ABOUT THIS NOTICE
- any customer(s) of the dealership including any named drivers
- any dealership engaged in using the CSL products and services
- all employees of the dealership
- any customer or potential customer of CSL
- any user of the CSL websites
Your privacy is important to us and we are committed to keeping your information secure and managing it in accordance with our legal responsibilities under applicable data protection laws.
This Privacy Notice provides details of the personal information (personal data) we collect from you, why do we do it and what we do with it. This Notice also explains your data protection rights and how to get in touch with us.
Please note that CSL is part of PIB Group whose companies act as Data Controllers. You may also wish to refer to the PIB Group Privacy Notice for additional information about handling your data at Group level. This can be found here https://www.pibgroup.co.uk/privacy-policy or see written contact details below to ask for a written copy.
In some circumstances CSL may be a Data Controller, but we will mostly be a Processor handling data on another organisation’s behalf.
If you need help in deciding who is your Data Controller and therefore responsible for looking after your personal data, please send an email to firstname.lastname@example.org and we will endeavour to help.
We ask that you read both of the Privacy Notices before providing us with any personal information.
We continually review and update this Privacy Notice to reflect changes in any of our services as well as to comply with changes in Data Protection Laws and Legislation. We would, therefore, encourage you to review this Notice on a regular basis.
OUR CONTACT INFORMATION AND DATA PROTECTION OFFICER
Coopers Solutions Limited is a subsidiary of PIB Group Limited. Our Data Protection Officer can be contacted directly here:
Data Protection Officer
PIB Group Limited
London, EC3R 7AA
0330 058 9700
WHY DO WE COLLECT AND USE YOUR PERSONAL INFORMATION
We process personal information which you give us:
- To provide you with the products and services you have requested
- Whilst servicing your request through our website, in writing or over the phone
- If you request information or assistance from us
WHAT PERSONAL INFORMATION, (SOMETIMES KNOWN AS “PERSONAL DATA”), DO WE PROCESS
If you provide us with personal data about other people, for example: family members you wish to add to a policy or contract, we expect you to ensure that they know you are doing so and they are content with their information being provided to us.
As a minimum if you use a simple contact form on our website, you will be providing us with your name, address, telephone number and email address.
When payment is made via credit or debit card, your card details will be processed by our nominated third party.
If you use the chat function on any of our websites, your discussion will be captured by our third-party chat provider and retained by them and us for a short period of time in accordance with data protection law.
Depending on the product you use, we will process the following personal data and information:
|Product||Categories of Information Processed|
We will process any driver’s contact details, vehicle details, signature and any information included on a driving licence. This is for the purposes of administering insurance cover.
We will also process the dealership employee contact details for administering the service.
|FullCompliance||Where enhanced fleet management services are being provided, we will process the dealership employee’s contact and customer vehicle details. If insurance is arranged through our platform, we will process any information included on a driving licence.|
|FullControl||We will process customer contact details in order for dealership employees to provide vehicle information to their customer. We will also process the dealership employee contact details for administration of the service.|
|FullForecast||We will process customer contact and vehicle details in order for dealership employees to provide vehicle information to their customer. We will also process the dealership employee contact details for administration of the service.|
|FullCycle||We will process dealership provided customer contact details and vehicle details to allow the dealership to better improve their services. We will also process the dealership employee contact details for administration of the service.|
|FullAuction||We will process the dealership employee contact details for provision of the service.|
|FullAppraisal||We will process the customer’s contact details, vehicle details and signature in order to allow the dealership to provide customer vehicle appraisals and fulfil any contractual requirements. We will also process the dealership employee contact details for administration of the service.|
SPECIAL CATEGORY AND CRIMINAL CONVICTION PERSONAL DATA
Special categories of personal data include information about an individual’s health and other categories of personal information which are closely protected.
We do not generally process such information unless you have voluntarily provided this to us. For example, where you have advised us of a health issue, which could mean that you may be classed as a “vulnerable”. We will process sensitive information where you have voluntarily provided this information to us and have agreed that we can use this information to deliver services to you. Where possible we shall seek to minimise the collection and use of such special categories of personal data.
Criminal convictions may be collected and processed where we have obtained your consent and the law permits this, such as for insurance purposes.
WHAT WE DO WITH YOUR PERSONAL DATA AND WHY WE ARE ALLOWED TO DO IT
We will use your information to enable us to provide you with the products and services you have requested.
We will only process your personal data for the purpose for which it is collected. If you use our services or request information, we collect your personal data for use by PIB Group Limited and subsidiary companies including us. We use this personal data for the provision of information and services or the performance of the contract.
We may use your personal data for other similar purposes, including marketing and communications, but that will only occur if we have your consent or where, as a current or previous user of our services, we are otherwise able to do so by law. You have a right at any time to stop us from contacting you for marketing purposes. Please contact us to do so – see above.
The way insurance works means that, If you have a contractual or service relationship with us, your information may be shared with and used by, a number of third parties in the insurance or risk sector; for example, insurers, agents or brokers, reinsurers, loss adjusters, sub-contractors, specific service providers, claim management companies, credit reference agencies, regulators, law enforcement agencies, fraud and crime prevention and detection agencies and compulsory insurance databases. We will only disclose your personal information in connection with the contract or service that we provide and to the extent required or permitted by law. Due to the fluid and complex nature of the relationships, you can find out details relating to the processing of your personal data used by any third parties we use, by contacting the Data Protection Officer above.
