Quick Lane

Cookie and Website Privacy Policy

 Privacy Policy

Owner – DPO and GDPR Consultant

Version and Approval History

 | Version | Author | Date | Description | Reviewer / Approval
 | 0.1 | Andrew Okwedadi | 11/12/2019 | Final Draft |  
 | 1.0 |   |   | Final |  
 | 1.1 |   |   | Final Updated |  

Maintenance

 | Review Frequency  | Annually
 | Next review date  | 11/12/2020


Table of Contents
 
1. Introduction

Quick Lane Europe Limited (“we”, “our” or “us”) and/or Quick Lane outlet (“Centre”, “we”, “our”) Is committed to safeguarding the privacy of personal and sensitive personal data and is bound to comply with the UK Data Protection Act 2018 and EU General Data Protection Regulation (2016/679) GDPR, along with similar and applicable laws in other countries around the world. This Privacy Policy forms part of Quick Lane Europe’s Limited’s and Quick Lane outlet’s obligation to be open and fair with all individuals whose personal and sensitive personal data we and our centre processes and to provide details around how we process such personal data and what we do with it.

We process the personal data of our customers, such as name, contact details and email address, certain information about you and your vehicle will be processed, amongst other things. Processing of this data implies collecting, storing, using, disclosing or disposing of individuals’ personal data.

Individuals’ who leverage Quick Lane Europe’s and our Centre products and services, may be provided with further Privacy Policies which may be contained in a separate supplemental notice. These additional Privacy Policies shall supplement this website Privacy Policy and describe in more detail how your personal information is used in a particular context.

This Privacy Policy relates to the processing of personal data by Quick Lane Europe Limited and Quick Lane outlet. Unless otherwise stated, all references to “we” or “our” shall imply all Quick Lane Europe Limited and the Centres are processing personal data or sensitive personal data as separate data controllers.

None of the lists, or examples provided in this Privacy Policy, are intended to be exhaustive or fully representative of every individual.


2.Scope

The scope of this Privacy Policy covers customers in respect of the following: -

·        Collecting Personal Data

·        Using Personal Data

·        Disclosing Personal Data

·        Retaining Personal Data

·        Securing Personal Data

·        International Data Transfers

·        Your Rights (including Subject Access Request)

·        Updates / Amendments

·        Third Party Websites

·        Quick Lane Europe Ltd Website – Use of Cookies

·        Opt-in / Opt-out

·        Our Details

·        Complaints


3. Collecting personal data

This Policy details how we collect and use your data when you are in a Quick Lane centre, online, via social media, telephone, text, websites and any other form of correspondence. 

Other personal data that we collect are:

·        Your name and contact information(such as your address, telephone number(s) and email address) and information about your business or employer if you are enquiring in a commercial capacity; 

·        Information about your vehicle (including your Vehicle Identification Number ("VIN"),        vehicle registration number, model, age and mileage);

·        The products and services in which you are interested or have purchased;

·        Your contact and marketing preferences; and

·        Information required for financing purposes such as payment information;

·        And your chosen service relating to your booking. 
·        When you book or make enquiries with us, your reviews, complaints etc.


In addition and where permitted by law, we may combine the information we hold with information about you or your interests, socio-economic and socio-demographic status, online identifiers and current contact details collected by third parties such as marketing agencies and from public sources.

We may be required by law to collect certain personal information. We may also be required to collect your personal information as a result of a contractual relationship with you. Failure to provide this information may prevent or delay the fulfilment of these obligations.

We also collect information about your computer and about your visits to Quick Lane Europe’s website (quicklane.co.uk), and centres, including your IP address, browser type and version. 

Other means by which we can also collect you data are via our Social media platforms such as Facebook, LinkedIn Quick Lane UK and Europe pages, also your geographical location on both our website and social media platforms, when you enable location based services on your smartphone device. Also on our free Wi-Fi access within our centres, in-centre digital data collection booking forms. 

We may collect, use and store your personal data for the following purposes:

·        To Improve the services we offer to a wider audience based upon the services and/or locations you have chosen to utilise;

·        To inform you on the progress of work carried out on your vehicle or work identified that could legally prevent the usage of your vehicle. You can withdraw consent at any time or change your personal details on request.

·        Based on Information that you provide to us for the purpose of subscribing to our marketing communications.

·        Based on Information that you provide to us when using any of our products and services we provide, or that is generated during the course of using those products and services.

·        Based on Information that you post on our social media platforms.

·        Based on Information contained in, or relating to, any communication when you call us or that you send to us through our website, email or in writing.

