Privacy Policy

SUZUKI GB PLC

PRIVACY POLICY

INTRODUCTION

Welcome to Suzuki GB PLC's consumer privacy policy (referred to as the “Policy”).

We respect your privacy and are committed to protecting your personal data. This Policy describes how we look after your personal data, including when you visit our websites (regardless of where you visit them from), and tells you about your privacy rights and how the law protects you. Please read this Policy carefully.

This Policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this Policy.

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY

IMPORTANT INFORMATION AND WHO WE ARE

Purpose of the Policy

This Policy aims to give you information on how we collect and process your personal data. 

This Policy applies to all processing of your personal data across all the products and services we provide at Suzuki and all the websites, portals, applications and social media platforms we use to support and deliver those products and services.

It is important that you read this Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data. This Policy supplements other notices and privacy policies and is not intended to override them.

We operate a network of dealers and work with other partners. Our dealers and partners are independently owned and operated businesses. We may share your personal data with our dealer network. When this happens we will do so in accordance with this policy. If you have concerns about how your personal data is processed by one of our dealers or partners, please contact them directly in the first instance.

Where we process your personal data through any third party platform such as Facebook, Instagram and/or any other social network, the privacy policies of those platforms will in addition to this privacy policy, apply to the processing of your personal data. Please note that any processing of your personal data within those platforms other than by us, is outside of our control. If you have concerns about how your personal data is processed within those platforms, please contact them directly in the first instance.

Who we are

Suzuki GB PLC (company number 00768587) of Steinbeck Crescent, Snelshall West, Milton Keynes, Buckinghamshire, MK4 4AE (referred to as “Suzuki”, “we”, “us” or “our”) is the controller and responsible for the websites, applications and social media accounts listed here  (referred to as our “Sites”).

Suzuki GB PLC is a subsidiary of Suzuki Motor Corporation, Japan (“SMC”). SMC is a separate legal entity.  It may collect personal data directly from you, or through Suzuki GB PLC or any other third party, and has its own processes and procedures for handling your personal data.  SMC’s privacy policy is available here www.globalsuzuki.com/cookies/index.html

Contacting us

If you would like to stop receiving marketing and communications from us and our nominated third parties, please contact us via email at customerservices@suzuki.co.uk, follow this link https://cars.suzuki.co.uk/contact-us/update-my-preferences/, write to the Customer Services Department at Suzuki GB PLC, Steinbeck Crescent, Snelshall West, Milton Keynes, Buckinghamshire, MK4 4AE, or call us on 08085 011959 or  01 619 3671.

If you have any questions about this Policy, including any requests to exercise your legal rights as a data subject, please contact our Data Protection Officer via email at privacy@suzuki.co.uk, write to us at Attn. Data Protection Officer, Suzuki GB PLC, Steinbeck Crescent, Snelshall West, Milton Keynes, Buckinghamshire, MK4 4AE, or call us on 08085 011959.

Changes to the Policy and your duty to inform us of changes

This version was last updated on 28^th November 2022.

Any changes we may make to this Policy in the future will be posted on this page and, where appropriate notified to you by email. Please check back frequently to see any updates or changes to this Policy.

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.

Third-party links

The Sites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave the Sites, we encourage you to read the privacy policy of every website you visit.

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. It does not include data where the identity has been removed (anonymous data).

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, age, marital status, title, date of birth, gender and household details (such as other members of your household).
• Contact Data includes house number or name, street name, town/city, county, postcode, phone number, mobile number, email address, social media account details and social media handles.
• Financial Data includes bank account, payment card details and income.
• Transaction Data includes details about how you heard about us, whether you are a Motability customer, the preferred date and time of your test drive, details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, GPS location 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 the Sites.
• Profile Data includes your username (or similar identifier) and password, purchases or orders made by you, your life stage, number of children, interests, preferences, feedback and survey responses (including your opinions of our products and services), records and recordings of telephone calls made by us, records of telephone calls made by our dealers, records and transcripts of help desk conversations conducted over ebay, and photographs, images or video of you.
• Usage Data includes information about how you use the Sites, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third party partners and your communication preferences.
• Vehicle Data includes details of your historic and current brand and model of vehicle, model description, vehicle colour, vehicle capacity, Vehicle Identification Number, vehicle registration number, key number, engine number, engine type, selected optional equipment, ownership option (purchase, rental or leasing), number of cars in your household, annual mileage, motor fuel spend, vehicle purchase spend, motor insurance spend, motoring maintenance costs, and total motoring expenditure.
• Criminal Records Data includes details of driving offences and the number of points on your driving licence.
• Health Data: May include injury details as part of an accident form.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.

