SNOWS MOTOR GROUP LIMITED PRIVACY POLICY

1. General intro

We are committed to ensuring that we manage your personal data professionally and in compliance with all applicable data protection laws. Part of this commitment is to ensure that there is transparency about how we process personal data. This policy includes an explanation of:

• what data we are processing;
• why we are processing it and what we do with it;
• whether we will share it with anyone else;
• whether we will transfer it outside of the United Kingdom;
• how we keep your data safe; and
• your rights.

We hope that you find this Privacy Policy helpful. If you have any questions, please don’t hesitate to contact us.

2. About us

• Our company name is Snows Motor Group Limited, and we are located at Snows House, Second Avenue, Millbrook, Southampton, Hampshire, SO15 0BT. In this policy we have referred to Snows Motor Group Limited as: we, us, our or Snows.
• Snows is an authorised retailer for: Abarth, Alfa Romeo, BMW, Citroen, DS, Fiat, Jeep, Kia, Lexus, Lotus, Mazda, Mercedes-Benz Vans, Mini, Peugeot, SEAT, Suzuki, Toyota, Volkswagen Commercials and Volvo. A full list of our retail locations and our trading titles is available on our website: www.snowsgroup.co.uk
• For any queries concerning your data and this policy, please contact the Group Communications & Marketing Director, at the above address or by email at groupcommunicationsdirector@snowsgroup.co.uk or by 'phone on 02380 707750.

3. Your personal data

We process your personal data if we understand that you may be interested in purchasing our products or services. In this section we provide more detailed information about how we will manage your personal data.

What data do we hold about you and how have we obtained this?

• We will obtain information about you when you enquire about our products or services. Typically, the information that we obtain will be your contact details and payment information. If you choose to buy finance or insurance products from us or from companies that partner with us, we will need more detailed information including, in some cases, identity and personal financial information.
• If you are part exchanging or selling your vehicle to us, we will check your vehicle details via third party providers. These checks include vehicle mileage, condition, outstanding finance and history.
• If you have visited our website we may automatically collect some personal information including: 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 the Internet protocol (IP) address assigned to you by your internet service. We collect some of this information using cookies – please see Cookies in section 5 for further information. We may also collect any personal information which you allow to be shared that is part of your public profile on a third party social network.
• Our telephone calls are recorded for training purposes and may also be used to verify any comments that were made during any conversation.
• If you use our web chat function, we will keep a record of our communications.
• We have CCTV in operation at each of our operations for security purposes. It is therefore possible that images of you will be recorded when visiting our sites.
• Sometimes you will have sent your information directly to us, but you may have provided your information a third party who, in turn, has provided the information to us.

Your data that we process with your consent?
For new customers who have purchased goods or services from us on or since 25th May 2018 and who have consented, we:

• will provide you with marketing information beyond your initial enquiry about our products and services or the products and services of our selected partners;
• will keep you informed of events that we think will be of interest to you;
• will use photographic images or video footage of you when you collect your vehicle from us and may use this material to promote our business via social media channels or via our websites; and
• will use your interaction with our website and with our chat function to identify which products and services will be the most relevant to you and deliver targeted and relevant messages to you.

Your data that we process to comply with our contract
We will process your data as required to perform our contract with you. This may include processing your order with the manufacturer of the vehicle that you have chosen and for completing warranty work or other after-sales obligations such as the provision of breakdown and recovery services.

Your data that we process in your vital interests
Where it is in your vital interests, we may use your information to organise and notify you about safety and product recall notices.

Your data that we process to comply with our legal obligations
We may process your information to comply with legal obligations including assisting HMRC, the Police, the Driver and Vehicle Licensing Agency, the Driver & Vehicle Standards Agency and the Financial Conduct Authority.

Your data that we process to pursue our legitimate interests

We may process your information to allow us to pursue our legitimate interests including for:

• analysing our performance to further improve our customer services;
• training and to administer our websites;
• the prevention of fraud or other criminal acts;
• undertaking credit checks for finance and vehicle mileage/condition checks;
• complying with requests from you including if you exercise any of your rights noted in this Privacy Policy;
• the purpose of corporate restructure or reorganisation or sale of our business or assets;
• enforcing our legal rights or to defend legal proceedings and for general administration purposes;
• contacting you about contractual changes;
• contacting you by post or phone for service, maintenance & MOT reminders or by email where you are a recent customer;
• contacting you for market research and satisfaction surveys;
• (where you purchased goods or services before 25th May 2018) providing marketing information to you about our products and services or the products and services of our selected partners and to keep you informed of events that we think will be of interest to you;
• providing you with information about the products or services that you have asked us to provide – including sending you videos of your vehicle being serviced;
• responding to your enquiry concerning any of our products and services – including sending you a video of a vehicle that you have expressed an interest.

Will we share your personal data with any third parties?

