Privacy Notice

1.1 At Brotherwood Automobility Limited we are committed to maintaining the trust and confidence of all customers and website visitors. Your privacy is very important to us, so we want you to feel comfortable with how we use and share your personal data.

1.2 This Privacy Notice acknowledges the General Data Protection Regulation (GDPR) and explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll process, store, handle and ensure your data is kept safe.

1.3 We are registered with the Information Commissioner’s Office (ICO) in the United Kingdom.

1.4 In this Notice, “we”, “us” and “our” refer to Brotherwood Automobility Limited, unless mentioned otherwise.

1.5. You can find our contact details at the end of this document (see section 14). You can contact us to exercise your rights, for example update your details, or for any other questions regarding how we handle your data.

1.6 Our website contains links to other websites. This privacy notice only applies to our website so when you link to other websites you should read their own privacy notices. We are not responsible for the content of any third-party websites.

1.7 This notice may change, so please check this page from time to time to ensure that you’re up to date and happy with any changes. (Please see further changes to the notice in section 14)

1.8 The privacy notice was last updated on 23/05/18

2.1 We collect a range of data which helps us to deliver a better service to you as well as helping you when choosing a Wheelchair Accessible Vehicle (WAV) or any other product/service we offer. In most circumstances this will involve processing your name, contact details (e.g. phone number, email and postal address), WAV brochure requests, demonstrations and orders.

2.2 We also process the following types of data which relate more specifically to our business processes and our contract with you, (not exclusive):

• Details of your interactions with us through correspondence history; For example, we collect notes from our conversations with you, on purchases you make, WAV’s demonstrated to you, details of any complaints, and how/when when you contact us.

• Copies of documents you provide to prove your driving license, tax exemptions etc. In some instances, this will include details of your full name, address, date of birth and facial image. If you provide a passport, the data will also include your place of birth, gender and nationality;

• Details of your visits to our websites and which referral path you came from to reach us, through the use of google analytics;

• Information gathered by the use of cookies in your web browser (Please see section 13)

• Personal details which help us to recommend items of interest to you;

• Motability contracts;

• Payment information, not stored

• Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback;

• Your comments and product reviews/feedback collected by Feefo;

• Imagery which is recorded on CCTV when you visit our factory;

• Call log details, temporary stored to aid answerphone call-back.

We may collect information in the following circumstances, (not exclusive):

• When you visit our websites to browse our products and services;

• When you interact with our online chat service;

• When you contact us by any means with queries, brochure or demonstration requests, complaints etc.;

• When you complete a Motability application;

• When you request a demonstration or a demonstration is conducted, we need to collect the wheelchair users’ seated height, weight and general wheelchair dimensions, plus any other factors to assist us in determining and providing the best WAV to meet your needs.

• When you purchase a WAV or another product/service from us, such as conversion warranty;

• When you engage with us on social media;

• When you hire a WAV from us;

• When you engage with us at an exhibition/show;

• When you choose to complete any surveys we send you;

• When you enter prize draws or competition;

• When you comment on or review our products and services via our feedback third party, Feefo. (Any individual may access personal data related to them, including opinions. So if your comment or review includes information about the member of staff who provided that service, it may be passed on to them if requested.)

• When you’ve given a third party permission to share with us the information they hold about you, e.g. an occupational therapist.

• When you visit our site we use CCTV systems, operated for security reasons for both customers and staff. These systems may record your image during your visit.

4.1 Our ultimate aim is to give you the best possible customer experience. In order to achieve this we need to use certain key pieces of personal information that you provide in order to better understand your needs and requirements. We then use this to offer you promotions, products and services. In the long term this information is also extremely helpful for business planning and future product development.

4.2 This use of personal data is permitted under GDPR as part of our legitimate interest; to understand our customers and provide the best service we can. Please contact us if you would like further clarification of how we use your data. Furthermore, if you do not want us to use your data in this way, you are within your rights to have your data deleted (see Contact Us, 14).

4.3 We also use your data to comply with your requirements, for example if you want to be added to the stock list and contacted when we have a certain WAV available, you must give us permission to contact you.

Here are some examples of how we will use your personal data and why:

• To process any orders. We will collect your personal data throughout the purchasing journey in order to process your order and comply with our legal obligations.

• To respond to your queries, complaints and requests. Processing your personal information allows us to respond. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service. It also helps us to understand how we can improve our service, based on your experiences.

• To protect our customers, premises, assets and staff from crime, we operate CCTV which record images for security purposes. The imagery is held for 30 days before being automatically overwritten. We do this on the basis of our legitimate business interests.

• To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests, as well as helping to protect our customers from fraud.