More detailed information on how the Insurance market works and transfers data, is available from the London Insurance Market Core Uses Information Notice available here
We may record or monitor calls for training purposes, to improve the quality of our service and to prevent and detect fraud. We may also use CCTV recording equipment in and around our premises.
In order to meet your service needs and fulfil our contract with you, when we process the above-stated personal data information collected, we ensure that we have a legal basis permitting us to do this. This will depend on the reason and activity for which we are processing it and we have broken this down below.
|ACTIVITY THE PERSONAL DATA COLLECTED IS ASSOCIATED WITH||LEGAL BASIS|
|Providing a service and internal processing|
|To assess your needs and provide you with products and services|
Legitimate interest and/or contract to provide and manage the product and service and to ensure the contractual relationship is appropriate
Where special categories of personal data are processed, these are necessary to assess your needs
|To service and administer your requests||Legitimate interests and/or contract to provide and manage the service|
|To confirm, update and improve our customer records||To comply with legal obligations in the data protection legislation|
|To provide you with any information on the services that you have requested||Legitimate interests and/or contract to provide information on the services you have requested|
|To inform you of products and services that may be of interest to you, where you have chosen to be made aware of this||Legitimate interest to provide information on the services you have requested|
|Training and development|
|For training purposes and to improve our service to you||Legitimate interests to improve our services and develop our employees|
|Complying with Legal Obligations|
|To prevent, investigate and prosecute crime, fraud and money laundering||To comply with legal obligations for prevention of financial crime and money laundering|
|If we are obliged to disclose information by reason of any law, regulation or court order||To comply with legal obligations|
|For any other purpose we bring to your attention and to which you agree.||With your consent|
HOW DO WE LOOK AFTER YOUR PERSONAL DATA
We only collect personal data that is required for use in the activities described above. We restrict, secure and control all the data we hold, against unauthorised access, damage, loss or destruction; whether physical or electronic. We retain personal data only for as long as is necessary to perform the functions above and to respond to your requests, or longer if required by law, or if we need to retain the data to perform a contract. If we retain your personal data for historical or statistical purposes, we will ensure that the personal data cannot be used for any other purpose. Whilst in our possession, together with your assistance, we try to maintain the accuracy of your personal data.
We will retain your personal information in accordance with our legal obligations and business needs as follows:
|Product Subscription||Retention Period|
|FullCover||7 Years + current year|
|FullCompliance||6 Years + current year|
|FullControl||4 Years + current year|
|FullForecast||6 Years + current year|
|FullCycle||Set by each individual dealership subscribed to the product. Please consult with the dealership you are dealing with.|
|FullAuction||Set by each individual dealership subscribed to the product. Please consult with the dealership you are dealing with.|
|FullAppraisal||Set by each individual dealership subscribed to the product. Please consult with the dealership you are dealing with.|
HOW WE SHARE YOUR INFORMATION
|FullCycle||We will share customer vehicle details with our nominated third party in order to provide vehicle finance information. Where instructed us to do so by the dealership, we will share customer vehicle details with the dealerships nominated Service Plan provider in order to provide customer service plan information to the dealership.|
|FullAuction||Once an auction has finished, we will share the successful bidder and sellers’ /employee contact details with each party to enable the sale to be finalised between both parties.|
|FullAppraisal||In order to provide vehicle valuations, we will share customer vehicle details with our nominated third party. We will also share customer transaction details with any of their nominated third-party providers as instructed by the dealership.|
There may be occasions where the nature of the processing requires the processing to take place outside the UK or EEA. If this is the case, we will always adhere to all data protection legislation, including having contractual terms in place and where appropriate ensuring there are adequate safeguards in place for international transfers.
ADDITIONAL INFORMATION ABOUT PROCESSING YOUR PERSONAL INFORMATION
We may collect information about your mobile phone, computer, or other device from which you access our websites including, where available, your IP address, operating system and browser type, for systems administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns and does not identify any individual. We may, however, use such information in conjunction with the data we have about you in order to track your usage of our services. We do this so as to improve your customer & dealership experience, so that we can improve our services to you. We consider this is on both our legitimate interests to do so.]
For the same reason, we may obtain information about your general internet usage by using a cookie (a small text) file sent from our website and stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help us to improve the Website and to deliver a better and more personalised service. They enable us:
- To estimate our audience size and usage pattern.
- To store information about your preferences and so allow us to customise the Website according to your individual interests and improve your interaction with us.
- To speed up your searches.
Unless we specifically share your personal data, as stated above, where we include links to other websites, those websites have their own data protection obligations and are not and cannot be governed by our Privacy Statement. We cannot guarantee your privacy when you access other websites through any link provided on our website.
You have the right to request copies of your personal information within our custody and control and details of how we use that information. If you think any of the personal information we hold about you is inaccurate, you may also request for it to be corrected. If you consider we are no longer entitled to hold your personal data, you can also ask for to be erased. You also have a right, in certain circumstances, to object to our processing of your personal information, to require us to port your personal data electronically, to require us to stop processing your personal information and/or to withdraw your agreement to processing based on ‘consent’. However please be aware that there may be legal justification for us to continue processing your data.
To exercise any of these rights, please write to us at the address above.
DATA PROTECTION COMPLAINTS PROCESS
If you have a complaint about how we have handled your personal information, we hope that you will first give us an opportunity to investigate your complaint. You also have the right to complain to the Information Commissioner’s Office (www.ico.org.uk), which regulates the processing of personal data.