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Privacy Policy

Privacy Policy

This Privacy Policy lets you know what happens to personal data that you provide to us or that we may collect about you. We hope that the following sections will answer any questions that you may have but if not, please get in touch with us. 

This Policy was last updated on 18 May 2018 to take into account new requirements under the General Data Protection Regulation regarding how we inform you about the ways in which we use your personal data, and your rights in relation to that data. Any changes we may make to this Policy in the future will be posted on this page. You can also obtain an up to date copy of this Policy from any dealership or by contacting us using the details set out in section 1 below. 

This Policy applies only to personal data processed by or on behalf of the Rybrook Group. We represent a number of vehicle brands and we share some of your information with the relevant manufacturer. For details of the manufacturers’ privacy policies please visit their websites.

 

1. About us and how to contact us

In this Policy “Rybrook Group”, “we” or “us” refers to each of Rybrook Holdings Limited and its subsidiary companies. Our operating companies are:

  • Rybrook Limited
  • Rybrook Cars Limited
  • Rybrook Motors Limited
  • Rycliff Cars Limited
  • Rybrook Services Limited

You can find the details of the Rybrook Group company that you are dealing with using the information set out in Appendix A. 

You can contact us on any matters relating to your personal data by emailing data@rybrook.co.uk or by writing to Data Compliance, Rybrook Holdings Limited, 6 Athena Court, Athena Drive, Tachbrook Park, Warwick, CV34 6RT.

 

2. What personal data do we collect and why 

We collect information from you when you visit our website or dealership locations, purchase something from us, enquire in person about our products (vehicles, parts and accessories) or services, contact us by telephone, email or other means, or respond to a communication from us. We may also receive information about you from the relevant manufacturer. The provision of information to us is largely voluntary; however, if you do not provide us with Transaction information or Preference information, we may not be able to fulfil your order or provide you with updates.

Contact information

  • Name
  • Address
  • Email Address
  • Telephone Number

Vehicle information

  • Your new and/or existing car registration, mileage, service history, vehicle history and vehicle diagnostic data.

Test Drive information

  • Contact information
  • copy of your driving licence

Transaction information

  • Contact information, together with purchase details, delivery details, payment details, your driving licence (or other forms of identification), any relevant Vehicle Finance information, any communications we have about your purchase.

Vehicle Finance information

  • If you require finance for your vehicle purchase, we will need further information such as proof of address, previous addresses, number of dependants, your marital status, your occupation, your employer, your bank details and any other relevant information requested by the finance provider.

Sensitive information

  • Information relating to medical conditions and/or any disability where necessary to enable us to assist with specially enabled vehicles for those eligible.

Legal information

  • Fraud checks or flags raised about your transactions, payment card refusals, complaints, copies of documents you provide to prove your identity where the law requires this (eg driving licence).

Preference information

  • Your marketing preferences, your account settings including any default preferences, any preferences we have observed, such as the types of offers that interest you, or the areas of our website that you visit.

Communications

  • Communications we may have with you, whether relating to a transaction or not. Please note that we normally record calls to and from our dealership sites.

Voluntary information

  • Any voluntary information you provide us with, such as hobbies and interests, and responses to surveys or competition entries.

Observed information

Details of your online browsing activities on our website, such as the pages, products or areas of our website that you visit, or which link has brought you to our website from our email communications or third party websites. This includes the new and used vehicle searches that you perform on our website.

This information may be identifiable to you because you are logged in to your account, or because we have collected details of your IP address or the device that you have used to access the website. This may also give us the geographic region which your device reports that you are located in. CCTV footage at our dealership premises.

We use the data we collect about you for various purposes. European data protection legislation sets out specific “lawful bases” for processing personal data. The basis on which we process different information about you and the purpose of that processing are explained below.

 

Lawful basis and purpose What personal data do we use

Consent: To send you direct marketing in accordance with the preferences you select when you sign up to receive updates, purchase products, or via our preferences centre https://www.rybrook.co.uk/update-personal-information.

  • Contact information
  • Preference information
  • Communications
  • Voluntary information

To use cookies or other similar technologies, as more fully described in our Cookies Statement https://www.rybrook.co.uk/cookie-policy.

  • Observed information

Entering into and performance of our contract with you: To discuss and negotiate a transaction (including arranging test drives), fulfil your order, take payment and deliver your products or services to you, to deal with any complaints or any after sales services, including for warranty purposes.

  • Vehicle information
  • Test Drive information
  • Transaction information
  • Preference information
  • Communications
  • Voluntary information

To share information with financial providers should you require vehicle finance for your purchase.

  • Vehicle Finance information

Should you require a specially enabled vehicle, we will process your Sensitive information to ensure that you receive the correct vehicle.

  • Sensitive information

Complying with legal obligations: To confirm your identity, keep records required by law or to evidence our compliance with laws, including tax laws, consumer protection laws and data protection laws. To provide information to law enforcement agencies or other authorities where we are required to do so, including in the event of any offences committed while driving one of our vehicles.