·        Information to help us comply with our legal and regulatory obligations, including reporting to and being audited by regulators and external auditors.

·        Information to help us comply with court orders and to exercise and defend our legal rights.

·        Any other personal information that may be sent to us and which we use for legitimate business purposes.

Before you disclose to us the personal data of another person, you must obtain that person's consent to both the disclosure and the processing of that personal data in accordance with this Privacy Policy. Where the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, we are mandated to collect this personal information in order to provide you with our products or services. Non provision of this information means that we cannot provide you with the product/services requested.


4. Using Personal Data

We collect your personal information when:

You fill in forms or make bookings (for example, if you book a service), receive services or purchase products at a Centre; and you contact us (for example, we will keep a record of the information you provide when you write to us or contact our customer service centres).

We use the personal information we collect to:

§  Fulfil your requests (to provide services to you- E.g. Vehicle repair);
§  Manage and improve our business and our relationship with you;
§  Assess the quality of the services we and the Centres provide, and the services our suppliers provide to us or on our behalf;
§  Deal with your enquiries;
§  Conduct market research and measurement of customer satisfaction; 
§  tracking of sales information; 
§  Provision of this information to the manufacturer and other members or associates of the manufacturer for the above purposes.
§  Send you marketing material in line with your communications preferences;
§  comply with our legal and regulatory responsibilities, to respond to legal process or requests for information issued by government authorities or other third parties, and to prevent and detect crime and fraud, or protect your, our or others’ rights; and
§  Repair, diagnosis and servicing for your vehicle. 

When your vehicle was manufactured it was assigned a unique number (the Vehicle Identification Number, or "VIN"). From the VIN we can tell certain information about your vehicle, including its model, age, the software it uses and its technical specifications.

In order to diagnose, analyse, repair or service your vehicle, the technicians working on it will need to collect the VIN together with certain diagnostic information and information about the current state of your vehicle (for example, what software versions it is using, its mileage etc.).

This information will be transferred to a system run by your vehicle manufacturer so that the technicians working on your vehicle can be provided with vehicle-specific repair, maintenance and diagnostic information (such as wiring diagrams and vehicle software updates) and information about any past work carried out on your vehicle to assist them to diagnose, repair and/or service it and to enable them to maintain their records.

To make sure your vehicle has a comprehensive diagnosis record, information about what work is done to your vehicle when it is serviced or repaired will be linked to the VIN of your vehicle. This will be transferred to the system and stored so that Quick Lane (or any third parties authorised to use the system in this way) can make information about past repair or service available to any repairer anywhere in the world who needs to repair or service your vehicle.

The Centres and Quick Lane Europe, may combine your personal data for analysis purposed to assist with the purposes outlined above, and to:

§  Help us understand, develop and improve our products, processes, services and marketing strategies;
§  Personalise our communications, products and services to you;
§  Keep your personal information up to date;
§  Understand our customers better; and
§  Manage and improve our relationship with you.

This could include, for example, inform our distribution strategy, evaluating the effectiveness of our marketing and customer service, conducting market analysis and identifying products or services which may be of interest to you, and contacting you to tell you about those products and services.

We would like to make sure the communications we send you and our interactions with you are as relevant to you as possible. As a result, from time to time, we may use information about you collected from public sources and from third parties to help us determine what products and services you might be interested in. For example, analytics providers and advertising services may analyse the information they collect from online and other sources to provide us with information about your demographics and interests – such inferences about your age range and the types of products or services that may interest you. We may then send you information about those products and services in accordance with your communications preferences, and use the information we hold about you to inform our customer service centres if you contact them. 

We may also work with third parties to show you tailored advertising on social media platforms or, if you have consented to the use of cookies, when you browse the internet/visit other websites. You can find out how to stop receiving marketing material from us in the 'opt-in/opt-out' section below.

We keep your personal information in identifiable form for as long as is reasonably necessary to fulfil the purposes for which it was collected and as required to comply with applicable legal and regulatory obligations. This generally means holding your personal information for as long as one of the following apply:

Your personal information is reasonably required in order to provide the services you have requested;

Your personal information is reasonably required in order to protect and defend our rights or property (this will generally be the length of the relevant legal limitation period); or

Applicable laws or regulations otherwise require the retention of your personal information.

We may also use your personal information to:  

§  Administer, personalise and secure our website.
§  Enable your use of any product or service that we may provide through our website.
§  Supply you with Quick Lane products and services. 
§  Send invoices and payment reminders to you or collect payments from you.
§  Send you marketing communications.
§  Deal with enquiries and complaints.
§  Comply with our legal and regulatory obligations.


