Privacy Statement

Introduction
Changes to our Privacy Notice
Definitions
Who is Haydock Commercial Vehicles Limited
How we process your Information legally
Why we collect your Information and the Information we collect
Supplier information.
Who we share your Information with
How long we keep your Information
Where we hold your Information
How we keep your Information safe
Use of Cookies
Links to other websites
What are my rights over my Information?
When you request to exercise your rights
How to stop receiving direct marketing
Contacting us
Further information

INTRODUCTION

Haydock Commercial Vehicles Limited (“we”, “us” and “our”) is committed to protecting and respecting your privacy.

Our Privacy Notice explains the personal data we collect about you when you interact with us. It also gives you information about what we do with your personal data and how we keep it safe.

Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

We hope that this Privacy Notice will give you clear guidance on how we use your personal data and what your rights are, but if you have any further questions, please do contact us.

You will find our contact details at the end of this Privacy Notice which you can use if you have any questions, including how to update or access your Information. Please see the section “Contacting us”.

CHANGES TO OUR PRIVACY NOTICE

This Privacy Notice may change over time. Any changes we make to our Privacy Notice will be posted on this page. If there are any significant changes, we will contact you and explain the changes.

DEFINITIONS

We use abbreviations in this Privacy Notice as follows:

Contact Information means your name, business name, address, telephone numbers and email addresses.

Information or Personal Data means Personal Data as defined by the UK General Data Protection Regulation (“UK GDPR”), the Data Protection Act 2018 and any other legislation relating to the protection of personal information (“data protection laws”)

Vehicle Identification Information means registration number and chassis number;

Vehicle Generated Information means:

(i) performance data such as vehicle components, fuel consumption, brake usage, gear shifting, battery usage, engine data and error codes; and

(ii) geographic position; and

(iii) in-vehicle entertainment information

WHO IS HAYDOCK COMMERCIAL VEHICLES LIMITED?

A data controller (“Controller”) is the company that decides why and how your Information is processed i.e. how it is collected and used.

When you deal with us, the Controller of your data is Haydock Commercial Vehicles Limited. There may be exceptions to this and if there are, we will bring those to your attention.

Where this Privacy Notice refers to “we”, “our” or “us” below, unless it mentions otherwise, it’s referring to Haydock Commercial Vehicles Limited as the Controller.

We are registered with the Information Commissioners Office under registration number ZB129133.

HOW WE PROCESS YOUR INFORMATION LEGALLY

When you provide Information to us, we will treat that information in accordance with this Privacy Notice and in line with the data protection laws.

Personal information or personal data, means 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).

Most of the Information we process is provided to us directly by you for the purpose of providing you with our services.

We collect and process your Information through your use of this website, including any Information you may provide through this website, or when you correspond with us by phone, email or otherwise.

We also collect your Information when you place an order for services, search for a product or service, participate in any social media functions on our website, or enter a competition, promotion, or survey, and when you report a problem with our website.

We will only use your Information when the law allows us to do so.

The lawful basis we most commonly use to collect and process your Information are:

· With your CONSENT

o In specific situations, we will seek your consent to collect and process your Information. When we seek your consent, we will make clear to you how we would like to use your Information so that you can make an informed decision about whether to allow us to collect and use your Information.

· Where we have a CONTRACTUAL OBLIGATION

o We may need your Information to comply with our contractual obligations to you. We may also require your Information where we take steps towards entering into a contract with you.

· Where we have a LEGAL OBLIGATION

o If the law requires us to, we may collect and process your Information.

· Where it is in your VITAL INTERESTS

o We will use your Information where we consider the processing of your Information will prevent or reduce any potential harm to you. For example, if we need to communicate a product safety announcement to you.

· Where it is in ours, or someone else’s, LEGITIMATE INTEREST

o In certain circumstances we may collect and use your Information where it is reasonable for us to do so in the interests of our business operations and where we consider that doing so will not materially impact your rights, freedom or interests. This means we may use your Information in a reasonable way (that you might expect) but only where we consider this will not cause you any excessive or unnecessary risk.

WHY WE COLLECT YOUR INFORMATION AND THE INFORMATION WE COLLECT

We collect and process Information about our clients, customers, suppliers, subcontractors, stake holders, business partners or joint venture partners in order 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.

Customer Account

When you have a sales interaction with us for the first time, we will likely create a customer account on our system. A customer account is similar to an address book entry and includes your contact Information (“Customer Account”).

