SUZUKI GB PLC

SUZUKI GATEWAY PRIVACY NOTICE

1.    What is the purpose of this document?

Suzuki GB PLC (referred to as Suzuki, we, us or our) is committed to protecting the privacy and security of your personal information.

This privacy notice describes how we collect and use personal information about you when you visit the Suzuki Gateway (gateway.suzuki.co.uk) (referred to as the Gateway). This notice also explains how we collect and use personal information about you through the different applications accessed through the Gateway (referred to as the Applications).

It applies to all Suzuki employees, workers and contractors, as well as to all principals, employees, workers and contractors of our dealers.

 

Suzuki is a "data controller". This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

This notice applies to all Suzuki employees, workers and contractors, as well as to all principals, employees, workers and contractors of our dealers. This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time but if we do so, we will provide you with an updated copy of this notice as soon as reasonably practical.

It is important that you read and retain this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information and what your rights are under the data protection legislation.

2.    Data protection principles

We will comply with data protection law. This says that the personal information we hold about you must be:

1. Used lawfully, fairly and in a transparent way.

2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.

3. Relevant to the purposes we have told you about and limited only to those purposes.

4. Accurate and kept up to date.

5. Kept only as long as necessary for the purposes we have told you about.

6. Kept securely.

 

3.    The kind of information we hold about 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).

There are certain types of more sensitive personal data which require a higher level of protection, such as information about a person's health or sexual orientation, and information about criminal convictions. We do not collect or use your sensitive personal data through the Gateway or the Applications.

 

We will collect, store, and use the following categories of personal information about you:

         Identity Data, such as your first name, last name, Gateway username or similar identifier, and Gateway password.

         Contact Data, such as your work email address (which might include your name and/or initials).

         Technical Data, such as internet protocol (IP) address, 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 used to access the Gateway.

         Helpdesk Data, such as details about the problems you may be experiencing with the Gateway.

         Usage data, such as information about how you use the Gateway and the Applications.

 

4.    How is your personal information collected?

We collect personal information about Suzuki employees, workers and contractors, as well as principals, employees, workers and contractors of our dealers, directly from them.

We may also collect personal information about employees, workers and contractors of our dealers from their employer or their principal. This includes when an employer or principal:

         completes an information form when entering into their dealer agreement; and

         assigns a Gateway profile to their employees, workers and contractors.

Third parties, including our third-party Suzuki Gateway Helpdesk providers, collect personal information on our behalf. This includes when you call or email the Suzuki Gateway Helpdesk.

5.    How we will use information about you

We will only use your personal information when the law allows us to. We will use your personal information where it is necessary for our legitimate interests and your interests do not override our interests.

 

We will use your personal information to pursue our legitimate interests, provided your interests and fundamental rights do not override our interests. We do not rely on consent as a legal basis for processing 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.

Purpose/Activity

Type of data

Lawful basis for processing

To set up your Gateway profile

(a) Identity

(b) Contact

Necessary for our legitimate interests (we have a legitimate interest in allowing you to use a single sign on portal to enable us and our dealers to access and share information)

To communicate with you about your use of the Gateway and the Applications, including the provision of the Suzuki Gateway Helpdesk

(a) Identity

(b) Contact

(c) Technical

(d) Usage

Necessary for our legitimate interests (we have a legitimate interest in communicating with you to ensure that we maximise the benefits of the Gateway and the Applications)

To re-set your Gateway password

(a) Identity

(b) Contact

Necessary for our legitimate interests (we have a legitimate interest in re-setting your Gateway password so that we can manage access to the Gateway and the Applications)

If you are a principal, employee, worker or contractor of one of our dealers, to store and display your details on our Central Dealer Database

(a) Identity

(b) Contact

Necessary for our legitimate interests (we have a legitimate interest in storing and displaying your details on our Central Dealer Database to enable us and our employees, workers and contractors to contact you about business matters)

To monitor your use of the Gateway and the Applications to ensure compliance with our IT policies

(a) Technical

(b) Usage

Necessary for our legitimate interests (we have a legitimate interest in monitoring your use of the Gateway and Applications to enable us study how you use the Gateway and Applications and improve them)

To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution

(a) Identity

(b) Contact

(c) Technical

(d) Usage

Necessary for our legitimate interests (we have a legitimate interest in ensuring our network and information is secure to protect our confidential information and prevent unauthorised use of the information we hold)

 

6.    If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to provide you with access to the Gateway or the Applications.

7.    Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when the Gateway sets or accesses cookies. If you disable or refuse cookies, please note that some parts of the Gateway may become inaccessible or not function properly. For more information about the cookies we use, please see Cookie Policy.

8.    Change of purpose

We will only use your personal information 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 we need to use your personal information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

9.    Data sharing

We will share your data with third parties, including our dealers, their principals, employees, workers and contractors, third-party service providers and other companies in our group.

We require third parties to respect the security of your data and to treat it in accordance with the law.

We will transfer your personal information outside the EU. Where we do so, you can expect a similar degree of protection in respect of your personal information.

 

We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

"Third parties" includes our dealers, their principals, employees, workers and contractors, third-party service providers (including contractors and designated agents) and other companies within our group.

The following third-party service providers process personal information about you for the following purposes:

         IT service providers acting as processors based in the UK who provide the Suzuki Gateway Helpdesk; and

         IT service providers acting as processors based in the UK who provide access and authentication services in relation to the Gateway.

All our dealers, third-party service providers and other companies in the group are required to take appropriate security measures to protect your personal information in line with our policies and our contracts with them.

We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

10. Transferring information outside the EU

We do not transfer your personal data outside of the European Economic Area.

11. Data security

We have put in place measures to protect the security of your information.

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

 

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

12. How long will you use my information for?

We will only retain your personal information 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.

If you are a Suzuki employee, worker or contractor, We will retain your personal information for as long as you remain a Suzuki employee, worker or contractor, and for a further 90 days, after which point we will delete your personal information.

If you are a principal, employee, worker or contractor of one of our dealers, We retain your personal information for as long as you remain an employee, worker or contractor of one of our dealers and for a further 90 days after we have been informed by your dealer principal that you are no longer an employee, worker or contractor of the dealer, after which point we will delete your personal information.

13. Rights of access, correction, erasure, and restriction

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

         Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

         Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

         Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).

         Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.

         Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

         Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our Data Protection Manager via email at legalservices@suzuki.co.uk or write to us at Attn. Data Protection Manager, Steinbeck Crescent, Snelshall West, Milton Keynes, Buckinghamshire, MK4 4AE.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such 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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Data Protection Manager

We have appointed a Data Protection Manager to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the Data Protection Manager.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority 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.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

If you have any questions about this privacy notice, please contact our Data Protection Manager via email at legalservices@suzuki.co.uk or write to us at Attn. Data Protection Manager, Steinbeck Crescent, Snelshall West, Milton Keynes, Buckinghamshire, MK4 4AE.