2.2.1	Lancaster plc; and
2.2.2	to the extent you use the Website contact facilities to directly contact, or request contact by, one of our specific dealerships and/or locations, the Operating Company within Jardine Motors Group operating that dealership and/or site location, details of which can be obtained www.jardinemotors.co.uk.
2.3	As described below, your personal information may be shared with other members of the Jardine Motor Group that may receive and process your personal information as a data controller in their own right.
3.	What type of information does the Jardine Motors Group collect and why?
3.1	When you visit our Website, we may automatically collect standard internet and website log information and details of patterns about how website visitors behave. The information we may collect includes information about your Internet service provider, your operating system, browser type, domain name, the Internet protocol (IP) address of your computer (or other electronic Internet-enabled device), your access times, the website that referred you to us, the Web pages you request and the date and time of those requests. This may allow us to find out which parts of the Website are popular or need changing or to show you products and services of relevance to you, either on the Jardine Motors Group website or through online advertising on Google, Facebook or other websites. These details are in addition to Personal Data collected below but unless you register an account with us and use that on our website your Website usage details are not linked to other Personal Data we may collect about you.
3.2	Our collection of websites use information and may also involve the use of cookies and Web beacons. Please see our Cookies Policy https://www.jardinemotors.co.uk/site/nd-cookies-policy/ for more information.
3.3	The Website allows you to interact with Jardine Motors Group in many ways, including raising customer services enquiries, emailing us if you have a question, any feedback, suggestions for us to consider as well as interacting with us through our social media accounts including Facebook, Twitter and live chat.
3.4	We would be happy to interact with you in the ways described above. You can choose to provide us with some personal information described in more detail below. We will then collect that information for our own use and for the purposes described in this Policy.
4.	What type of personal information does Jardine Motors Group collect?
4.1	Where you choose to provide personal details to us, we may collect the following personal information from you:
•	your full name and contact information (address, city, post code, email address and telephone number);
•	your main address and contact details;
•	details of your enquiry or interest or preference(s) about our products or services, such as possible planned purchase or lease date, vehicle(s) brand, make and/or model, or vehicle requirements;
•	records of emails and correspondence with you in relation to such enquiries, negotiations, resultants sales and/or supplies your contact and marketing preferences;
•	the registration number, brand, make, model and mileage of your current vehicle;
•	in the event that you purchase a vehicle and/or services, information including registration number, brand, make, model, model year, selling dealership, servicing dealership, date of purchase, lease or service history;
•	in the event that you purchase vehicle parts, what they are, for which brand, make and model;
•	if you take a survey or interact with us in various other ways (including information about subjects that may interest you);
•	details about any marketing consents and marketing preferences;
•	customer feedback and survey results;
•	information you voluntarily submit to us (including through the Website) from time to time as part of user generated content (or through other means);
•	information necessary for legal compliance; and/or
•	information you choose to share from the Website through other social media outlets where similarly accessed through the Website (including Facebook and Twitter).
4.2	This information will be collected primarily from you as information voluntarily provided to us, but we may also collect it where lawful to do so from (and combine it with information from) public sources, third party service providers, individuals who you have indicated have agreed for you to provide their personal information, government, tax or law enforcement agencies and other third parties. We may also collect personal information about you from your use of other Jardine Motors Group websites or services. In addition, we may combine your Personal Data with other data held by third parties (such as vehicle and value data) to allow us to provide vehicle valuation services. We may also buy in data for marketing purposes.
