Summary

As part of your dealings with All Car Parts Limited we will collect and otherwise process personal information about you in order to supply goods and services to you and to administer our relationship with you. This may involve sharing your personal information with third parties and other Vertu entities. This Privacy Policy describes in detail how we will use your personal information and how you can exercise your rights with respect to your personal information.

If we decide to change this Privacy Policy, we will post the updated Privacy Policy on our websites so that you are always aware of what personal information we collect, how we use it and under what circumstances we disclose it. The updated Privacy Policy will take effect as soon as it is posted on our Websites.

Introduction

In this Privacy Policy, references to we, us or our (or words of similar import) means All Car Parts Limited being the entity that processes your personal information (as defined below) and interacts with you (for example, the entity from whom you purchase goods or other services).

All Car Parts Limited is a member of the group of companies of which Vertu Motors plc is the holding company (each company being a Vertu entity) and we operate using different trading names.  The documents you receive from any Vertu entity will identify the relevant Vertu entity that you are dealing with in any particular instance.

Trading names for All Car Parts Limited include:

• AceParts
• All Car Parts
• CarBulbsDirect
• PowerBulbs
• WiperBlades
• WSW WindscreenWipers

and for the purposes of this Privacy Policy All Car Parts Limited and the Vertu entities shall constitute the Vertu Group.  Other Vertu entities which are part of the Vertu Group have separate privacy policies which can be found on their websites. 

In this Privacy Policy, references to you mean the person whose personal information (as defined below) we collect, use and process. This includes anyone who visits our Websites, contacts us in connection with the purchase of any goods or services we provide or otherwise interacts with us (for example, via a physical or virtual store).

In this Privacy Policy, references to a Website means any website owned and operated by or on behalf of All Car Parts Limited including websites of our stores operating with any of our trading names.

We are committed to protecting your privacy. We will use your personal information in accordance with the Data Protection Act 2018 and the UK GDPR (as defined in The Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019 both as amended from time to time (together the Data Protection Legislation) and other applicable laws and regulations that relate to data protection and privacy.

Who is responsible for your personal information?

For the purposes of the Data Protection Legislation All Car Parts Limited is the data controller in respect of your personal information that we collect and process as further described in this Privacy Policy. All information is stored on a group database so will be shared with other organisations in the Vertu Group who may act as data processors.

We may share your personal information with other organisations that may receive and process your personal information as a data controller in their own right. Please see below for further information.

What information do we collect?

We may collect and process information about you, including your name, date of birth, address, contact details (including email address and mobile phone number), vehicle details, purchase history , online history on our Websites and data collected as part of any payment (including previous addresses, bank account and credit or debit card details). This information is referred to in this Privacy Policy as personal information.

In particular, we may collect and process the following personal information about you:

• Information that you provide by filling in forms, including those on our Websites and those on third-party websites that contain advertisements for our goods, and information provided by you as part of a purchase or potential purchase on our Websites including purchase and payment processing by our transaction and payment providers, even if that purchase does not proceed and information provided by you in response to our or third-party surveys and as feedback.
• When you enquire about or purchase goods or services we collect personal information to respond to your enquiry and to process and complete your purchase.
• Details about the transactions you carry out with us including vehicle support services and purchases of goods.
• CCTV footage in which you feature when you visit our premises.
• Information contained in records of communications between us, including e-mails, letters and text messages. We may also record calls between us for training, monitoring and quality control purposes. Our telephone system is set up in such a way that all calls in and out of our contact centre are recorded. These are kept for a period of 13 months. If a call is made to or from our contact centre but gets transferred to a dealership or another head office department, then the recording terminates at the point of transfer.
• Details of your visits to our Websites, including, but not limited to, information you input into forms/fields on our Websites, traffic data, location data (including the country and telephone area code where your computer is located), IP (internet protocol) address, browser and operating system information, and the resources that you access (including the pages of our Website that you view, the website from which you access our Website, and goods and services that you are interested in). For more details of how we collect data through the use of cookies, please see the separate cookies policy on our Websites. You may be able to disable the collection of some of this data through amending the web settings of your device or browser but doing so may impact the functionality of our Website.
• Details of your device and Google ID if you SMS "sign" or open a document that we send to you by SMS or click on a link in an email we send to you.
• Information concerning your marketing preferences where these rely on consent.
• If you follow or comment on social media posts from or shared by the Vertu Group, we may collect details that are part of your public profile on social media sites.
• Details supplied by you as part of a competition or prize draw entry.
• Your details and details of your current vehicle when you provide details to us on one of our Websites.
• If you sign up for an account on one of our Websites, details of the goods that you have searched for, obtained quotations on or saved to your account.