We would then ‘attach’ to your Customer Account, details of your interactions with us and your Vehicle Identification Information (where you have purchased a vehicle from us, we have worked on the vehicle (no matter the manufacturer) or you have otherwise provided us with your vehicle details).

We may add Information to your Customer Account (or create a Customer Account where you do not already have one) in the following circumstances:

When you purchase a vehicle, parts, service or merchandise from us in one of our depots, over the phone or online, we will record details of your invoices and payments against your Customer Account. We require this information when you interact with us to comply with our legal obligations.
When you enter into a service agreement, a repair and maintenance agreement or a warranty agreement with us.
When you part exchange a vehicle.
When you enter into a contract with us for Monitor, Connect, Driver Training, Driver Coaching or other Optimise Services product package.
When you request a credit account with us, or any changes are applied to your credit account.

We may use your Customer Account information to:

process any purchases, services or repairs that you request. We require this information when you interact with us to comply with our legal obligations;
send you communications required by law or which are necessary to inform you about our changes to the services we provide you. These service messages will not include any promotional content and do not require prior consent when sent by email or text message.
send you product safety notices which are in your vital interest;
contact you about service requirements of your vehicle, or other operational communications. If we use your information in this way, we will do so on the basis of our legitimate interest in order to keep our business operations running effectively;
contact you in regard to any contract that you may have with us to fulfil our contractual obligations;
where you have requested a credit account, we may use your Information to conduct a credit check. Where you have an existing credit account, we may use your Information to periodically review the credit amount we extend to you. We do this on the basis of our legitimate interest to ensure the affordability of extended credit; and/or
retain records to evidence our agreement with you. We may do this on the basis of a legal or contractual obligation, or our legitimate interest where we retain records for the purposes of defending or pursuing any future legal claim.

Customer Relations Account:

When we create a Customer Account, we will also create a Customer Relations Account which will record details of our interactions with you. A Customer Relations Account may include:

Your Contact Information;
Details of your contact with us, including queries, requests, complaints and warranty claims.
We will record details of your interactions with us (and ours with you) through our contact centres, depots, central services, online or by using one of our apps. For example, we collect notes from our conversations with you, details of any complaints or warranty claims you make and any feedback you have given. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in using any feedback from you to improve our customer services and inform our product development.

We may create a Customer Relations Account, or add information to your existing Customer Relations Account in the following circumstances:

When you ask us to email you information about a product or service.
When you engage with us on social media, we may collect your social media username to help us respond to your comments, queries or feedback.
When you download or install one of our apps.
When you enter prize draws or competitions, we will use your information to administer the prize draw or competitions which you enter. We may also use this information to market to you if you represent a company.
When you book any kind of appointment with us or book to attend an event, for example a test drive or a customer track day event.
When you choose to complete any surveys, we may send to you.

Where you represent a limited company or incorporated partnership, we may use your Customer Relations Account Information to inform you about relevant products and services, including special offers, discounts, promotions, events etc. We do this on the basis of our legitimate interest to promote our products and services. We strive to provide you with choices regarding certain personal information uses, particularly around marketing and advertising. You are free to opt out of marketing communications from us at any time. Please see the section “How to stop us direct marketing to you”.

Where you are an individual, a sole trader or an unincorporated partnership, we may use your Customer Relations Account information to inform you about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on. With your consent, we will use your Customer Relations Account information to keep you informed by email and by other electronic communication methods such as text message. We may also market to you by mail or telephone on the basis of our legitimate interest to promote our products and services. We do not need your consent to market to you in this way, but you are free to opt out of marketing communications from us at any time. Please see the section “How to stop us direct marketing to you”.

Connected Services Information

We may receive your Vehicle Generated Information from Scania CV AB, our parent company. This information will usually not identify you as an individual. However, in certain circumstances, this Vehicle Generated Information may amount to personal data, for example, if you are an owner driver.

Vehicle Generated Information can be used to evaluate driving style, identify your servicing needs for the purposes of flexible maintenance, your location in the event of breakdown, and/or allows you to engage with fleet management through the Connected Services portal.

For more information about Vehicle Generated Information and how that is used, please see Scania CV AB’s Privacy Policy on their website.

Other Information

We may also collect your Information in certain other circumstances:

· PAYMENT CARD DATA: When you make a credit or debit card purchase with us, we will process your payment card information. We do not hold your long card number. It is used by our payment processing partner only in the moment the payment is processed. We ensure your payment card information is secured to Payment Card Industry Data Security Standards. We retain for our records your payment method, card type and the last 4 digits of your payment card. We process this Information on the basis of our legitimate interest to prevent fraudulent transactions. This also helps to protect our customers from fraud. If we discover any criminal activity or alleged criminal activity through our use of suspicious transaction monitoring, we will process this Information for the purposes of preventing or detecting unlawful acts.