5.	How does Jardine Motor Group use information about you?
5.1	Jardine Motor Group may use information about you for purposes described in this Policy or as otherwise disclosed to you on our Website or with our services. For example, we may use information about you for the following purposes:
•	providing our products and services to you;
•	making an appointment with you to visit one of our dealerships;
•	to respond and/or deal with your request or enquiry through the Website;
•	to administer the Website;
•	for internal record keeping (including customer enquiry, deal files, accounting and complaint files);
•	to provide a valuation of your car through the Website;
•	to contact you by e-mail or phone for any of the above reasons;
•	to provide you with information at your request, or as a result of searches undertaken using the Website;
•	undertaking customer service surveys to ensure we continually improve our service(s) to you;
•	helping us review, develop and improve the products and services we offer, for example through research, analysis and planning;
•	to communicate with you accordingly, including to provide you with customer and vehicle support, such as notifying you about changes to our products and services, any issues with them, such as product recall, and to otherwise communicate with you for example to respond to queries from you;
•	processing and retaining Personal Data relating to your credit/debit card and order details to enable the fulfilment of your order, financial applications and to deal with any queries or refunds of payment;
•	carrying out security checks to protect against fraudulent transactions at or following any purchase or order you make to prevent and detect criminal activities. For example, we may undertake verification checks to identify any discrepancies with your payment details;
•	responding to and addressing any claims made against us;
•	using cookies and traffic data as set out in Clause 3 above;
•	to carry out direct marketing to you using the details you have provided (postal address, email and/or telephone calls, messages and/or texts) for similar goods and services ;
•	to provide you with details of our products and/or services from time to time, including relevant offers, including by direct marketing by post or as otherwise agreed with you, such as by telephone, email, or otherwise;
•	to remind you about important dates, such as service due dates and warranty expiry dates;
•	to contact you from time to time to ensure your details on record are correct and up to date and to ensure we have your up to date preferences for marketing and contact;
•	to depersonalize, pseudonymize or fully anonymize and/or aggregate your data to reduce privacy intrusion but facilitate our use of the data for analysis and research, to better understand our business and customer base and their needs and to improve our products and services and business;
•	where necessary as part of any restructuring of Jardine Motors Group or sale of Jardine Motors Group company, business or assets;
•	for compliance with legal, regulatory and other good governance obligations; and
•	for the management and administration of insurance claims.
5.2	This list is not intended to be exhaustive and may be updated from time to time as business needs and legal requirements dictate. Some of the personal information that Jardine Motors Group maintains will be kept in paper files, while other personal information will be included in computerised files and electronic databases as set out in more detail below.
5.3	In most cases, the information Jardine Motors Group processes about you is required to deal with your enquiry or purchase, or required by law, or is necessary for the exercise of Jardine Motors Group legitimate business interests and needs.
5.4	Jardine Motors Group may also convert personal information into anonymous data and use it (normally on an aggregated statistical basis) for research and analysis to monitor and improve Website performance.
5.5	In addition, Jardine Motors Group may use pixels or transparent GIF files, to help manage online advertising and/or email marketing. Any information that we collect and share through such means is anonymous and not personally identifiable.
5.6	Personal information will be retained by us and other members of Jardine Motors Group for as long as is reasonably necessary (or as defined under applicable laws and regulations) to provide products and services (including after sales service) to you and to maintain records as required to satisfy tax and other legal or regulatory requirements as well as to protect and defend against claims.
5.7	Jardine Motors Group may keep your details on record for as long as is necessary for the purposes set out above and will then endeavour to delete your details in accordance with data protection and other applicable legislation.
6.	Does Jardine Motors Group share personal information with third parties?
6.1	Your personal information will only be made available for the purposes mentioned above (or as otherwise notified to you from time to time) to staff who properly need to know these details for their functions within Jardine Motors Group. Please note that certain individuals who will see your personal information may not be based at Jardine Motors Group or within the United Kingdom (please see paragraph 11 below).
7.	We may disclose your personal information to other members of the Jardine Motors Group for any of the purposes set out above and those listed below.
8.	Jardine Motors Group is authorised by a number of manufacturers to market, sell and supply specific branded vehicles, accessories, parts and related services, subject to requirements imposed by the manufacturers. In the event that you express an interest in a specific brand, especially in a particular make and model, and definitely if the interest is in a specific branded vehicle, make and model (such a wishing to place a factory order for a new car), Jardine Motors Group may share your details with the  relevant manufacturer to check vehicle availability, place an order, confirm delivery and timing, ensure warranty registration and/or service cover, deal with warranty claims and service issues, or deal with recall or comparable warnings and requirements. These manufacturers use your details independently from Jardine Motors Group and in accordance with their own privacy policies (details of which can be found on their websites).
9.	Jardine Motors Group aims to ensure high quality and secure Personal Data used within the group. Where possible, the group wishes to do so in an efficient and uniform manner worldwide. To facilitate this, Jardine Motors Group has in place an Intra Group Agreement to identify and deal with the data protection and other relevant legal requirements involved in the sharing, transfer and other processing of Personal Data between the Jardine Motors Group companies.   For further details of Jardine Motors Group, please visit www.jardinemotors.co.uk.
10.	Each of the dealerships is operated by a company within Jardine Motors Group. When you place an order for product or service at a dealership, the data controller of the Personal Data will be the Jardine Motors Group Operating Company operating that local dealership. Lancaster plc may process that data on behalf of the dealership, including financial information, to process your order. Lancaster plc also provides other services to each dealership and processes your Personal Data in that context including processing and retaining Personal Data relating to your credit/debit card and order details to enable the fulfilment of your order and to deal with any queries or refunds of payment.
