Privacy and Cookie Policy

1.        Introduction/About Us

Carkeys.co.uk, a brand of Autonetwork (GB) Limited (“we”/”us”) is committed to protecting and respecting any personal information you share with us.

This statement describes what types of information we collect from you, how it is used by us, how we share data with others, how you can manage the information we hold and how you can contact us.

We will always give you the option not to receive marketing communications from us. We will never send you unsolicited ‘junk’ email communications or share your data with anyone without having an appropriate lawful basis for doing so.

The contents of this statement may change from time to time so you may wish to check this page occasionally to ensure you are still happy to share your information with us.

This version of our Privacy Statement (2.2) is live from 1st January 2021.

2.       How do we collect information about you?

We collect information about you when you use our website, applications and our customer service centre. We also obtain information about you from other companies who provide services to us, such as IT service and data providers. Some of this information does not identify you personally but provides us with information about how you use our services and engage with us (we use this information to improve our services and make them more useful to you).

Personal information is collected by us in the following ways:

Website enquiry forms

We use forms placed within website pages to capture your enquiry information.

Chatbots

We use automated bots to ask you relevant questions and capture your enquiry.

A ‘chatbot’ is a computer programme that you can interact with, which simulates a conversation with a human. The chatbot may pop up on your computer screen when you visit our website, or if you visit another third-party website, but you don’t have to use it, it’s just available for you if you prefer to communicate with us in this way.

Verification

When you have paced an enquiry with us, we must make sure that the data you provide to us is verified. We use a system called Melissa to verify your name, email address, postal address and telephone number.

Live chat

Our live chat service is provided by our own specialist live chat customer service representatives although we use a third-party software provider, LiveChat Inc., to provide the technology for this service.

If you use our live chat service, we will collect the content of your live chat session which will be held by LiveChat Inc. and ourselves for up to 12 months from the date of your live chat contact.

If, during the course of a live chat, you wish to submit an enquiry for our services, we will then collect your enquiry details via live chat and transfer this data into our enquiry system so we may fulfil your request.

Consumer Satisfaction

We occasionally operate a consumer satisfaction measurement (CSM) programme by sending a SMS to consumers.

This service is provided by Textmagic, who operate an online tool for sending SMS messages.  Only if you respond to the initial SMS will you receive a follow-up text asking for any additional information. 

Social media channels

We collect data directly within social media channels including Facebook, YouTube and Google search where you have responded to an advert and completed an enquiry form within that channel. This data is submitted into our enquiry system.

By telephone

You may request our services by calling our team directly. During this telephone call, enquiry details and data collected from you will be inputted into our enquiry system so we may fulfil your request.

We may also call you following your submitting an enquiry to us online. The purpose of this call will be to collect any further information we require, to better understand your needs and provide you with the best possible service.

Our Call centre uses a cloud-based telephone system provided by Twilio. The Twilio system allows to make and receive calls; telephone calls are recorded, and we will confirm this with you at the beginning of the call. The recording of your telephone call will be used to help resolve any issues or complaints, training our staff and monitoring quality.

Occasionally, vehicle manufacturers may ask us to transfer your call directly to them so that you can discuss your enquiry with them immediately.  Dialpad is a third-party solution that we use for transferring your call to an external party.

Newsletter signup forms

Within our website, we may offer you the opportunity to sign up to receive future correspondence from us detailing services available, offers and product information.

We use a third party to provide this service on our behalf. This means that if you have consented to email marketing, your personal data will processed by Active Campaign.

Surveys

We use a third party, Hotjar, in order to better understand our users’ needs and to optimise this service and experience. It is a technology service that helps us better understand our users’ and this enables us to build and maintain our service with user feedback. Hotjar collects data on our users’ behaviour and their devices. This information is stored by them on our behalf in a pseudonymised user profile. In accordance with our obligations under data protection legislation, we have a written data processor contract with them.

Other websites

CarKeys.co.uk may include links to external websites. These links are relevant to the content they are linking from and are suitable for the likely audience. They may also offer commercial services, such as online purchases. However, we are not responsible for the content of external websites. This is because:

• We do not produce them or maintain them.
• They can be changed without our knowledge or agreement.

These links are provided for your information only and not intended to signify that we endorse any such website and/or content. It is your responsibility to check the terms and conditions and data protection policies of any other websites you may visit.