5. Disclosing Personal Data

Your personal information may be disclosed to:

We only disclose your personal data in the ways set out in this Privacy Policy or subject to any agreements in place between us. The following circumstances may apply:

·        Across our business, as part of a need to know or as part of improving our existing solutions and services or as part of providing new solutions and services. 

·        companies or other organisations that we have engaged to provide services on our behalf, such as web-hosting companies, mailing vendors, analytics providers, event hosting services, and information technology providers;

·        companies or other organisations where You have asked us to or agreed that we may share your personal information with them;

·        Quick Lane outlet and our partners where this is necessary to provide You with a product or service;

·        professional advisors;

·        any law enforcement agency, court, regulator, government authority or other third party where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues;

·        To third parties who process personal data on our behalf, such as systems providers.

·        To third parties who collect personal data on our behalf as Data controllers, but provide us 
or you, with a service on behalf of us (E.g. our cloud service Data Processors E.g. Autino, Denfield Advertising Marketing Ltd, GP Strategies etc.)

·        To third parties with whom information is shared for other fraud and crime prevention purposes. 

·        To any regulator (e.g. Financial Conduct Authority, ICO), external auditor or applicable body or court where we are required to do so by law or regulation or as part of any investigation.

·        To any central or local government department (e.g. the Department for works and Pensions, Local council Authorities) and other statutory or public bodies, such as the HMRC, Home Office.

·        To any law enforcement and other government agencies.  We may also share personal information obtained through the Website in order to comply with a legal requirement or requests from public authorities; to protect or defend our or another's rights or property; to protect individuals' personal safety; or to detect, prevent, or otherwise address fraud, security, safety, or privacy issues.

·        To any prospective buyer and/or third party in the event we sell any part of our business and/or assets, we will ensure via contracts and other legal instruments that the buyer uses your personal data in accordance with the tenets outlined in this Privacy Policy. That is we will use reasonable efforts to try to ensure that the entity to which your personal information is transferred to uses it in a manner that is consistent with this notice.

·        We may share the personal data we collect with Quick Lane LLC which may carry out their own analysis of the personal data we collect to understand and improve their own services. We may also share the personal data with other Quick Lane Tyre and Auto Centres where it is necessary to provide you with a product and/ or service. We take steps to make sure these companies will not use your personal data in ways which are incompatible with the purposes set out above.

We do not sell, rent or trade any of your personal data.

We will not, without your consent, disclose or supply your personal data to any third party for the purpose of their or any other third party's direct marketing.


6. Lawful Basis for Processing Personal Data

There are different lawful grounds that we rely on to use your personal information and we will collect and use your personal information in the following situations:

Where our use of your personal information is necessary to perform a contract or contracts that you are a party to, or to take steps that you request before entering into a contract. These contracts could include the conditions on which you enter a competition or agreements you enter into for service products, for example.

Where our use of your personal information is within our legitimate interests or the legitimate interests of the organisation with which we have shared your personal information and we have made sure that your personal information, and your rights in relation to that information, are protected. For example, we may rely on this legal ground if we use your personal information to: 

§  understand and improve our (or their) products, services and/or business or marketing strategies; 
§  for research purposes; to manage and improve our relationship with you and for administrative purposes; 
§  to help find out what information, products and services are most likely to interest You and to send or show You information, offers, and online advertisements for these products or services; 
§  to personalise your experience of our products and services; to ensure that our products and services are delivered and used in accordance with the law and the terms and conditions that apply to them; 
§  and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues;
§  Where we believe it is necessary to use your personal information to comply with a legal or regulatory obligation;
§  In limited circumstances where we believe it is necessary to protect someone's safety or vital interests;
§  In certain circumstances, we may need to use your personal information for purposes which are in the public interest; and

Where we have your consent. We will rely on your consent to, for example use your personal information for marketing to you by email, text message etc (dependent on your chosen medium). 

Where we rely on consent to use your personal information, you have the right to withdraw that consent at any time. Please see the 'Opt-in/Opt-out' section of this notice for more details.


7. Securing Personal Data

As we are Data Controllers of your personal data, we will ensure that all necessary and adequate safeguards are in place to prevent unauthorised access, loss, misuse or alteration of your personal data.

We store all personal information on secure servers with relevant access, encryption and firewall controls. 

Any personal data sent to us, either in writing or email, may be insecure in transit and we cannot guarantee its delivery.