  • Potentially any category (where relevant)

Our legitimate interests: For our internal business administration, to manage customer accounts, including keeping general records of customers, sales, customer care and other interactions, and to protect genuine customers and our business from fraud. This is necessary in order for us to operate efficiently, deal with any issues which may arise and to protect ourselves against any future legal claims and ourselves and others against fraudulent transactions.

  • Vehicle information
  • Transaction information
  • Legal information
  • Preference information
  • Communications

Where you are an existing customer or have been in discussions to purchase products or services, to provide you with updates and promotional offers about our products and/or services, MOT/Service reminders and invitations to events, where you have not opted out of receiving such communications from us. This is necessary to support our commercial objectives. We will ensure that we are providing you with relevant details of our products and services where these are of interest to you. They will only ever be sent in line with your stated preferences and interests and you can update your preferences at any time.

  • Contact information
  • Preference information
  • Communications
  • Voluntary information

Similarly, if you are not an existing customer but have previously enquired about our products or services, to market to you by post or telephone unless you have asked us not to do so.

  • Contact information
  • Preference information
  • Communications
  • Voluntary information

To manage any competitions or other promotions that you have chosen to participate in.

  • Contact information
  • Preference information
  • Communications
  • Voluntary information

To target our direct marketing: This means that we use the information you provide us with and that we observe from your interactions with us to build a better picture of the type of offers we can provide which you might be interested in, so that the communications you receive are more relevant to you. We believe this is justified as you are in control over whether you receive our direct marketing (through our preference centre and each time we contact you) and you can restrict our use of cookies.

  • Transaction information
  • Preference information
  • Communications
  • Voluntary information
  • Observed information

To improve our marketing activity more generally: This means we use information about you and about our other customers to work out what is working and what is not in terms of our marketing activity or our sales performance, so that we can develop our websites and offers to be more relevant to our customers generally, to improve your online experience and the services we offer. We will also use information provided by your device to recommend the intended geographic website for the location it reports you as being in. Where possible, we will use statistical or pseudonymised data for these purposes. 

  • Transaction information
  • Preference information
  • Communications
  • Voluntary information
  • Observed information

To safeguard our premises and property.

  • Observed information (including CCTV footage)

Your vital interest: To contact you if there are urgent safety or product recall notices to communicate to you or where we otherwise reasonably believe that the processing of your personal information may prevent or reduce any potential harm to you.

  • Contact information

 

3. What are your rights?

You have certain legal rights, which are summarised below, in relation to any of your personal data which we hold.

Where our processing of your personal data is based on your consent, you have the right to withdraw your consent at any time. If you do decide to withdraw your consent we will stop processing your personal data for that purpose. Your withdrawal of your consent won’t impact any of our processing up to that point.

In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue to process your personal data.

 

Your right What does it mean? Limitations and conditions of your right

Right of access

  • Subject to certain conditions, you are entitled to have access to your personal data (this is more commonly known as submitting a “data subject access request”).
    • If possible, you should specify the type of information you would like to see to ensure that our disclosure is meeting your expectations.
    • We must be able to verify your identity. Your request may not impact the rights and freedoms of other people, eg privacy and confidentiality rights of other individuals.

Right to data portability

  • Subject to certain conditions, you are entitled to receive the personal data which you have provided to us and which is processed by us by automated means, in a structured, commonly-usedmachine readable format.
    • If you exercise this right, you should specify the type of information you would like to receive (and where we should send it) where possible to ensure that our disclosure is meeting your expectations.
    • This right only applies if the processing is based on your consent or on our contract with you and when the processing is carried out by automated means (ie not for paper records). It covers only the personal data that has been provided to us by you.

Rights in relation to inaccurate personal or incomplete data

  • You may challenge the accuracy or completeness of your personal data and have it corrected or completed, as applicable.
    • This right only applies to your own personal data. When exercising this right, please be as specific as possible.
  • We encourage you to notify us of any changes regarding your personal data as soon as they occur, including changes to your contact details, telephone number. 

Right to object to or restrict our data processing

  • Subject to certain conditions, you have the right to object to or ask us to restrict the processing of your personal data.
    • As stated above, this right applies where our processing of your personal data is necessary for our legitimate interests. You can also object to our processing of your personal data for direct marketing purposes.

Right to erasure

  • Subject to certain conditions, you are entitled to have your personal data erased (also known as the “right to be forgotten”), eg where your personal data is no longer needed for the purposes it was collected for, or where the relevant processing is unlawful.
    • We may not be in a position to erase your personal data, if for example, we need it to (i) comply with a legal obligation, or (ii) exercise or defend legal claims. 

Right to withdrawal of consent

  • As stated above, where our processing of your personal data is based on your consent you have the right to withdraw your consent at any time.
    • If you withdraw your consent, this will only take effect for future processing.

If you wish to exercise any of your rights please contact data@rybrook.co.uk. Please contact us if you have any concern about how your personal information is processed and we will try to resolve your concerns. If you are not satisfied with our response or you consider that we are in breach of our obligations under data protection laws you may make a complaint to the Information Commissioner’s Office. Please see the Information Commissioner’s website https://www.ico.org.uk for more information.