3.   What information do we collect?

The information we collect includes some or all of the following:

• Title, first and last names
• Email address
• Telephone number
• Postal address
• Vehicle(s) you are interested in/researching
• Current vehicle (if considering part exchange), including vehicle registration and mileage
• Whether you are considering a new or used vehicle
• Whether your enquiry is personal or on behalf of a business
• Business size, type and time established, company name and job title
• Current fleet size and number of vehicles required
• Purchase/leasing preferences
• Frequency of vehicle change
• Purchase timescale
• The date and time you used our services
• The pages you visited on our website and how long you visited us for
• Your IP address
• The internet browser and devices you are accessing our website from
• Cookies (please refer to the information regarding use of cookies later in this document)

If you give information on behalf of someone else you must ensure that you have their permission and that they have been provided with this Privacy Policy before doing so.

If you are under 16 please do not provide us with any of your information unless you have the permission of your parent or guardian.

4.   How is your personal information used?

Use of personal information under UK data protection laws must be justified under one of a number of legal grounds and we are required to set out the grounds in respect of each use in this policy. The following lists the grounds under which we may collect your personal data.

Consent

• Where you have consented to receiving future electronic communications from us, we will send you regular emails providing vehicle information, highlight offers and promote other services we can provide.
• Where you have consented for us to share the information you have provided with an automotive company so that they may fulfil your request. This applies where you have requested a brochure, test drive or pricing information relating to an automotive company’s products in which case we will send your information to that automotive company either directly or via their nominated data agency for the requested service to be provided.
• Where you have given consent for an automotive company to contact you in future for their own product and service marketing, we will share the information you have provided with them directly or via a data agency so they may contact you in future. Any further correspondence from the automotive company will be subject to their privacy policy.

Wherever we have processed your information using the basis of consent, you may withdraw your consent at any time by contacting us via email at datacontroller@carkeys.co.uk

Legitimate Interests

We may use and process your personal information as set out below where it is necessary for us to carry out activities for which it is in our legitimate interests as a business to do so as follows:

• Where you provide us with your personal contact information to receive a quote, brochure or to arrange a test drive, we will use this information to call you to arrange those services.
• We may also use the information you provide to us to decide if we should send your enquiry directly to the vehicle manufacturer, without the need to speak to you. We make these decisions based on how you have answered the questions on the enquiry form.  Our systems analyse your responses which helps us to understand the best way to provide our service to you.  This is called Profiling.
• We record telephone calls and live chat scripts in order to empower staff training, monitor staff performance and to provide evidence in case of any dispute. For these purposes, we may share details of the call (or an edited version) with the relevant automotive company, vehicle leasing company or their agencies. This data will only be processed within the UK and EEA.
• We use website activity monitoring and user tracking functionality to evaluate and improve our products and services so that your visit and use of our website, applications and customer service centre are more useful and enjoyable (we will generally use data amalgamated from many people so that it doesn’t identify you personally).
• To undertake market analysis and research (including contacting you with customer surveys) so that we can better understand you as a customer and provide tailored offers, products and services that we think you will be interested in. We will only send marketing communications to you if you have provided your consent for us to do so. All communications will provide a clear mechanism for you to opt-out of receiving any further correspondence from us.
• To identify and record when you have received, opened or engaged with our website or electronic communications.
• To respond to queries, complaints or claims and to manage legal and regulatory requests and requirements.
• To verify the accuracy of information that we hold about you and create a better understanding of you as a customer.
• To comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request).
• If you are a social media user, we may use certain social media tools for marketing purposes. We may use the information which we hold about you to show you relevant advertising on third party sites. These tools include such things as Facebook ‘Custom’ and ‘Lookalike’ Audiences.

Through using these tools, we may provide some of your data to the social media platform in anonymous form to allow us to identify those with similar characteristics to you who we think may also be interested in finding out more about our service.  It is in the legitimate interest (including commercial interests) of Carkeys to process data in this way.  We believe that this legitimate interest is not overridden by your rights and freedoms under the GDPR, and the processing does not have any adverse effect on you.  However, you may object at any time to this processing.  

5.   How do we keep your personal information safe?

We use technical and organisational security measures including encryption and authentication tools to protect your personal information, against manipulation, loss, destruction, and access by third parties.

All personal information we collect is stored securely within the UK and Ireland.

For the purposes of verifying the accuracy of some information you have provided, we may use third parties. We take steps to ensure that any third-party partners who handle your information comply with data protection legislation and protect your information just as we do. We only disclose personal information that is necessary for them to provide the data validation service that they are undertaking on our behalf.

International transfers

There will be instances where, through using third party software systems and service providers to verify the accuracy of information you have provided, some information will be processed in the USA. In those instances, we will ensure that appropriate safeguards (including standard contractual clauses) are in place for that transfer and storage as required by applicable law.

