Frank Dale & Stepsons Ltd trading as Frank Dale (incorporated and registered under company number 05140545), and Gordon Dale Enterprises Ltd
(incorporated and registered under company number 01042742), also referred to as “we”, “us” or “our” are committed
to protecting and respecting your privacy. For the purposes of applicable data protection legislation, Frank Dale
& Stepsons Ltd is the data controller. We will treat your personal data in accordance with our obligations under
data protection law, and implement adequate security measures. Our aim is to be clear and transparent about the way
we use your personal data and not do anything you would not reasonably expect. By submitting personal information to
us or by accessing our website at www.frankdale.com (the
“Website”) you are accepting and consenting to the practices described in this Privacy Policy. By
using our Website, you consent to our collection, use and disclosure of your information in accordance with this
Privacy Policy. If you do not agree with this Privacy Policy you must not use or access our services or Website. We
reserve the right to amend or modify this Privacy Policy and if we do so we will post the changes on our
Website. This policy (together with our terms of use and any other documents referred to on it) sets out the basis on
which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the
following carefully to understand our views and practices regarding your personal data and how we will treat
it.
INFORMATION WE MAY COLLECT FROM YOU
Personal data, or personal
information, means any information about an individual from which that person can be identified. It does not include
data where the identity has been removed (anonymous data). We may collect, use, store and transfer different types
of personal data about you, which we have grouped together as follows:
· Identity data: first
and last name, marital status, title, date of birth and gender;
· Contact information: postal
address, e-mail address, phone number(s);
· Financial Information: bank account details;
·
Transaction data: includes details about car enquiries, consignments, cars you have purchased from
us or through us, sold to and/or through us, payments to/from you and other details of cars and services you have
contacted us about;
· Profile Data: your car interests, preferences, feedback and offer
responses, information publicly available such as published articles or news;
·
Marketing and
Communications Data:
includes your preferences in receiving newsletters and updates from us and your
communication preferences;
· Social Media Information: You might give us permission to access
some information about you when using some social media sites such as Twitter, Google, Instagram and Facebook
depending on the privacy settings you have and the privacy policies of such companies.
We are not responsible
for the privacy policies and practices of other websites even if you accessed the third party website using
links from our Website or by means of our services
;
· Technical Data: includes internet
protocol (IP) address, your browser type and version, time zone setting and location, browser plug-in types and
versions, operating system and platform and other technology on the devices you use to access this Website, as well
as your journey through our digital platform (such as the links you click on and searches you make), which videos
you have watched and for how long, what content you like and share, your subscription status, which pop up or push
messages you might have seen and responded to and information collected in any forms you complete;
·
Usage Data: includes information about how you use our website, products and services.You may
choose to not provide us with your personal data. However, where we need to collect your personal data by law, or
under a contract we have with you, and you fail to provide us with your data, we may not be able to perform the
contract we have or are trying to enter into with you.
HOW WE MAY COLLECT YOUR DATA
· Direct Interactions:· when you call us;· by e-mail, or through our Website;· by giving us
your business card;· when you request our services;· by filling in forms and submitting them to us; ·
Information publicly available:· Identity Data and Contact Data: We may check some of the
information that you provide to confirm that it is accurate using third party databases such as Companies House and
the Electoral Register based inside the EU or from data brokers or aggregators such as Mint based inside or outside
the EU;· Profile Data: We may obtain Profile Data from public sources such as car registrars, newspapers, magazines,
attendance to events, word of mouth, etc;· Technical Data: We may obtain technical data from analytics providers
such as Talent or Google; advertising networks and search information providers all based inside or outside the EU.
HOW WE MAY USE THE DATA COLLECTED FROM YOU
We will only use your personal
information where the law allows us to. Most commonly, we will use your personal data in the following
circumstances, each known as a “lawful basis”:· Where we need to
perform a
contract
with you, for example selling you a car;· Where it is necessary for our
legitimate
business interests
, provided that your fundamental rights are not overridden by our interests;· Where
we need to comply with a legal or regulatory obligation.Generally, we do not rely on your
consent to process data, other than in relation to sending certain direct marketing messages. Where
we rely upon your consent, you have the right to withdraw your consent at any time by contacting us at sales@frankdale.com. We will only use your personal information in line
with the purposes for which you provided it to us or for compatible purposes.
MEANS OF
COMMUNICATION
E-mail:
· We will only contact you by e-mail with information about classic cars
and related events. You will be entitled to opt out from this by contacting us or by clicking “unsubscribe” in the
electronic communication you receive (lawful basis: legitimate interests).
Phone:· We
may contact you by phone when you send us a written enquiry by any other means (e.g. by e-mail) (lawful basis:
performance of a contract, legitimate interests).· We may contact you by phone in connection with classic cars and
car related activities we promote (i.e. this would typically consist of a very small number of calls to you per year
and follow up calls only if the first call yields positive interest) (lawful basis: performance of a contract,
legitimate interests).
Postal Mail:· We may contact you by postal mail when you have
expressed that this is your preferred means of communication (lawful basis: performance of a contract, legitimate
interests);· We may send you printed material in connection with classic cars offered and sold and car related
activities we promote (lawful basis: legitimate interests).
DISCLOSURE OF YOUR
INFORMATION
Information about our customers and prospective customers is an important part
of our business and we do not sell it to others. Any parties we share your data with will only process your personal
data on our instructions (unless otherwise required by law), and are subject to a duty of confidentiality.We only
share your personal data with the following parties and in the specified circumstances:
Related
Parties:
All these related parties that have or may have access to, and/or are associated with, the
processing of your personal information are obliged to respect the confidentiality of your personal information:·
Any member of our group of companies and our employees;· Third party consultants, contractors or other service
providers who may access your personal information when providing services (including but not limited to IT support
services) to us;· Auditors or contractors or other advisers auditing, assisting with or advising on any of our
business purposes or processes.