• We may share your data with the relevant manufacturer or seller of the product that you have purchased or expressed an interest in purchasing and other companies within our group.
• We may disclose your information to our third-party service providers for the purposes of providing services to us or directly to you on our behalf e.g. advertising agencies or administrative service providers. When we use third party service providers, we only disclose to them any personal information that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.
• If we sell all or part of our business to a third party, we may transfer your information to that party to ensure that it can continue to provide information that you have requested or for any of the other purposes that we have noted above.
  We may transfer your data to government or other official bodies for the purposes of complying with legal obligations, for enforcing our rights, or for the prevention or detection of a crime.

How long do we keep your data?

• If you have expressed an interest in buying products or services from us or from our selected partners, we will retain your contact details and related information concerning your enquiry for 12 months from the date of your enquiry unless you have consented for us to keep your information for a longer period. Where you have consented, we will retain your contact details and related information concerning your enquiry for 5 years from the date that that we last had contact with you.
• If you have purchased goods or services from us or from our selected partners, we will keep the data relating to that purchase (e.g. order forms and invoices and related correspondence) for 8 years from the date of the contract.
• Voice recordings of telephone calls and CCTV images shall be kept for up to 1 year.
• Records of any discussions through our web chat facility will be kept for 2 years.
• If you have requested that we do not send you marketing information we will always retain sufficient information to ensure that we remember to comply with your request.
• The periods stated in this section 3.9 may be extended if we are required by law to keep your data for a longer period.

4. Transferring your data outside of the United Kingdom (‘UK’)

The information that you send to us may be transferred to countries outside of the UK. By way of example, this may happen if any of our servers or those of our third-party service providers are from time to time located in a country outside of the UK. These countries may not have similar data protection laws to the UK.
If we transfer your information outside of the UK in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected. These measures include imposing contractual obligations on the recipient of your personal information or ensuring that the recipients are subscribed to ‘international frameworks’ that aim to ensure adequate protection. Please contact us if you would like more information about the protections that we put in place.
If you use our services whilst you are outside the UK, your information may be transferred outside the UK to provide you with those services.

5. Cookies

We use Cookies on our website. A cookie is a small text file which is placed onto your computer (or other electronic device) when you visit our website. This enables us to monitor how many times you visit the website, which pages you go to, traffic data, location data and the originating domain name of your internet service provider.
You can find out more about the Cookies we use in our Cookies Policy available on the home page of our website.
You can set your browser not to accept cookies, however some of our website features may not function as a result.
For more information about cookies generally and how to disable them you can visit: www.allaboutcookies.org.

6. Data security

We have adopted appropriate technical and organisational measures to protect the personal data we collect and use having regard to the state of the art, the nature of the data stored and the risks to which the data is exposed to human action or the physical or natural environment. However, as effective as our security measures are, no security system is impenetrable. We cannot guarantee the security of our database.
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 website; any transmission is at your own risk. Once we have received your information, we will use procedures and security features to try to prevent unauthorised access.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

7. Links to other websites

Our website may contain links to and from other websites (e.g. social media sites such as Twitter, Flickr, YouTube and Facebook). Unless we own such websites, we accept no responsibility for the way in which they process your personal data. You are recommended to check the privacy policy of each website before you submit any personal data to it.

8. Your rights

Your right to access data

• We always aim to be as open as we can and allow people access to their personal information. Where we hold your personal data, you can make a ‘subject access request’ to us and we will provide you with:
  • a description of it;
  • an explanation of why we are holding it;
  • information about who it could be disclosed to; and
  • a copy of the information in an intelligible form – unless an exception to the disclosure requirements is applicable.
• If you would like to make a ‘subject access request’ please make it in writing by email to subjectaccessrequest@snowsgroup.co.uk or by post to our Group Communications & Marketing Director at the address shown in section 2.1 and mark it clearly as ‘Subject Access Request’.
• If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.
• Unless you agree a different time, we will complete your subject access request within one month.

Right to stop marketing messages

You always have the right to stop marketing messages. We will usually include an unsubscribe button in any marketing emails. If you do wish to unsubscribe, please just click the unsubscribe button and we will promptly action that request. For text messages, please text back STOP to unsubscribe. Alternatively, you can update your marketing preferences by contacting us at any-time. Our contact details are shown in section 2.

Right to be forgotten
If we hold personal data about you, but it is no longer necessary for the purposes that it was collected and cannot otherwise be justified – you have the right to request that we delete the data.

Right to restrict data
If we hold personal data about you and you believe it is inaccurate you have the right to request us to restrict the data until it is verified. You also have the right to request that the data is restricted where you have a right to it being deleted but would prefer that it is restricted.

Transferring your personal data
Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with your contract, as set out under 3.3 and 3.4, you may ask us to provide you with a copy of that information in a structured data file. We will provide this to you electronically in a structured, commonly used and machine-readable form, such as a CSV file.
You can ask us to send your personal information directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information

Right to complain
You always have the right to complain to the personal data regulator, the ICO.

9. Policy updates

This policy was last updated on 11th July 2018

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COMPANY INFORMATION

Registered Name: Snows BMW Group

Company Registered Number: 1318267

Place of Registration: England

Registered Office Address: Snows House, Second Avenue, Millbrook, Southampton, SO15 0BT

VAT Number: GB 750 1062 76

Email Address: marketing@snowsgroup.co.uk

Snows Motor Group Limited is authorised and regulated by the Financial Conduct Authority for consumer credit broking and is an appointed representative of Snows Business Holdings Limited for general insurance mediation. Our Firm Reference Number (FRN) for consumer credit broking is 685889 and our FRN for general insurance mediation  is 404314. Snows Business Holdings Limited is authorised and regulated by the Financial Conduct Authority, and their FRN is 309925.