• With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, telephone and through the post. Of course, you are free to opt out of hearing from us by any of these channels at any time.

• To send you communications required by law or which are necessary to inform you about the changes to the services we provide you. For example, updates to this Privacy Notice, product recall notices, and legally required information relating to your orders.

• To administer any of our prize draws or competitions which you might enter; based on your consent given at the time of entering.

• To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.

• To comply with our contractual or legal obligations to share data with law enforcement agencies.

• To help make changes to future products/services based on the feedback and reviews you leave via our feedback channels supplied by Feefo.

5.1 Under the GDPR a business must comply with one of the six legal bases in order to collect and process personal data. The main concepts which we adhere to are:

5.2 Consent

We hold clear, explicit and defined consent for the individual’s data to be processed for a specific purpose. For example:

• When you subscribe to receive email newsletters.

• To supply brochures and other material when you have specifically requested it from us.

5.3 Contract

The processing is necessary to fulfil or prepare a contract for the individual. For example:

• To exchange warranty/servicing and aftersales.

• To supply you with our product/service

5.4 Legal obligation

We will use your information to comply with a legal obligation (excluding a contract). For example:

• Sharing your data with relevant third parties including, HMRC, DVLA and any other public authority and/or criminal investigating company.

• Transferring your data to vehicle manufacturers in case they should need to contact you, for instance if they need to conduct a product recall.

5.5 Legitimate interest

The processing is necessary for our legitimate interests. This condition does not apply if there is a good reason to protect the individual’s personal data which overrides the legitimate interest. For example:

• if we know your WAV contract is due to expire we may send you details on a new WAV which we think will suit your needs and preferences;

• to correspond and communicate with you;

• for market research in order to continually improve the products and service we deliver to you;

5.6 Vital interest

Processing the data is necessary to protect a person’s life or wellbeing. For example, if there is an urgent safety or product recall to communicate to you, or where we otherwise believe that the processing of your personal information will prevent or reduce any potential harm to you.

6.1 There are very few occasions that we share your personal data with a third party. On the rare occasions that we do, it’s only with said parties and in connection with products and services that complement our business, for example insurance companies.

6.2 Other parties may include certain service providers, agents, subcontractors and other organisations that provide a service to us or directly to you on our behalf. Such third parties may include delivery couriers, technicians visiting your home and vehicles dealers e.g. Volkswagen. We will always apply safety measures to protect your data and privacy, for example as follows:

• Provide only the information needed to perform a specific service;

• Ensure that your data is only used for the exact purpose specified in our contract with them;

• Working with the third party to ensure that your privacy is respected and protected at all times;

• Ensuring that any of your data held by them will either be deleted (according to their retention policy) or rendered anonymous if we stop using their services;

6.3 Examples of the kind of third parties we work with are:

• IT companies who support our website and other business systems; • Operational companies such as delivery couriers;

• MailChimp, to deliver our newsletter/emails;

• Product review companies such as Feefo who will collate your reviews;

• Interactive online chat provider, Tawk.to.

6.4 We use a third party provider, MailChimp, to deliver our newsletter. We gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our e-newsletter. For more information, please see MailChimp’s privacy notice.

6.5 We utilise Feefo, a third party company who generate reviews and feedback on our product and services on our behalf. If you make a purchase with us we may share your name, email address and order details, so Feefo can collect feedback from you. This falls under the category of our legitimate interest, but you do have the facility to opt-out if you do not wish for your personal information to be processed in this way. For more information, please see Feefos privacy policy.

7.1 We want to advise you of offers and promotions that are most relevant to your interests. In order to do this we combine your personal information which we have gathered from a range of fields such as our website, demonstration requests and consumer history. We may also use any data we gather from third parties such as Occupational Therapists and the feedback we gain from using the service provided by Feefo. This helps us to better direct the information we send to you.

8.1 We understand the importance of data security and know how much it matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it. We ensure that this message is relayed to all our staff to ensure that the security of your data is always afforded the highest priority.

8.2 Access to all electronically stored data is password-protected, and there is restricted access to all offline personal information. Certain sensitive information such as bank details, are not stored. We regularly monitor our system for possible vulnerabilities and attacks, and improvements to further strengthen security are frequently reviewed.

9.1 Your personal data will be processed from the point at which you first interact with us, and ultimately could include after-sales services such as servicing, parts and warranty related matters. In most cases this processing involves only UK based organisations. However, if you are located outside of the United Kingdom it may be necessary to share your personal information with organisation in both European Economic Area (EEA) countries and non-EEA countries in order to fulfil our obligations to you.

