Who is Responsible for Processing Your Personal Data
S&M Tyres LTD is the data controller and legal entity responsible for how your personal data is collected, stored and processed. This policy also relates to other companies within the S&M Tyres LTD Group, these companies are:
Managing Your Personal Data
What data we collect
We may collect the following information:
Name. address and contact information including email address.
Demographic information such as IP address and postcode.
Other information relevant to customer surveys and/or offers.
We record customer calls to the branches using Response Tap. Customers do have the option to opt out of the recording at the start of the phone call by pressing the relevant number on the telephone keypad.
Response tap is an analytics provider whose software allows website owners to understand the usability of their websites and the effectiveness of their marketing (the “Services”). This information enables a website owner which is a customer of ResponseTap to improve the service that they provide to their website visitors (a “Customer”).
The information we may collect on our Customer’s behalf (via our Customers’ websites) as described above could include your IP address and other information relating to your web browser or operating system configuration (such as screen resolution and browser version), cookie IDs, and telephone number. We may also process recordings of calls made to our Customers, on our Customer’s behalf.
The collection of such information is designed to enable the Customer to analyse a website visitor’s journey through the Customer’s website and analyse the effectiveness of the Customer’s marketing initiatives.
What we do with the information we gather
We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:
- Internal record keeping.
- We may use the information to improve our products and services.
- We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided.
- From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone or mail. We may use the information to customise the website according to your interests.
WSI-eMarketing provides Elite Garages with a variety of Marketing Services (including but not limited to; requesting reviews from Elite’s customers and maintaining ‘opt-in’ databases of non-customers) and in this context act as data processors on behalf of Elite, utilising software services (including but not limited to Reviews.co.uk and Sharpspring).
Obtaining your consent
We will obtain your consent to send you details of our latest products and promotions via Email Marketing and Telemarketing in several ways. We will obtain your consent when you register your details with us, open a credit account, make a purchase, sign up to our email newsletters, enter a competition or when we send you electronic receipts via email in store. You can change your email and telemarketing preferences at any time – see Changing Your Marketing Preferences.
At times, we would like to keep you informed about our latest product offers and promotions using the email address you provide to us. To do this, we will ask you to opt-in to receive marketing emails when you first register an account with us, sign up for our newsletter, enter a competition or prize draw or agree for us to use your email address for marketing purposes when we send you electronic receipts in store. You can opt out of email marketing at any time – see Changing Your Marketing Preferences.
We will ask your permission to ring you about our latest product offers and promotions when you make a purchase or open a credit account with us. You can opt out of telemarketing at any time – see Changing Your Marketing Preferences.
We will use your name and address to send you personalised marketing mails in the post. We have a legitimate business interest to send you information about our products and offers in the post as we know that many of our customers like to browse through catalogues or offers prior to placing an order with us. However, should you wish to exercise your right to stop personalised postal marketing activity, you can do this at any time – see Changing Your Marketing Preferences.
We will use your email address to send you online targeted marketing information about our product offers and promotions via social media platforms. To do this, we will share your email address in a secure manner with social media organisations, such as Facebook, who will match our advertising requirements to your social media profile. We have a legitimate business interest to send you product information via social media which we believe is of relevance to you; this is known as Interest-Based Advertising. However, should you wish to exercise your right to stop targeted social media marketing, you can do this at any time – see Changing Your Marketing Preferences.
Third Party Marketing
We will not share your personal data with third party companies for the purpose of them marketing their products and services to you.
Changing your Marketing preferences
You can change your marketing preferences for Email Marketing at any time by:
- Ringing us on 01403 756520
You can change your marketing preferences for Telemarketing at any time by:
- Ringing us on 01403 756520
Please allow 48 hours for your changes to be processed for email and telephone marketing.
You can exercise your right to object to Direct Mail or Social Media at any time by:
- Ringing us on 01403 756520
Please allow 48 hours for your changes to be processed for social media. You may still receive direct marketing materials that are already processed before we received your request for up to 2 months.
Using your Personal Data to Open a Credit Account
When you apply for a credit account with us, we will use your personal data to make a decision as to whether or not we will accept your application and, if so, the amount of credit we will offer you. Without this data, we are unable to perform the services under this contract i.e. to calculate the amount of credit offered and manage your credit account in accordance with the applicable guidelines and regulation.
You have a choice to opt out of providing us with your personal data for the purpose of making an decision at the point of application and select a cash account.
We will hold your personal data for 6 years, plus the current financial year, after the date of your last transaction on your personal credit account.
Credit Reference Agencies
We will request information about you from Credit Reference Agencies (“CRAs”) and we will also supply your personal data to CRAs. The CRAs that we use are Experian, Call Credit, Equifax and Aire Labs Ltd. For more information as to how CRAs use your personal data, please refer to the Credit Reference Agency Information Notice (“CRAIN”) at:
These companies receive and share personal and financial data on you from all the companies that you are connected with financially as well as providing us with verification of your name, address, date of birth and gender details from the Electoral Register to prevent fraudulent applications. The CRA record details of all credit searches and tell us the risk associated with providing credit and if there is any suspected fraudulent activity associated with you.
We will also share your personal data with CRAs and other companies for fraud prevention. We will continue to exchange information about you with CRAs while you have a relationship with us. We will also inform the CRAs about your settled accounts. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt. This information may be supplied to other organisations by CRAs. When CRAs receive a search from us they will place a search footprint on your credit file that may be seen by other lenders.
We may make periodic searches of our records that we hold about you, CRAs and fraud prevention agencies to manage your account with us and to take decisions about credit, including whether to make credit available or to extend existing credit arrangements. These searches will not be available to other lenders for credit assessment purposes.