There may be circumstances when we collect special categories of personal data regarding your health, sexual orientation or criminal convictions, if you provide this information to us as part of a discussion regarding your vehicle or vehicle enquiry.

If you provide us with personal information about another person, you must ensure that before you provide us with their personal information, you have their agreement to do so and that they are aware of the ways in which we use personal information as set out in this Privacy Policy.

We may collect and process information we receive about you from third parties. This information may include your personal and financial information, your employer, companies that you are connected with (such as a Director) or other person connected with your finance application; any business accounts you have and public information such as County Court Judgments, bankruptcies and the Electoral Register.

We may also collect information about your preferences in connection with our Websites and your activity on our Websites, for the purposes of enhancing and personalising your experience on the Websites. We may provide our manufacturer partners, suppliers and our advertisers with aggregate information about Website users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience.

How do we use your personal information?

We use your personal information in connection with our business activities. In particular, we may use your personal information in the following ways:

• to respond to queries from you regarding the possible purchase of goods or services, including looking at your searches and history on our Websites prior to an enquiry and combining the data held on our systems with your activity on our Websites and your Google ID;
• to carry out our obligations arising from any contracts entered into between you and us including purchase of goods and provision of services, and to respond to queries from you regarding those contracts;
• to manage and administer the relationships between you and us (or one or more of the members of the Vertu Group);
• to notify you about changes to our services and to otherwise communicate with you; for example, we will use your contact details in order to respond to any queries that you submit to us;
• to obtain feedback from you regarding us and the manufacturer of your goods;
• to provide you with information regarding other services and products that are available to you from us or third parties, including follow up calls, SMS and / or email to establish your interest in any such products and, where we have targeting cookie consent, driving or suppressing targeted online advertising;
• to provide you with reminders regarding your vehicle including, for example, when your vehicle may be due for replacement parts; and
• to offer assistance with your transactions with us where you have partially, but not fully, completed an online transaction or enquiry (i.e. you have provided your details or logged in to your Website account, you have consented to targeting cookies, you have clicked on a page on our Website originating from a link sent to you, or added items to a basket but have not completed a purchase).

If you enquire about any goods or services or add items to a basket we will use your information to contact you for up to 1 month about that potential purchase (and target advertising to you where you have accepted targeting cookies).

If you go ahead and purchase any goods or services from us we will use your information in various other ways, details of which are provided to you at the time of your purchase. These include:

• contacting you to obtain feedback on your purchase or other services provided;
• contacting you in the future with reminders about your vehicle and / or goods;
• use or supress targeted advertising to you

If you have a Website account, we will use the information contained within it to contact you regarding items you have expressed an interest in, or similar items.

All of the above are examples of where we believe that we have a legitimate interest in using your data (apart from the specific consents referenced).

In accordance with your preferences and cookie consents, we may also use your personal information to provide you with additional information about vehicles, services, promotions and offers that may be of interest to you including those relating to the rest of the Vertu Group, which may be based on data held about you.  The preferences set within your Website account will apply only to communications sent using that account information and, if you are also a customer of the Vertu Group, you will have separately stored preferences in that capacity.  