· DRIVING LICENCE: If you wish to drive one of our vehicles (courtesy cars, rental vehicles, driver training vehicles etc), we may ask you for a copy of your driver’s licence or your DVLA code. This will include details of your full name, address and date of birth, and in the case of a photocard licence, your facial image. We collect this Information under our legitimate interests for the purposes of ensuring you have a valid licence to drive our vehicle, to safeguard our property, staff, instructors and other road users, and for the purpose of insuring the vehicle. We will hold your Information for a limited time only. Your Information will not be shared unless we are notified of an accident or incident whilst you were driving the vehicle; in which case, your Information may be shared with the police, our insurers and legal advisors.

· WEBSITE: When you enter our website, our web servers may store details of your browser and operating system, the website from which you visit our website, the pages that you visit on our website, the date of your visit, and, for security reasons, e.g. to identify attacks on our website, the Internet Protocol (IP) address assigned to you by your internet service provider. We collect some of this Information using cookies. Please visit the ‘Cookies’ section of this Privacy Notice to learn more.

· SAFETY: When you fill in any forms, for example, if an accident happens on any of our premises, we may collect your Information.

· THIRD PARTIES: When a third party provides us with your Information, for example, businesses within the Haydock Commercial Vehicles Limited Group may provide us with your Information. Where your Information is received by us and you have not received a copy of this Privacy Notice, we will contact you to inform you that we have received your Information, what Information we have received and how we may use that Information.

· PUBLIC SOURCES: From publicly available sources (such as the Vehicle and Operator Services Agency) when you have given your consent to share Information or where the Information is made public.

· CCTV: When you use our car parks and premises, we may have CCTV systems operated for our security and yours. These systems may record your image and number plate during your visit. We do this on the basis of our legitimate interest to protect our customers, premises, staff and assets from crime. If we discover any criminal activity or alleged criminal activity through our use of CCTV, we will process this Information for the purposes of preventing or detecting unlawful acts.

We may also use your Information in the following circumstances:

· To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate interest to improve our product offerings to customers.

· To comply with our contractual or legal obligations to share Information with law enforcement.

· To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to send these communications to help improve our products and services.

SUPPLIER INFORMATION

Where we work with Suppliers or other business partners (or prospective suppliers or business partners), we may share Information.

Information shared in this way will be used for the purposes of the administration of any contract or other agreement and for the ongoing supply of goods/services and other communications with our business partners.

Where Information is shared in this way, other Information may be generated and stored by us. For example, voicemails, emails, correspondence and other work-related communications and computer logs may be created, stored or transmitted by us using our computer or communications equipment for the purposes of our legitimate interest in the efficient management of the business and supply contracts.

WHO WE SHARE YOUR INFORMATION WITH

We understand that your privacy is important and that you trust us to look after your Information. We will never sell your Information.

We may share your Information with carefully chosen third parties that we trust to carry out services on our behalf.

When Information is shared with a third party, we ensure that your Information is kept safe by:

Providing only the Information they need to perform the services for us.
Restricting the use your Information for the exact purposes we specify in our contract with them.
Work closely with them to ensure that your privacy is respected and protected at all times: and
Ensuring, when we stop using their services, that your Information will either be deleted by them or rendered anonymous.

We will not share your Information without good reason.

Below are some of the categories of third parties who we may share your Information with:

i. Group Companies

We may share your Information with other companies within the Haydock Commercial Vehicles Limited Group. This may be to offer you services that we cannot, for example, vehicle finance options, or to provide vehicle recovery services such as Scania Assistance.

ii. The Scania Dealer Network

We may share your Information within the Scania Dealer Network. The Scania Dealer Network consists of over 60 Scania Dealerships across the UK. Some of the dealerships belong to Scania (Great Britain) Limited and some of them belong to other franchisees, operating according to Scania Dealer Operating Standards. Together they form the ‘Scania Dealer Network’. Each corporate member of the Scania Dealer Network has access to your Information held on the Customer Account and Customer Relations Account. This allows the UK network to operate as efficiently as possible to keep you moving, to assist you in the event of breakdown and to keep you up to date with your servicing requirements. The companies within the Scania Dealer Network (and links to their own privacy policies, where available) are:

Scania GB Ltd - https://www.scania.com/uk/en/home/legalnotice/privacy-statement.html
TruckEast Limited - https://www.scania.com/uk/en/truckeast/legalnotice/privacy-statement.html
West Pennine Trucks Limited - http://www.scania.com/uk/en/westpennine/legalnotice/privacy-statement.html
Graham (Commercials) Limited - http://www.scania.com/uk/en/graham/legalnotice.html
Keltruck Limited - https://www.keltruck.com/about-keltruck/legal-information/
Road Trucks Limited - https://www.scania.com/uk/en/roadtrucks/legalnotice/privacy-statement.html
Pip Bayleys Limited - https://www.scania.com/uk/en/home/legalnotice/privacy-statement.html
Granco Limited - https://www.scania.com/uk/en/home/legalnotice/privacy-statement.html
S.J.Bargh Limited - http://www.sjbargh.co.uk/

iii. Our Suppliers and Service Providers

We may share your Information with our third party service providers, agents, subcontractors and other organisations for the purposes of providing services to us or directly to you on our behalf.

Category	Industry	Sector	Location
Drivers	Services	Automotive	EU
Credit Reference Agencies	Financial Services	Credit Agencies	EU
Marketing Agencies	Media	Advertising	EU
Body Builders	Manufacturing	Automotive	EU
Insurers	Financial Services	Insurance	EU
IT Service Providers	Information Technology	IT Software and Services	EU & USA
Travel Companies (Events)	Consumer Services	Hotels, Airlines, Restaurants and Leisure	EU & USA
Fuel Card Services	Financial Services	Consumer Finance	EU
Survey Providers	Professional Services	Research and Consulting	EU & USA
Market Researchers	Professional Services	Research and Consulting	EU
Driver Trainers	Services	Automotive	EU
Institute of Advanced Motorists	Regulated body	Automotive	EU

iv. Other third parties
We may also share your Information if we’re under a duty to disclose or share it in order to comply with our legal obligations, to detect or report a crime, to comply with our tax obligations, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our staff and customers. In these circumstances, your Information may be shared with the Police, HMRC, DVLA, VOSA or other registered bodies.

v. In the event that we undergo a merger, acquisition or sale, or other corporate transaction, your Information may be transferred to the successor entity or third party as part of the transaction. Such transfers will be conducted in compliance with applicable laws and this Privacy Notice. The receiving entity will be required to protect your Information in a manner consistent with this Privacy Notice and applicable data protection laws.

HOW LONG WE KEEP YOUR INFORMATION

Whenever we collect or process your Information, we’ll only keep it for as long as is necessary for the purpose for which it was collected and to defend any potential claims.

At the end of that retention period, your Information will either be deleted completely or anonymised. We may use your data in an anonymised way (so you cannot be identified) for statistical analysis and business planning.

When we consider how long to hold your Information, we will consider several factors:

whether any legal provisions require a maximum or minimum retention period;
whether the business requires the Information and documents for business operations;
whether we need to retain your Information to allow us to contact you in the event of any product safety issue;
whether the Information and documents we hold may support any legal claim or defence.

WHERE WE HOLD YOUR INFORMATION

Sometimes we may share your Information with third parties and suppliers outside the United Kingdom (UK), for example some of our suppliers are based in the European Economic Area (EEA), and the USA. The EEA includes all EU Member countries and Iceland, Liechtenstein and Norway. The table describing our Suppliers and Service Providers above will provides more detailed information about when this may occur and the locations.

If we do transfer Information outside of the UK, we have policies in place to ensure your Information receives the same protection as if it were being processed inside the UK. For example, our contracts with third parties and suppliers stipulate the standards they must follow at all times.

Any transfer of your Information will follow applicable laws, and we will treat your Information under the guiding principles of this Privacy Notice and in line with the data protection laws.

HOW WE KEEP YOUR INFORMATION SAFE

We, the Depots within the Haydock Commercial Vehicles Limited Group, and the Scania Dealer Network all use technical and organisational security measures to protect the Information supplied by you and managed by us against manipulation, loss, destruction, and access by third parties. Our security measures are continually improved in line with technological developments.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Information, we cannot guarantee the security of your Information whilst in transit to our website and any transmission is at your own risk.

Where we have given (or where you have chosen) a password which enables you to access an account, you are responsible for keeping this password confidential. We ask you not to use the same password as on other accounts and not to share your password with anyone.

USE OF 'COOKIES'

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By browsing the site, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive. Cookies allow our websites to recognise you when you visit.