6.   How long do we keep your personal information for?

The personal data that we hold about you will be retained for a period of 12 months following our last contact with you, at which point it will be securely destroyed.

Within this 12 month period, we may contact you to follow up any initial enquiry you submit to us and to evaluate the service you received.

If you have opted-in to receive further electronic communications from us, you will be given the opportunity to opt-out at any time via links contained within any communication.

Call recordings and any online conversation transcripts are kept for a period of 12 months after which time they are securely destroyed.

7.   How can you manage the information we hold about you?

In accordance with data protection legislation, you can make a request to us for the personal information we hold about you. This is called a ‘subject access request’. If we do hold information about you, we will:

• give you a description of it;
• tell you why we are holding it;
• tell you who it could be disclosed to; and
• let you have a copy of the information in an intelligible form.

We will provide you with the information to which you are entitled within one month of your request. However, we will need to check who you are and therefore we will ask you for proof of identity. We do this to protect your personal information from being disclosed to anyone who should not have access to it.

Under data protection law, you have a number of further rights in relation to control over the personal information we hold about you as follows:

• You may ask us to correct and update your information.
• You may withdraw your consent (where we rely on it – please refer to ‘How is your personal information used?’). Where you have consented to receive any direct electronic marketing from us, you may withdraw your consent at any time using either unsubscribe links or instructions contained within our correspondence.
• You may object to our use of your information (where we rely on our legitimate interests to use your personal information) provided we do not have any continuing lawful reason to continue to use and process the information.
• You can ask us to erase your information (or restrict the use of it), provided we do not have any continuing lawful reason to continue to use and process that information.
• You can request we transfer your personal information in a structured data file (in a commonly used and machine-readable format).

We will respond to any request you make regarding these rights within 1 month. You can exercise the above rights and/or manage your information by contacting us using the details below.

Post: Data Controller, Carkeys.co.uk, 13^th Floor, 20 Chapel Street, Liverpool L3 9AG

Email: datacontroller@carkeys.co.uk

8.    What if you have a concern or complaint?

By using this website, you signify your acceptance of this policy. Your continued use of the website following the posting of changes to this policy will be deemed your acceptance of those changes.

If you have any concerns or wish to make a complaint to Carkeys.co.uk regarding use of your personal data, please contact us at  datacontroller@carkeys.co.uk

If you remain unhappy you have the right to lodge a complaint with the Information Commissioners Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF or visit www.ico.org

9.   About our use of Cookies

What is a Cookie and what do they do?

A cookie is a text file that is put on your device (computer, laptop, notebook etc.) when you visit a web site. Cookies can give users of web sites a better experience and make them work more efficiently. Without cookies, it would be very difficult for a web site to remember the user's preferences or registration details for a future visit.

We use cookies in a number of different ways to ensure that every visit is smooth, helpful and informative. We sometimes use third party cookies. We have outlined below the type of cookies that we use; those that are strictly necessary for the site to function, those that are used to enhance the performance of the site, those that remember your choices to provide enhanced features and allow the site to function better for you, and those that help the site to provide a more personal (targeted) experience by gathering information about your browsing habits, for example, by remembering a website that you’ve visited.

Strictly Necessary: These are cookies that are necessary. If you don’t allow these cookies, then you won’t be able to use our website.

Analytical/Performance: These cookies allow us to count visits and traffic so that we can improve the performance of our site and the therefore improve the customer experience. If you don’t allow these cookies, then we won’t know which pages are the most (and least) popular.

Functionality: These cookies allow the website to provide better functionality and personalisation. If you don’t allow these cookies, then some parts of the website may not work properly.

Targeting: These cookies and similar technologies help personalise content. Whilst these cookies and similar technologies can track your visits to other websites, they don't usually know who you are.

How do I manage cookies?

You can modify your browser settings so that it notifies you when cookies are sent to your device. This will allow you to manage the cookies that are set from using this website. 

You can refuse cookies altogether, however in doing so, you may not be able to use the web site at all or some parts of the web site won’t work properly.

Here’s how you manage cookies in the various major browsers:

MICROSOFT INTERNET EXPLORER

GOOGLE CHROME

MOZILLA FIREFOX

APPLE SAFARI

For more information on cookies and how to manage them please go to www.allaboutcookies.org or www.aboutcookies.org.

To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout

If you have any questions or comments on this Cookies Policy, then please contact: enquiries@carkeys.co.uk.

If you have any questions or comments on this Cookies Policy, then please contact: enquiries@carkeys.co.uk