Kettlewell Motorhomes Limited respects your privacy and is committed to protecting your personal data.
www.lucyandbensmotorhomes.co.uk is the website of Kettlewell Motorhomes Limited (Company No. 12804540) registered in England & Wales with a registered office at Elizabeth House, 1 Brewery Close, Barker Business Park, Melmerby, Ripon, North Yorkshire, England, HG4 5NL. Any reference in this policy to “we”, “us” or “our” is to Kettlewell Motorhomes Limited.
1. IMPORTANT INFORMATION AND WHO WE ARE
This website is not intended for children and we do not knowingly collect data relating to children.
For the purposes of the Data Protection Act 2018 and, to the extent that it applies in the UK, the General Data Protection Regulation or “GDPR” (and all other laws relating to the use your personal data), we are the “data controller”, meaning that we are responsible for deciding how your personal data is used and more importantly, for keeping your data safe and only using it for legitimate reasons.
Full name of legal entity: Kettlewell Motorhomes Limited
Email address: firstname.lastname@example.org
Postal address: Elizabeth House, 1 Brewery Close, Barker Business Park, Melmerby, Ripon, HG4 5NL
Telephone number: 01765 530825
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, title, date of birth, gender, National Insurance number and Driving Licence number.
- Contact Data includes billing address, email address and telephone numbers.
- Transaction Data includes details about payments to and from you.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
We may collect the following types of information from you when you use our website (using Cookies or other tracking technology):
- Usage Data includes information about how you use our website, products and services.
- Technical Data includes internet protocol (IP) address, your login data, 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.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel the service you have with us but we will notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact, Profile and Marketing and Communications Data by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- create an account on our website;
- upload your personal identity documentation using your online customer account, or by sending it via post or email;
- request marketing materials be sent to you; or
- give us feedback or contact us.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
- Publicly available sources. We will receive Identity and Contact data about you from the Driver and Vehicle Licensing Agency (DVLA) or foreign equivalent.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
- Where the individual has given their consent to the processing of their data.
Please see the Glossary at clause 10 below to find out more about the types of lawful basis that we will rely on to process your personal data.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer|| |
|Performance of a contract with you|
|Enable you to log-in to your account|| |
|Performance of a contract with you|
|To process your booking and liaise with you and our service providers in respect of it.|| |
Performance of a contract with you
|To confirm your ability to drive the vehicle with the DVLA or equivalent|| |
(a) Necessary to comply with a legal obligation
(b) Necessary for our legitimate interests (to ensure you can drive the vehicle and to satisfy us that we are prepared to provide the vehicle to you)
|Answer your enquiries which may involve contacting you by post, e-mail or phone|| |
Necessary for our legitimate interests (to ensure our customers are informed and satisfied with our services)
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)|| |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences|| |
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you|| |
(f) Marketing and Communications
(b) Necessary for our legitimate interests (to develop our products/services and grow our business)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Generally, we rely on consent as a legal basis for processing your personal data. You have the right to withdraw consent to marketing at any time by contacting us.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage, Profile and Marketing and Communications data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have opted-in to receiving marketing information from us or you have purchased services from us (or been in negotiations with us to purchase services from us) and you have not (or have not subsequently) opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by writing to us at email@example.com or by calling us on 01765 530825.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
If you are a supplier to us, you will be asked to supply certain personal data to us and we will process that personal data for the purposes of the contract that you and we enter into for the supply of your products. We will retain that personal data for a reasonable period of time thereafter for the purposes of our legitimate interests in being able to contact you in future so that you may be able to provide further goods/services to us.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out in the table above.
- External third parties such as:
- Service providers acting as processors based in the United States of America who provide IT and system administration services such as online booking systems and other IT and support services (including Woo Commerce and Microsoft One-Drive).
- Professional advisers (acting as processors or controllers) including insurers based in the United Kingdom.
- The Driver and Vehicle Licencing Agency or foreign equivalent.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes where they act for us as processors of data, and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
Some of our third party service providers are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
We may transfer Personal Data from the UK to other countries only pursuant to a specific legal basis. Any such Data transfer is usually based on one of the legal bases described below, however you can inquire with us to learn more and in particular which legal basis applies to which specific service, through the contact details provided in this policy.
Data transfer based on standard contractual clauses
If this is the legal basis, the transfer of Personal Data from the UK to other countries is carried out according to standard contractual clauses made or approved under the Data Protection Act 2018.
This means that data recipients have committed to process Personal Data in compliance with the data protection standards set forth by UK data protection legislation.
Data transfer to countries that guarantee appropriate data protection standards
If this is the legal basis, the transfer of Personal Data is carried out according to adequacy regulations made under the Data Protection Act 2018. These adequacy regulations are issued in respect of specific countries that provide Personal Data protection standards comparable to those in UK data protection legislation.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
8. DATA RETENTION
How long will you use my personal data for?
We will keep your data until you ask us to close your account or until your account becomes inactive after three years of non-use. After your account is closed or becomes inactive, we will delete your data except to the extent that we are required to retain that data if there is a legal reason for doing so (such as for tax purposes or where we need to resolve any disputes with you).
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data and you are entitled to:
- Access a copy of your personal data.
- Correct or update your personal data, which you can do yourself by logging into your account or if you would prefer, please contact us and we can help you out.
- Erase your personal data.
- Object to the processing of your personal data where we are relying on a legitimate interest (as set out in the above table).
- Restrict the processing of your personal data.
- Request the transfer of your personal data to a third party.
- Where you have provided your consent to certain of our processing activities, in certain circumstances, you may withdraw your consent at any time (but please note that we may continue to process such personal data if we have legitimate legal grounds for doing so).
If you want to exercise any of these rights, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
YOUR LEGAL RIGHTS
You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 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 we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data 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. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time 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.