10.1	Your personal information may also be made available to third parties (within or outside Jardine Motors Group) providing relevant services under contract to the Jardine Motors Group, such as finance providers, marketing agencies, auditors, compliance managers, insurers, IT hosting and IT maintenance providers. These companies may use information about you to perform their functions on our behalf.
10.2	We may disclose specific information upon lawful request by government authorities, law enforcement and regulatory authorities where required or permitted by law and for tax or other purposes. Your personal information may also be made available to third parties or partners, where necessary, as part of any restructuring of Jardine Motors Group or sale of Jardine Motors Group’s business or assets. Personal information may also be released to external parties in response to legal process, and when required to comply with laws, or to enforce our agreements, corporate policies, and terms of use, or to protect the rights, property or safety of Jardine Motors Group, our employees, agents, Website users and others, as well as to parties to whom you authorise Jardine Motors Group to release your personal information.
10.3	The Website includes links to third party websites and some of your personal information from your browsing session may be transferred to such third party websites (please see our Cookies Policy https://www.jardinemotors.co.uk/site/nd-cookies-policy/ for more information).
11.	Will your personal information be transferred abroad?
11.1	Your personal information may be transferred to, and stored, and otherwise processed in, one or more countries outside of the European Economic Area (“EEA”) where manufacturers and/or service providers are based there and/or provide services from there.
11.2	Jardine Motors Group is committed to ensuring that adequate safeguards are in place when transferring Personal Data outside the EEA, both between Jardine Motors Group companies and externally. As such, we will take reasonable steps to ensure that your personal information is adequately protected in accordance with the requirements of the UK data protection law. Unless the recipient is receiving details in the US subject to an appropriate, current and valid Privacy Shield certification, or otherwise the recipient is subject to appropriate Binding Corporate Rules in respect of the details, your Personal Data will only be transferred outside the EEA by us on the basis of European Model Clause data transfer terms (as approved by the EU Commission).
12.	What choices does Jardine Motors Group offer you with regard to direct marketing?
12.1	Jardine Motors Group may wish to provide you with information about new products, services, promotions and offers, which may be of interest to you and may invite you to take part in market research or request feedback on our products and services and our services. This communication may occur by e-mail, telephone call or message, post or text/SMS. We will obtain your consent and advise you of how to opt-out of receiving such communications where we are required to do so in accordance with applicable law. You may opt-out of direct marketing activities by contacting us as follows:
12.1.1	using the unsubscribe or opt out links in marketing communications which we send to you;
12.1.2	visiting our Customer Services Department website at centraldataservices@jardinemotorsgroup.co.uk; or
12.1.3	writing to us at Customer Services, c/o Lexus Newcastle, 22 Benton Road, Newcastle, Tyne & Wear, NE7 7EG.
12.2	This will allow you to opt out of telephone and email communications and/or to change previously submitted opt-out preferences. You can also call 0800 012 5050 to opt out of direct mail communications, as well as telephone and email communications, and/or to change previously submitted opt-out preferences.
13.	What safeguards are in place to protect your personal information?
13.1	While we take efforts to safeguard your personal information which are consistent with relevant laws, the nature of the internet is such that we cannot guarantee absolutely the security of any personal information you disclose online.
14.	What rights do you have to review and amend personal information?
14.1	You have the right to review your personal information held by Jardine Motors Group and have certain inaccurate information about you corrected. Under UK law, a request for access to your Personal Data needs to be in writing and accompanied by the statutory fee (£10).
14.2	If you wish to do so, or to contact Jardine Motors Group in respect of its data processing activities, please contact centraldataservices@jardinemotorsgroup.co.uk or write to us at   Customer Services, c/o Lexus Newcastle, 22 Benton Road, Newcastle, Tyne & Wear, NE7 7EG.
15.	Changes to this Policy
15.1	We keep this Policy under regular review. We may change this Policy from time to time by updating this page in order to reflect changes in the law and/or our privacy practices. The date at the end of this Policy will be updated accordingly.
15.2	We encourage you to check the date of this Policy when you visit the Website for any updates or changes. We will notify you of any modified versions of this Policy that might materially affect the way we use or disclose your personal information.
15.3	This Policy only extends to the Website and does not, therefore, extend to your use of, provision of data to and/or collection of data on any website not connected to us to which you may link by using the hypertext links within this website.
16.	Contact/address details
16.1	If you have any questions about this Policy, please contact us at:
Customer Services, c/o Lexus Newcastle, 22 Benton Road, Newcastle, Tyne & Wear, NE7 7EG.