The section below entitled "What choices do I have?" explains how you can change whether to receive information from us that is based on consent/preferences. Please note that, even if you choose not to receive this information, we may continue to use your personal information in the ways described above and below.

Your personal information may also be used by us, our employees, contractors or agents, and disclosed to third parties, in order to comply with any legal obligation (including in connection with a court order), or in order to enforce or apply the terms of any agreements we have with or otherwise concerning you (including agreements between you and us (or one or more Vertu entity), to investigate or prevent suspected crime or fraud, or to protect our rights, property or safety or those of our customers, employees or other third parties.

In addition, 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.

How do we make decisions using your data?

We will use your information to carry out automated decision-making and profiling in some circumstances. For example, reminders will be automatically sent where relevant based on the vehicle, the goods and maintenance information we hold. We will also select customers for marketing campaigns and offers based on factors such as age of vehicle, type of vehicle and date since last purchase of goods as well as previous responses to marketing campaigns and Website activity.

We may use your offline and online history to drive or supress targeted online advertising, in accordance with our cookie policy.

How long do we keep your personal information?

We will not retain information longer than we need to. In general, if you enquire (in person or by creating a Website account) but do not purchase goods or services from us, we will keep your information for 2 years to enable us to deal with future enquiries more effectively and to deal with any concerns regarding the enquiry process. If you purchase goods or a service from us, or have servicing or repair work carried out, or purchase apart from us, we will keep your information (and your Website account will remain live) for 7 years from your last transaction with us. We may keep details of a vehicle for longer than that but without it being attached to your information.

With whom do we share your personal information?

In connection with the above uses of your personal information, we may share your personal information with third parties as described below. We will share your personal information with other Vertu entities in the Vertu Group for the purposes set out above and below.

We may disclose your personal information to third parties in connection with our business activities, including in the following circumstances:

• Your personal information may be passed to or collected by third-party organisations that provide services to us such as software providers, web-hosting companies, mailing vendors, analytics providers, prospecting agencies and marketing agencies, IT providers (including data storage, data security, data integration, accounting, analytics), telephone service providers and any third party to whom we sub-contract work (such as repairs or specialist fitting) or who provide services or offers to our customers on our behalf.
• Your personal information may be passed to or collected by our purchase and payment processing providers (including Shopify International Limited, Paypal UK Limited, Stripe Inc., Sage Group plc) to assist with our online stores and commerce services. These providers may be located in other countries and your details may be passed outside of the European Economic Area, in order to provide these services to you including, but not limited to, transaction processing and fraud prevention.
• We may share your name and contact details with Facebook and other social media sites to enable them to identify you as a customer of the Vertu Group and to assess criteria such as age and location to assist with our marketing on social media. We do not receive any details from Facebook that we do not already hold and the data would be used in a generic way only to target advertising.
• We may share your details with Google to enable Google to identify you to drive or supress targeted advertising, if you have consented to targeting cookies we will be able to match your online device history to other offline information we hold if you have clicked on an email or SMS link sent to you.
• We may pass personal information to external agencies and organisations (including the police and other law enforcement agencies) for the purpose of preventing and detecting fraud (including fraudulent transactions) and criminal activity. We may also disclose personal information to the police and other law enforcement agencies in connection with the prevention and detection of crime. We will pass your personal information to third-party providers of insurance products that we offer, if you consent to being provided with an indicative quotation for and / or take up the option of purchasing one of those products.
• In the event that we sell or buy any business or assets (including car dealerships), we may disclose personal information held by us about our customers to the prospective seller or buyer of such business or assets. If we or substantially all of our assets are acquired by a third party (or subject to a reorganisation within our corporate group), personal information held by us about our customers will be one of the transferred assets.
• We may pass your personal information to third parties if we are under a duty to disclose or share your personal information in order to comply with any legal obligation (including in connection with a court order), or in order to enforce or apply the terms of any agreements we have with or otherwise concerning you (including agreements between you and us (or one or more members of the Vertu Group); or to protect our rights, property or safety or those of our customers, employees or other third parties.
• We may pass your personal information to third parties for the purpose of customer data management. This could include activities designed to support data accuracy by cleansing and updating existing records, correcting database errors and identifying if you have recently moved, or if there is a recent change in your personal details or circumstances that may affect our relationship with you.