We do not routinely 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). It is possible that some Special Categories of Personal Data could be collected, used, stored and transferred as part of managing and responding to your requests, queries and complaints about our products, services or dealers.  This will only occur where you volunteer this information in an email, during a telephone call or live chat, or in an open text box form on the Sites.

We will only process Criminal Records Data where we meet a specific condition in Schedule 1 of the Data Protection Act 2018 and comply with the additional safeguards set out in that Act.

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 (for example, to provide you with products or services). In this case, we may have to cancel a product or 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, Financial, Transaction, Profile and Vehicle Data by filling in forms or by corresponding with us by post, phone, email, live chat function, direct messages or comments within social media, or otherwise. This includes personal data you provide when you:
  • apply for, order, or purchase our products or services;
  • create an account on one of our Sites;
  • subscribe to our services, publications or mailing lists;
  • search for your local dealer using our Sites;
  • book a test drive;
  • book a service;
  • make an enquiry in person or online;
  • request a brochure or other marketing materials to be sent to you;
  • enter a competition, promotion or survey, or take part in a promotional event;
  • ask us a question;
  • call, email or chat to us;
  • give us some feedback; or
  • communicate with us via social media.
• Automated technologies or interactions. As you interact with our Sites, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details and to manage your cookie preferences.
• Third parties or publicly available sources. We may receive personal data about you from various third parties, including our dealer network, our partners, and public sources as set out below:
  • Technical Data from the following parties:
    • analytics providers such as Google based outside the EU. Details of how Google collects and processes data can be found here www.google.com/policies/privacy/partners/;
    • advertising networks based inside and outside the EU; and
    • search information providers based inside and outside the EU.
  • Contact, Financial and Transaction Data from providers of technical, payment, and delivery and fulfilment services inside and outside the EU.
  • Identity, Contact, Financial, Profile, Vehicle and Marketing and Communications Data from data brokers or aggregators based inside and outside the EU.
  • Identity and Contact Data from publicly availably sources based inside and outside the EU such as Companies House, the Driver and Vehicle Licensing Agency, the Electoral Register, Registration Office Ireland and the Register of Electors.
  • Identity, Contact, Financial, Transaction Data, Profile and Vehicle Data from our dealer network based inside and outside the EU.
  • Identity, Contact, Profile and Vehicle Data from our motor insurance, courtesy car, and accident, breakdown and recovery service providers based inside and outside the EU.
  • Identity, Contact, Financial, Transaction, Profile, Marketing and Communications, and Vehicle Data from our e-commerce providers based inside and outside the EU.
  • Identity, Contact, Financial, Transaction, Profile, Marketing and Communications, and Vehicle Data from our marketing and research providers based inside and outside the EU.

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 (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