 

4. Who do we share personal information with and where are they? 

Information collected by one Rybrook Group company may be shared with other companies in the Rybrook Group for the purposes of administrative efficiency. In order to make certain products and/or services available to you we sometimes share your data with trusted third parties. 

As explained above, we represent a number of vehicle brands and we share some of your information with the relevant manufacturer. If your enquiry leads to the purchase of a vehicle your information will be shared with the relevant manufacturer for warranty, registration and safety recall purposes. We may also share your information to ensure that you receive the appropriate aftersales support for your vehicle. We will ask for your consent to pass your information to the manufacturer for marketing purposes. 

If you enquire about the purchase of a vehicle with a finance agreement or related financial products such as insurance, we will disclose your information to our selected finance partners. If you are accepted for finance, the finance company will become the data controller for your information and we recommend that you read their privacy policy to see how they will use your data. 

To ensure that the data that we hold remains up to date we periodically cleanse our databases using consumer credit reporting agencies to check contact information. We may use third party service providers such as events management companies, call centres and mailing houses to support our marketing activities. We may also use service providers in less direct ways, such as in the provision of our payment and finance systems, or fraud verification. 

We have agreements with our service providers which restrict how they are able to process your personal information and require them to keep it secure. If any service provider is based outside of the European Economic Area, we will ensure that the provider is either a current subscriber to the EU/US Privacy Shield, or we have an appropriate contract for the international transfer of personal information with them. Our website also contains scripts from third party affiliates who will gather Observed information about you in order to verify referrals from third party advertising. We do not process this information but it is collected directly by them and processed in accordance with their privacy policies. For a list of affiliates, please see our Cookie Policy https://www.rybrook.co.uk/cookie-policy. 

We may share any of your personal data with a prospective purchaser of all or any part of our business, on the basis of our legitimate interests and the interests of our purchaser, so that they can appropriately value the business and assess any risks and continue doing business with you after the acquisition.

 

5. How long do we keep your information for? 

We will only retain your personal information for the purposes set out in this Policy and for as long as we have a legal or business requirement to do so. By law, different retention periods apply to different types of records and data, however the longest we will normally hold any personal data is 7 years from the date of your last transaction, for taxation, accounting and risk management purposes. This may be extended in the event of a query, investigation or dispute until fully resolved.

 

APPENDIX A – LIST OF DEALERSHIPS 

Company and Brand (Dealership)

Rybrook Limited

  • BMW (Shrewsbury, Warwick, Wolverhampton, Worcester)
  • MINI (Shrewsbury, Stratford, Wolverhampton, Worcester)
  • BMW Motorrad (Wolverhampton)
  • Rolls-Royce (Birmingham, Bristol)

Rybrook Cars Limited

  • Jaguar (Conwy, Huddersfield, Warrington)
  • Land Rover (Conwy, Copley, Huddersfield)
  • McLaren (Birmingham, Bristol) Volvo (Chester, Warrington)
  • Rybrook Specialist Cars (Birmingham, Bristol)
  • DealerPX (Online only)

Rybrook Motors Limited

  • Porsche (Chester)

Rycliff Cars Limited

  • Bentley (Bristol)
  • Lamborghini (Bristol) 

Company Information

Company Information

Registered Name: Rybrook Limited 

Company Registered Number:  05818937

Place of Registration: England and Wales

Registered Office Address: 6 Athena Court, Athena Drive, Tachbrook Park, Warwick, CV34 6RT

VAT Number: 887126980

Email Address: 

FCA Status Disclosure:

Rybrook Limited is authorised and regulated by the Financial Conduct Authority for consumer credit activity (Limited Permissions) – FRN 456584. Rybrook Limited is an Appointed Representative of South Quays Limited which is authorised and regulated by the Financial Conduct Authority for insurance mediation activity – FRN 528881.

Complaints Procedure

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

Contacting us.

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

Customer Service
BMW (UK) Limited
Summit ONE
Summit Avenue
Farnborough
Hampshire GU14 0FB

Telephone:

0370 5050 160

Email:

customer.service@bmw.co.uk

We’re here:
9am - 6pm Monday to Friday

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, by the end of the next business day if possible. If this is not possible, and your complaint relates to our credit broking, 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.

Find out more

 

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 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:

0300 123 9 123

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.

 

Motor Codes

Motor Codes is a government-backed, self-regulatory body for the motor industry. BMW subscribes to the New Car Code, which covers the sale of new cars, warranties, the availability of replacement parts, and advertising and complaint handling. In addition, our BMW Centres subscribe to the Service and Repair Code which commits them to open, transparent and fair methods of business aiming to maintain consistently high standards.

Telephone:

0207 3441 651

Email:

consumer@motorcodes.co.uk

Website:

www.motorcodes.co.uk

 

BVRLA conciliation

BMW is a member of the British Vehicle Rental and Leasing Association (the BVRLA). If you are not happy with our final response and would like to refer your complaint to the BVRLA’s conciliation scheme, you may email them at:

complaint@bvrla.co.uk

or write to them at:

BVRLA
River Lodge
Badminton Court
Amersham
HP7 0DD

 

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:

http://ec.europa.eu/consumers/odr/