct of accounts in your and your financial associate’s name (this is anyone linked to you for credit or finance purposes), any business accounts you have and public information such as County Court Judgments, bankruptcies and the Electoral Register.
We may combine Submitted Information with Third Party Information and may use both these categories of information and the combined information for the purposes set out below.
How We Use the Information Collected About You
Account Processing and Administration
Sale or Supply Agreement Administration: which will mean verifying identity and customer services, to investigate and respond to a complaint; complying with legal, regulatory and compliance obligations that apply to us (for example, anti-money laundering and counter terrorism checks), detection and prevention of fraud and other crimes; account management and call monitoring.
General Administration: tax administration, auditing, reporting and accounting functions, statistical analysis and market research, market, regulatory and operational risk management; systems testing and network monitoring.
Marketing Activities: conducting customer service surveys and offering goods and services such as insurances, warranties and/or service plans; profiling of your data for marketing purposes; contacting you where you have consented to us doing so to offer you other products and services, analysis of our customer database to understand our customer’s activities and preferences and to improve our services to you.
Commercial Activities: assigning our rights or obligations to a third party, obtaining funding for our business, and to understand and improve our products and services, (and when we use your data for each of these purposes we do so on the basis that we have a legitimate interest in doing so).
Telephone Conversations: call recording and customer identification
We will also use your personal data to check your identity if you get in touch with us.
We may monitor and record calls made to us for monitoring and training purposes and to improve the services we offer. We use your information in this way in our legitimate interest, in order to improve the services we provide to you. We never record your payment details over the phone and have a separate process to safeguard your information.
Verifying your identity and preventing fraud and money laundering: we will use certain personal data you have provided to us in order to confirm your identity and to prevent money laundering. More details about these checks are set out below.
When we use your personal data for these purposes we do so on the basis that we have a legitimate interest in assessing your application, preventing fraud and money laundering, and to verify identity, in order to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the services you have requested, and we will not be able to process your application without undertaking these checks.
As part of your original finance application, the lender will collect its own data in order to assess your application. However, should your application with one of our selected lenders, be unsuccessful we may pass your application details to another finance company. We will let you know who that is prior to passing your information to that company or credit broker, to help fulfil your lending requirement. That company will obtain their own credit reference and fraud prevention searches. The lenders we may pass your information to are: MotoNovo Finance, Black Horse Finance and DSG Financial Services.
We, as the suppliers of the vehicle, will have access to your information up to the point that your finance agreement is executed with the finance company, to facilitate your application for finance. However, we may also gain access to your information after the execution of any finance agreement to assist in a regulatory or servicing requirement, such as complaints handling and settlement values for any finance agreement arranged through us, for you.
Data Retention and Storage
All personal data you provide to us, or which we obtain from third parties, will be stored on our secure servers (or those of third parties or contractors we engage to help us run our business). We will keep information no longer than we need to for the purpose for which we collected it. The period of time for which we keep personal data depends on the legal and regulatory requirements, the purpose for which the information was obtained, and our business needs. We will keep information about any account you hold with us for at least a period of 6 years from the date we provide you with the vehicle and its associated funding, in line with our data retention policy that stipulates the timescales in line with our lawful purpose for processing your data.
Who We Share Your Data With
We may share your personal data with the following other third parties: third parties acting on our behalf, including without limitation, AutoProtect (for related Mechanical Breakdown Services), Judge Service (for feedback reviews) and outsourcing providers; retailers and manufacturers of Goods relating to your agreement; regulatory bodies, and law enforcement agencies, for administrative purposes, processing or for the operation and maintenance of your business with us.
We may also share your personal data with any person (and their or our professional advisors for this purpose) with whom we are negotiating any sale, transfer or re-organisation of our business or where we are organising our commercial funding. If this proceeds, the acquiring party or part of it may use your personal details in the same ways and for the same purposes as set out in this policy. We will give you their details once the business change has been completed.
Your Rights
You have the following rights (subject to certain statutory exemptions):
· to opt-out of receiving marketing information, or withdraw your consent to receive marketing information if provided on a previous occasion
· to be informed about the processing of your personal data (this is what this statement sets out to do)
· to have your personal data corrected if it’s inaccurate and to have incomplete personal data completed
· to object to processing of your personal data
· to withdraw your consent to processing your personal data
· to restrict processing of your personal data
· to have your personal data erased
· to request access to your personal data and information about how we process it
· to specify which credit reference agencies we have shared your personal data with
· from 25th May 2018 only: to move, copy or transfer your personal data (“data portability”)
If you are unhappy about how your personal data has been used you can contact us using the details above. You also have a right to complain to the Information Commissioner's Office (https://ico.org.uk), which regulates the processing of personal data.
If you would like more information about how we process personal data; are unable to access of any of the links or further information referred to in this document ; or would like to exercise any of your data protection rights please contact us using the contact details set out at the top of this notice.