COMPLAINTS PROCEDURE

BMW (UK) Limited (BMW) is committed to providing products and service of the highest standard. But we do understand that sometimes things can go wrong. If you have a concern or are dissatisfied in any way, we’ll do our best to help resolve the situation in a fair and transparent way.

BMW will investigate all complaints competently, diligently and impartially obtaining additional information as necessary. Every complaint will be assessed fairly, consistently and promptly taking into account all relevant factors to ensure a fair outcome for you.

Step 1: Discussion with your BMW Centre.

If you have a concern with either your vehicle or the service you have received at your BMW Centre, please firstly raise this with the Service Manager or Head of Business at the BMW Centre itself. They are best placed to address your concerns and if required, will contact us directly on your behalf.

Step 2: Contact us.

Should you remain unhappy with your BMW Centre’s response, please contact us by your preferred method from the list below.

Write to us at:
Customer Service
BMW (UK) Limited
Summit ONE
Summit Avenue
Farnborough
Hampshire
GU14 0FB

Call us on: 0370 5050 160
Calls are charged at the local rate, plus your phone company's access charge.

We're here: 8am - 7pm Monday to Friday

Email us at: customer.service@bmw.co.uk

What you will need to provide.

To help us investigate and try to resolve your complaint, please provide us with the following information:

• your name and address;
• details of how we can contact you;
• a clear description of your complaint;
• details of what you would like us to do to rectify the situation; and
• if appropriate, copies of any relevant supporting documentation.

Our commitment to you.

We’ll thoroughly investigate your complaint and offer a fair response that will take into account all the information available to us.

We will do our best to resolve your complaint quickly, sending a Summary Resolution Letter if your complaint can be resolved by close of the third business day following receipt. If your complaint relates to our credit broking activities and cannot be resolved by close of the third business day, we will:

• within 5 working days, provide a written acknowledgement of your complaint and give you the details of who is handling the case and how to contact them
• keep you updated on the progress of your complaint, and
• within 8 weeks of receiving your complaint, we will either: write to you with our final response and the reasons for providing this response, or explain why we are not in a position to give you a final response and let you know when we expect to be able to provide it.

In some cases we’ll need to contact your BMW Centre for more information. If appropriate, we may refer the complaint directly to them for information or action.

We may not always provide the answer you are looking for, but we’ll make sure we offer a clear explanation for our decision.

Financial Services

If your complaint relates to a finance agreement with BMW Financial Services, please click below for details on BMW Financial Services’ complaint handling procedure.

Step 3: What if I remain unhappy with your response?

If you are dissatisfied with either our final response, or the reasons for any delay in providing our final response you may be able to ask the Financial Ombudsman Service for an independent review.

To be able to ask them for an independent review your complaint must be in relation to our credit broking activities that is to say any marketing material or recommendations we make in relation to any finance offers from MINI Financial Services, a trading name of BMW Financial Services (GB) Limited, and you must have given us the opportunity to find a resolution first. You must also be a private individual, or a business, charity or trust with an annual turnover of less than 2 million euros and fewer than 10 employees.

If you wish to pursue your complaint to the Financial Ombudsman Service you must do so within 6 months from the date on which we send you our final response letter.

The Financial Ombudsman’s details are:
The Financial Ombudsman Service
Exchange Tower
London
E14 9SR

Telephone: 0800 0234 567

Email: complaint.info@financial-ombudsman.org.uk

Website: www.financial-ombudsman.org.uk

You may also raise a complaint with any of the trade bodies listed below.

THE MOTOR OMBUDSMAN.

The Motor Ombudsman is the UK's government-backed, self-regulatory body for the motor industry.

Fully-impartial, it is the first ombudsman to be focused solely on the automotive sector, and self-regulates the UK’s motor industry through its comprehensive Chartered Trading Standards Institute (CTSI)-approved Codes of Practice. BMW is accredited to the Motor Industry Code of Practice for New Cars.

Over 7,500 businesses, are accredited to one or more of the Codes covering new cars, sales, vehicle warranties and servicing and repair. These drive even higher standards of work and service, and give consumers added protection, peace of mind and trust during the vehicle purchase and ownership experience.

Address:
The Motor Ombudsman
71 Great Peter Street
London
SW1P 2BN

Telephone: 0345 241 3008

THE EUROPEAN COMMISSION’S ONLINE DISPUTE RESOLUTION SERVICE.

European legislation guarantees consumers:

• fair treatment;
• products which meet acceptable standards;
• a right of redress if something goes wrong.

To help ensure that companies meet the standards set by the European Parliament, consumers now have the right to address their complaint to the European Commission’s Online Dispute Resolution (ODR) Service. For full details please go to: https://ec.europa.eu/consumers/odr/