10.1 You have a number of rights under the GDPR; the main ones summarised as follows:

10.2 Access to your personal information; You have the right to access a copy of your personal information that we hold about you. You can ask us to provide you with a copy or simply for us to state what information we hold about you. In order to access your information you will need to write or email us (see section 14). We cannot provide you with a copy of your information if it concerns other individuals, without their consent, or if there is a lawful reason to withhold the information.

10.3 Correcting or updating your personal information; We understand the importance of having accurate data and we will work with you to correct or update any of your personal information. If you change your name, email address of any other details, or you discover that we hold inaccurate data, please let us know by contacting us (see section 14) so we can make the necessary changes.

10.4 Withdrawing your consent; You have the right to withdraw your consent where we rely on it as the legal basis for processing at any time. You may withdraw your consent by contacting us (see section 14). If you would like to unsubscribe from any of our marketing which you have previously opted into, you can do so by either changing your preferences online, or by contacting us (see section 14).

10.5 Object to automated decision making; You have the right to object to any automated decision making that we might use, such as automatically compiling a list of past customers of a particular vehicle, and can request us to stop processing your personal information which we are doing so under a legitimate reason. You can make this request in writing by contacting us (see section 14). We will stop processing your personal information whilst we look into the matter. If we agree with your request we shall terminate the processing, otherwise we will provide you with a justification as to why we need to continue processing your information. You can however object to direct marketing.

10.6 Erasing your personal information; You have the right to ask to be ‘forgotten’ or to have your personal information removed from our systems; please do so by contacting us (see section 14). We will make every effort to remove the data and comply with your request, unless we have other lawful grounds which require us to keep your data. We will inform you if this is the case and justify our legal basis for keeping the information.

10.7 Right to complain to the Information Commissioners Office (ICO); You have the right to complain to the ICO if you are concerned in anyway about the way in which your personal information is handled. Please visit their website (www.ico.org.uk/concerns) for more details.

10.8 The need for specific consent; It may be necessary on some occasions during our assessment of your particular needs, to take photographs. These photographs will only be retained for the period they are required (usually your contract length) and are securely disposed of after this period. We will strive to avoid taking any photographs that can be directly related to you, however, on occasion this cannot be avoided e.g. images of a seatbelt configuration. Under such circumstances your consent will be obtained before taking such photographs and in the case of images of Children Under the age of 16, will involve specific consent.

10.9 Checking your identity and responding to requests; To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act. In responding to a request from you we may ask you for information, such as to confirm your identity and where applicable to clarify the nature of your request. Unless we state otherwise, we will respond to any request we receive within 30 days.

11.1 Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary and for the purpose for which it was collected.

11.2 At the end of that retention period, your data will either: be deleted completely; securely destroyed; or anonymised (for non-identifiable, statistical analysis and business planning).

An example of the customer data retention period is: Vehicle Orders; When you purchase a WAV with us we will keep the personal data you give us for the length of time you own that vehicle. This will change depending on your unique contract, for example on Motability the contract is 5 years but can be terminated early or extended.

12.1 By using our website you are consenting to receive Cookies. Cookies are small text files placed on your computer to collect standard internet log information and visitor behaviour information. For further information visit www.aboutcookies.org or www.allaboutcookies.org

12.2 We use Google Analytics Cookies to track non-identifiable visitor use of the website and to compile statistical reports on website activity. If you wish, you can choose to opt out of providing website usage information.

12.3 We occasionally may use iPromote and Facebook cookies to provide offers and products to you after you have left our website.

12.4 You can manage your browser’s cookies to determine which websites can provide targeted advertising with the Network Advertising Initiative Consumer Opt-Out (Beta) tool.

12.5 You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However, in a few cases some of our website features may not function as a result.

12.6 We manage and generate unique phone numbers through ResponseTap Cookies. This helps connect your customer journey by knowing how you reached us and through what channel.

12.7 We utilise the service of AddThis, This means using cookies to identify the device used when you visit our website. This information does not directly identify an individual, but you can opt-out of any data collection, or see your rights here: http://www.youronlinechoices.eu/

13.1 We may make changes to the privacy notice from time to time. Any changes we make will be updated to the privacy notice, available on our website. We recommend that you regularly check for changes and review this notice when you visit our website. If you do not agree with any of the changes then it is your responsibility to contact us to change your preferences. (See 1.5)

14.1 We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.

14.2 If you have any questions that haven’t been covered, please contact us:

(a) Email: enquires@brotherwood.com

(b) Or write to us at: Brotherwood Automobility Ltd, Lambert House, Pillar Box Lane, Beer Hackett, Sherborne, Dorset, DT9 6QP