Third Party Service Providers: We may share some of
your data with our trusted service providers and suppliers for the purpose of providing you with the information,
cars or services you request:· If such service providers or suppliers are acting on our behalf: they cannot use your
data for any other purpose than that, which is prescribed by us, and we only use those service providers and
suppliers who undertake to protect your details with the same degree of care as we do; or· If service providers or
suppliers are acting on their own account, you will be subject to their own terms and conditions and privacy
policy.
To Protect our Rights: We may share personal data with third parties if doing
so is necessary:· To protect the rights, property or safety of Frank Dale & Stepsons, our customers, or others.
This includes exchanging information with other companies and organisations for the purposes of fraud prevention and
credit risk reduction;· To enforce or apply our Terms, and/or other agreements;· To protect the rights, property, or
safety of our group of companies, our customers, or others.
As Required By Law:· We
will share personal data with government bodies and law enforcement agencies and in response to other legal and
regulatory requests, if we are under a duty to disclose or share your personal data in order to comply with any
legal or regulatory obligation or request.
INTERNATIONAL TRANSFERS
Some of
our third party service providers are based outside the European Economic Area (EEA) so their processing of your
personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the
EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards
is implemented:· We will only transfer your personal data to countries that have been deemed to provide an adequate
level of protection for personal data by the European Commission.· Where we use certain service providers, we may
use specific contracts approved by the European Commission which give personal data the same protection it has in
Europe.· Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield
which requires them to provide similar protection to personal data shared between the Europe and the
US.
DATA SECURITY
The Internet is not a secure medium. However, we have put
in place various security procedures with regards to the Website and your electronic communications with us, as set
out in this Privacy Policy.· Please be aware that communications over the Internet, such as e-mails/webmails are not
secure unless they have been encrypted. Your communications may route through a number of countries before being
delivered – this is the nature of the World Wide Web/Internet.· We cannot accept responsibility for any unauthorised
access or loss of personal information that is beyond our control.· We have appropriate security policies, rules and
technical measures to protect the personal data that we have under our control (having regard to the type and amount
of that data) from unauthorised access, improper use or disclosure, unauthorised modification, unlawful destruction
or accidental loss.· We have procedures in place to deal with any suspected data breach, and will notify you and any
regulator of a breach when legally required to do so.
DATA RETENTION
We
will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including
for the purposes of satisfying any legal, accounting, or reporting requirements. For instance, by law we have to
keep basic information about our customers (including contact, identity, financial and transaction data) typically
for six years after they cease being customers for tax purposes.
YOUR RIGHTS IN RELATION TO YOUR
INFORMATION
Request access to your personal data: You can write to us at
any time to obtain a copy of the personal information that we hold.
Request correction of your
personal data:
You can write to us to have your personal information erased, restricted, rectified,
amended or completed.
Request erasure of your personal data: You can write to ask us to
delete or remove personal data where there is no good reason for us continuing to process it. Note, however, that we
may not always be able to comply with your request of erasure for specific legal reasons which will be notified to
you, if applicable, at the time of your request.
Object to processing of your personal
data:
Where appropriate, you may write to object to our processing your personal data under certain
circumstances. In some cases, we may demonstrate that we have compelling legitimate grounds to process your
information which do not override your rights and freedoms.
Request restriction of processing
your personal data:
This enables you to ask us to suspend the processing of your personal data under
certain circumstances.
Request transfer of your personal data: You may ask your
personal data to be sent to you or to a third party. We will provide to you, or a third party you have chosen, your
personal data in a structured, commonly used, machine-readable format.
Right to withdraw
consent:
Where we are relying on consent to process your personal data. However, this will not affect
the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may
not be able to provide certain products or services to you. We will advise you if this is the case at the time you
withdraw your consent.If you wish to exercise any of the rights set out above, please contact us at sales@frankdale.com. To protect your information, we will require proof of
your identity. We will try to respond to all legitimate requests within one month.You will not have to pay a fee to
access your personal data, or to exercise any other rights. However, we may charge a reasonable fee if your request
is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in such
circumstances.
IP ADDRESSES AND COOKIES
We may collect information
about your computer, including where available your IP address, operating system and browser type, for system
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.For the same reason, we may obtain information
about your general internet usage by using a cookie file which is 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 our site 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 our site according to your individual
interests.To speed up your searches.To recognise you when you return to our site.You may refuse to accept cookies by
activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select
this setting you may be unable to access certain parts of our site. Unless you have adjusted your browser setting so
that it will refuse cookies, our system will issue cookies when you log on to our site.
ACCESS
TO INFORMATION
Questions, comments and requests regarding this privacy policy are welcomed
and should be addressed to sales@frankdale.com· You have the right to
contact the Information Commissioner's Office if you have a complaint regarding your personal data. Their website
address is https://ico.org.uk. We would, however, appreciate the
chance to resolve your concerns before you approach the ICO, so please contact us in the first
instance.
LEGAL DISCLAIMER
All contents on this website are copyright to Frank Dale & Stepsons and related manufacturers.
Changes may occur and errors may be made in the production and electronic transfer of material, for which Frank Dale & Stepsons accepts no responsibility.
Information and images copyright Frank Dale & Stepsons.
CHANGES TO OUR PRIVACY POLICY
Any changes we may make to our
privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Last
updated 01/11/2020.
Registered Company Number: 05140545
Registered Office Address: Ashbourne House, The Guildway, Old Portsmouth Road, Guildford, Surrey, United Kingdom, GU3 1LR