Passwords must be kept confidential and not disclosed to a third party. We will not ask you for your password.


8. International Data Transfers

Your personal information will be treated in accordance with UK law concerning data protection and may be transferred within the European Economic Area ("EEA"), as well as to countries outside the EEA (including to the USA). The countries to which we transfer your personal information may not be regarded by the European Commission as ensuring an adequate level of protection for personal information. As a result, when we transfer your personal information outside the EEA we will put in place appropriate international transfer legitimising safeguards in accordance with our legal obligations to ensure that your personal information is adequately protected, irrespective of the country to which it is transferred. If this is the case, we will ensure that appropriate safeguards are in place to protect the personal information and to ensure it is kept securely at all times. Such safeguards used are the EU Commission approved Standard contractual Clauses (Model Contract Clauses- MCC’s) EU-USA Privacy Shield Certification Framework or other legitimising instruments (as stated in chapter v of the GDPR) for international data transfer for data to be processed appropriately. If you would like to know more about how we protect your personal information when it is transferred outside the EEA, please contact us using the details below.

9. Your Rights

As a customer, you may instruct Quick Lane Europe Limited and the Centres to provide you with any personal data we hold about you as part of a Subject Access Request. The provision of such information will be subject to: -   

Appropriate evidence of your identity, such as a passport, driving licence as well as a recent bank statement or utility bill.  

In certain instances, where exemptions exist, we may withhold personal data that you request, and which are permissible by law.  

You have the right to rectification and may wish to contact us if the personal data that we hold about you needs to be corrected or updated. 

You have the Right to Object to us processing your data, when the legal basis upon which that processing has been carried out has been on the basis of our legitimate interest and for the purpose of direct marketing, and the right to request we restrict the processing of your data.  

We do not perform any auto-profiling of individuals.

10. Updates/Amendments

In order to remain compliant with any legal and regulatory obligations, or as part of our evolving business practices, we may update this Privacy Policy from time to time by publishing a new version. In certain instances, we may notify you.

11. Third Party Websites

We are not responsible for the practices employed by Third Party Websites linked to or from our Website nor the information or content contained therein. Often links to other websites are provided solely as reference points to information on topics that may be useful to the users of our Website. Please remember that when you use a link to go from our Website to a Third-Party Website, our Privacy Policy will no longer apply. Your browsing and interaction on any other Website, including Third Party Websites, which have a link on our Website, are subject to that Website's own Privacy Policy.

12. Quick Lane Europe LTD Website - Use of cookies

Quick Lane Europe Ltd records the number of visitors to the relevant sections of our Website and tracks movement between the sections by means of ‘cookies’. Cookies are small data/text files containing anonymous information placed on your internet browser (Google chrome, internet explorer etc.) and by extension on your computer, and are automatically downloaded to a user’s hard drive in order to recognise a user that has visited our Website previously. 

The cookies used on this Website are cookie’s description, XSRF-Token cookie (validates user as not a “bot”, but a real person), Quick Lane session cookie, Google analytics (allows google to track the activity of the sessions e.g. pages clicked, time spent etc.).

Quick Lane Europe Ltd reserves the right to use cookies in order to analyse trends and to improve the design and layout of our Website. You cannot be identified as an individual from this type of information.

See also our Cookie use policy for more information.

13. Opt in/ Opt out

You have the right, at any time, to ask us not to process your personal data for marketing purposes. 

You can opt-out of receiving email communications simply by clicking the unsubscribe link, which is contained within every marketing emails or outreach we send to you. 

You may instruct us at any time not to process your personal data for marketing and communications purposes by means of ‘opting-out’.

Please note it can take up to 28 days for a request to be fulfilled because of pre-planned or ongoing marketing activity.

14. Data Protection Registration

We are registered as a data controller with the UK Information Commissioner's Office and our data protection registration number is ZA563832. 


15. Our Details

Quick Lane is registered and Incorporated in England Company Number No 11331850

You can contact us as follows: -

Telephone:                         

In Writing:                                                         

Data Protection Officer
Quick Lane Europe Limited
Registered Office: Arterial Road, Laindon, Essex, England, SS15 6EE


Complaints

If you feel your rights have not been respected, or do not feel a situation was resolved satisfactorily, you have the right to raise a complaint with the UK Information Commissioner’s Office.

You can contact them as follows: -

Telephone: +44 (0)303 123 1113

In Writing:                        

 Information Commissioner's Office
 Wycliffe House
 Water Lane
 Wilmslow
 Cheshire
 SK9 5AF