We use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services;
Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
COOKIE_MESSAGE - Cookie Message - This cookie tells us whether you have accepted our cookie policy.
RECENTLY_VIEWED - Recently Viewed - This cookie is used to simplify the use of the Dealer locator, telling us which Scania Dealers you have previously looked at.
S-FID - Adobe Analytics - This cookie is used by Adobe Analytics to help measure the amount of traffic on our website.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

LINKS TO OTHER WEBSITES

Our website may contain links to other websites run by other organisations which we do not control.

This policy does not apply to those other websites and apps‚ so we encourage you to read their privacy statements. We are not responsible for the privacy policies and practices of other websites and apps (even if you access them using links that we provide) and we provide links to those websites solely for your information and convenience. We specifically disclaim responsibility for their content, privacy practices and terms of use, and we make no endorsements, representations or promises about their accuracy, content or thoroughness. Your disclosure of Information to third party websites is at your own risk.

In addition, if you linked to our website from a third party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party website and recommend that you check the policy of that third party website.

WHAT ARE MY RIGHTS OVER MY INFORMATION?

You have several rights afforded to you under data protection laws. You have the right to:

Withdraw your consent: Where our processing of your personal data is based on your consent, you have the right to withdraw your consent at any time. If you do decide to withdraw your consent we will stop processing your personal data for that purpose.

Your right to be informed: You have the right to request a copy of the Information we hold.

Your right to rectification: Where any Information we hold is inaccurate, out of date or incomplete, you can request that it is changed. If you notify us that the Information, we hold is complete or inaccurate we will correct or complete the information as soon as possible.

Your right to Erasure or the Right to be forgotten: You may ask that we delete your Information, and we must do so where we no longer have a reason for holding your Information, you withdraw your consent or you object to its processing. Following your request, we will erase your Information without undue delay unless the continued retention is necessary and permitted by law.

If we make the Information public, we shall take reasonable steps to inform other data controllers processing about your erasure request.

Your right to object: In some circumstances you have the right to request that we temporarily stop using your Information in a certain way. This right applies where:

you think the Information we hold is inaccurate;
you think we are processing your Information illegally;
we no longer require your Information but you may require it for legal reasons; or
you have objected to us processing your Information (see below) and you await a response from us.

Where your details are used for marketing, you can opt out at any time. You are able to unsubscribe from marketing on each contact or you can contact us to object to any processing.

Your right to restrict processing: You have the right to request that we restrict the processing of your personal information. This can be done in circumstances where we need to verify the accuracy of the information, if you do not wish to have the information erased or you have objected to the processing of the information, and we are considering this request. Once the processing is restricted, we will only continue to process your personal information if you consent, or we have another legal basis for doing so.

The right not to be subject to automated decision making and profiling: You have the right to not be subject to solely automated decisions (i.e., decisions that are made about you by computer without any human input) in relation to any processes that have a legal or similarly significant effect on you.

We do not make a soley automated decisions that have a legal or simulary significant upon you. You will be notified if we make a solely automated decision which produces a legal effect or significantly affects you.

WHEN YOU REQUEST TO EXERCISE YOUR RIGHTS

You will not have to pay a fee to exercise any of the rights listed above. However, we may charge a reasonable fee if your request is clearly unfounded or excessive, including where requests are repetitive. 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 Information or to exercise any of your other rights. This is a security measure to ensure that personal information 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.

HOW TO STOP RECEIVING DIRECT MARKETING

You can stop receiving marketing emails from us at any time by emailing anyone within the Haydock Commercials Group, who will process this by forwarding the request to the Data Protection Champion.

We will stop all direct marketing to you if you email your request to haydock.pulse@haydockcommercials.com

Please note that you may continue to receive communications for a short period after changing your preferences whilst we process your request.

Contact us
If you have any queries questions, suggestions or complaints about the processing of your Information or wish to contact us to amend/update your marketing preferences, please contact us using the details below:

Email: haydock.pulse@haydockcommercials.com

Postal Address:

Haydock Commercial Vehicles Limited

Unit 4, Lockheed Road

Burtonwood
Warrington

WA5 4AH

Telephone: 01942 714103 and ask for the Data Protection Champion or Finance Director.

FURTHER INFORMATION

We encourage you to get in touch with us directly in the event of any query or question, and we will do all we can to resolve any issue you may have.

For further information on data protection please visit the Information Commissioner’s Office (ICO) website.

The Information Commissioner’s Office regulates data protection. If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal information, you have the right to lodge a complaint with the Information Commissioner’s Office.

You can contact them by calling 0303 123 1113 or visit the website.