We, CRAs and fraud prevention agencies may also use the credit records for statistical analysis about credit, insurance and fraud generally. This is not personal data but is aggregated for the purpose of trend analysis, managing debt and fraud prevention.
You have the right to access your personal records held by CRAs by contacting Experian, Call Credit and Equifax directly.
Using your Personal Data for Fraud Prevention
We carry out fraud checks on new credit applications and credit orders. In order to do this, we use data sourced from Credit Reference Agencies and other external agencies that are involved in fraud detection. If we identify fraud, we will pass data relating to the fraudulent activity such as name, address and email address to these agencies to help protect individuals and other businesses from the threat of fraud in the future.We will hold your personal data for 6 years, plus the current financial year, after the date of your last transaction on your personal credit or cash account.
Using your Personal data to Improve our Services
As a valued customer, we may use your personal data to contact you by phone, SMS, letter or email to ask you to participate in one of our service improvement programs. We will share your personal contact details with our chosen third party partners and service providers who may carry out these service improvement programs on our behalf. We will always make you aware of how we will use the information that we gather from you at the time of contacting you for any specific service improvement program. We have a legitimate business interest in contacting our customers in this way and will always treat your involvement in any service improvement program, and associated personal data, in confidence. Should you not wish to participate in our service improvement program, you can simply decline to participate at the point of contact or, should you wish never to be contacted for the purpose of market research, you can tell us at any time by ringing us on 01403 756520.
Processing your Personal Data Outside of the EU
We will transfer your personal data outside the European Economic Area (the EEA) to prevent fraud, for credit searches and with our outsourced IT partners and contact centres. Please also see Sharing Your Personal Data with Third Party Processors & Partners. In some cases, countries outside the EEA may not have such well-developed data protection laws as those in the EEA. However, we will put in place measures and safeguards that require your personal data to be kept secure, confidential and to be processed only and strictly in line with.
Sharing your Personal Data with Third Party Processors & Partners
As part of delivering our products and services to you, we will share your personal data with carefully chosen Third Party Processors and Partners who carry out a number of services on our behalf. (i.e Promotions). Should you wish to obtain a list of our latest Third-Party Processors and Partners, you can request this at any time by contacting on 01403 756520.
Any third party that communicates with you on our behalf must only do so for the purpose of carrying out the services and not for the purpose of direct marketing their own products and services. If you have any concerns about any of our third-party processors and partners, please contact us on 01403 756520
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect by phone, online or in Branch.
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Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
Controlling your personal information
You may choose to restrict the collection or use of your personal information in the following ways:
- You have the option to call our company rather than complete any online forms, applications or registration process
- If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us directly.
We will never sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about products, services or third parties that we think you may find interesting if you tell us that you wish this to happen.
You may request details of personal information which we hold about you under the Data Protection Act 1998, and you may also request that information we hold about you is erased from our systems as per Article 17 of the GDPR. A fee may be payable for excessive or repeat requests and each request will be considered, and if seen to be reasonable will be acted upon within 1 month of the request being made. If you would like a copy of the information held on you please contact us directly by post, in person, or by phone using the address details on this website, and we will require verifiable evidence of your identity – requests without the required identification, as with repeat requests will be refused as per the ICO GDPS Rights of Access Guidelines.
If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the address or using the contact form on this website. We will promptly correct any information found to be incorrect.
How to contact us
Tel: 01403 756520
If you are at all dissatisfied with the information provided by the Data Governance Team, please address any complaints to the Data Protection Officer at the same address.
Your Personal Data Rights
Right of Access
You may wish to access a copy of the personal data we hold about you – known as a Subject Access Request. You can do so by ringing, writing to or emailing us. We will respond to your Subject Access Request as soon as possible and, in any event, within the statutory 30 days. However, in the event that we need more information from you to verify your identity, which we must do to ensure we disclose your personal data to the right person, the 30 day response period will only commence from the time that we have validated your identity.
Please be aware that for security reasons we do not usually provide details of any bank details that we hold against your account(s). Please speak to us should you need this additional information.
Right of Rectification
If you believe we have made an error as to the personal data we hold about you, please speak to one of us on 01403 756520 and we will be able to process the correction for you.
Right of Erasure
You have the right to request your personal data to be permanently deleted from our records and systems to avoid any further communication with you. Your request will always be considered in light of the legal bases that we hold, store and process your personal data and the purpose that we collected your data. Where the legal bases permits, we will carry out your instruction without undue delay. Please note, however, that where we have a legal or contractual obligation to hold your personal data, we may not be able to carry out your request, but we will explain this fully to you. Please address any request to delete your data to S&M Tyres Ltd.
Right to Restrict Processing
Should you believe that we are processing your personal data in a way that you did not understand or agree to and wish to restrict such processing, please speak to the us and we will be able to assist you.
Right to Object to Processing
You have the right to object to certain types of processing of your personal data. We will always make it clear at the outset of any new arrangement with you how we are going to process your personal data. Should you wish to object to such processing, particularly concerning Decisioning and Profiling, we will give you the option to opt out on application. However, should you wish to discuss this matter further, please speak to us.
Right to Portability
In the event that you wish to move your personal data that we hold on you to another organisation in the form of an excel or csv format, please contact us and we will be able to assist you.
Right to be Informed
Right to Complain to the Information Commissioners Office (ICO)
You have a right to lodge a complaint with the Information Commissioner’s Office (ICO) if you have a complaint with how you believe your personal data has been handled. For more information, please visit https://ico.org.uk/concerns
R J Whittemore
Date: 6th November 2018