We may share non-personal aggregate statistics (group) data about visitors to our Websites, sales and traffic patterns with members of the Vertu Group and other third parties.

Protecting your personal information

Our security procedures mean that we may occasionally request proof of identity and address before we are able to disclose sensitive information to you.

The transmission of information via the internet is not completely secure; this risk is not specific to our Websites and is common across the internet. We cannot guarantee the security of your data (including your personal information) transmitted to our Website; any transmission is at your own risk.

What choices do I have?

If you think the personal information we hold about you is inaccurate or incorrect, you can request that we correct this information (including your marketing preferences) by writing to us using the details below.

You can choose to stop receiving marketing emails or SMS messages from us by following the unsubscribe link and instructions on the respective marketing emails or SMS messages we send you. You can also ask us to stop including you in marketing campaigns using profiling by writing to us using the details below.

You can also choose to change your marketing preferences by writing to us using the details below.

These changes will not prevent all uses of your information (where we believe we have legitimate interests to use it) but if you are concerned about this you can ask us to stop all contact with you.

Access to your personal information

The Data Protection Legislation gives you the right to access your personal information. To request access to your personal information, please contact us using the details below.

Right to be forgotten

You have the right to request that Vertu Group delete your personal data in certain circumstances if you would like more information about this please contact us using the details below. If you have purchased goods or services from us we will retain details of your purchase for 7 years. If we are unable to delete your data as we believe that we are required to retain it, we will delete as much information as we are able to and will also stop sending you any further information.

Third Party sites

Our Websites contain links to other websites. This privacy policy applies only to the All Car Parts Limited websites, so visitors should always be aware when they are moving to another site including those provided by other Vertu entities and read the privacy statement of any site which collects personal information. We cannot be responsible for the privacy policies and practices of other sites even if you access those using links from our Websites.

We do not pass on any personal information about our visitors to any other site (unless we have obtained your consent to do so). In addition, if you linked to a Website from a third-party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party site and recommend that you check the policy of that third party site and contact the owner or operator if you have any concerns or questions.

Transferring your information outside of Europe

As part of the services offered to you through the Website, the information which you provide to us may be transferred to countries outside the United Kingdom and outside the European Economic Area (EEA). By way of example, this may happen if any of our servers are from time to time located in a country outside of the EEA. If we transfer your information outside of the EEA in this way, we will take steps to ensure that it is to a country with data protection laws which are at least as stringent as those in England or we will put in place appropriate 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. These safeguards may include obtaining contractual assurances from any third party given access to your personal information that your personal information will be protected by standards which are equivalent to those that protect your personal information when it is in the EEA.

If you use our services while you are outside the EEA, your information may be transferred outside the EEA in order to provide you with those services.

Cookies

Our Websites use cookies. A cookie is a small file of letters and numbers that we put on your computer if you agree. These cookies allow us to distinguish you from other users of our Websites, which helps us to provide you with a good experience when you browse our website and also allows us to improve our Website. Details of the cookies used and how we use the information we obtain are set out in our cookie policy under ‘Information: Privacy/Cookie Policy’. You will be asked to set cookie preferences when you access one of our Websites for the first time.

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.

How to contact us

If you have any questions, comments or requests regarding this Privacy Policy, please feel free to contact us by writing to us at: Data Protection Officer, Vertu Motors plc, Vertu House, Fifth Avenue Business Park, Team Valley, Gateshead, Tyne & Wear, NE11 0XA or emailing on datacontroller@vertumotors.com.

You also have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.