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
Sales
To register you as a new customer	(a) Identity (b) Contact	Performance of a contract with you
To find your local dealer using our Sites, including when you contact us via our live chat function	Contact	Necessary for our legitimate interests (necessary to fulfil requests you make to us relating to our dealer network)
To arrange a test drive/ride, which will include sharing your personal data with our dealers	(a) Identity (b) Contact	Necessary for our legitimate interests (necessary to fulfil requests you make to us relating to our products and services)
To send you a brochure and to allow you to sign-up to mailing lists for our products and services	(a) Identity (b) Contact	Necessary for our legitimate interests (necessary to fulfil requests you make to us relating to our products and services)
To configure your vehicle or product	(a) Identity (b) Contact	(a) Performance of a contract with you (b) Necessary for our legitimate interests (necessary to respond to your needs for a particular product)
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications (f) Vehicle	(a) Performance of a contract with you (b) Necessary for our legitimate interests (necessary to provide you with a product that meets your order and necessary to recover debts due to us)
To validate ownership of a vehicle when brought to a dealer, and maintain ownership records	(a) Identity (b) Contact (c) Vehicle	Performance of a contract with you
Marketing
To enable you to take part in a prize draw, competition or complete a survey and, if you win, to deliver prizes to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	Necessary for our legitimate interests (necessary for promoting our business, brand, products and services)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	(a) Necessary for our legitimate interests (to develop our products/services and grow our business) (b) You have provided your consent to us to process your personal data for the purpose of direct marketing
To notify you about the opening and closing of Suzuki dealers in your area	(a) Identity (b) Contact (c) Vehicle	Necessary for our legitimate interests (to keeping to informed about where you can access sales and after-sales services)
To evaluate the success of dealer promotional events	(a) Identity (b) Contact (c) Profile (d) Vehicle	Necessary for our legitimate interests (necessary for promoting our business, brand, products and services and necessary for measuring the marketing performance of our dealers)
To process requests for sponsorship, complimentary or promotional products and merchandise, or to provide you with such items	(a) Identity (b) Contact (c) Vehicle	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to offer and provide you with ancillary products and services from us and our partners)
To measure your experience when receiving services from our dealers	(a) Identity (b) Financial (c) Transaction (d) Contact (e) Profile (f) Vehicle	Necessary for our legitimate interests (necessary for promoting our business, brand, products and services and necessary for measuring the performance of our dealers)
To profile your motivations, values and needs so that we can make the content of our marketing and communications more relevant to you, see “Profiling” paragraph below	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Vehicle	Necessary for our legitimate interests (necessary for promoting our business, brand, products and services)
To enable you to take part in promotional events and advertising, and to allow us to create and share marketing content	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Vehicle	You have given your consent to the processing
To include your comments, opinions, content and photos in our marketing activities	(a) Identity (b) Vehicle	You have given your consent to the processing
IT and Administration
To administer and protect our business and the Sites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (necessary to administer our business, ensure network security and prevent fraud (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical (g) Vehicle	Necessary for our legitimate interests (necessary to analyse how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics and profiling to improve the Sites, products/services, marketing, customer relationships and experiences	(a) Identity (b) Contact (c) Technical (d) Profile (e) Usage (f) Marketing and Communications (g) Vehicle	Necessary for our legitimate interests (to define types of customers for our products and services, to keep the Sites updated and relevant, to develop our business and to inform our marketing strategy)
Aftersales and Customer Care
If you take insurance cover, to monitor the performance and take-up of such insurance	Vehicle	Necessary for our legitimate interests (necessary for management reporting)
To register your warranty, provide you with warranty and after-sales services, or to determine whether a repair can be undertaken under warranty	(a) Identity (b) Contact (c) Vehicle	Performance of a contract with you
To offer and allow for the provision of accident, breakdown and recovery services by our third party providers	(a) Identity (b) Contact (c) Vehicle	Performance of a contract with you
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or Policy (b) Asking you to leave a review or take a survey (c) Checking and updating the information we hold about you (d) Analysing how you use our products and services (e) Complying with requests from you to exercise your data subject rights	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Vehicle	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (necessary to administer our business)
To manage and investigate reports of product defects	(a) Identity (b) Contact (c) Vehicle (d) Health Data	Necessary for our legitimate interests (necessary for ensuring the safety and performance of our products) Necessary to comply with a legal obligation
To contact you in the event of any urgent safety or product recall notices	(a) Identity (b) Contact (c) Vehicle	Necessary in order to protect your vital interests or the vital interests of another person
To manage and respond to your requests, queries and complaints about our products, services or dealers	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Vehicle	Necessary for our legitimate interests (necessary for managing your requests, queries, complaints and claims, and for sending communications to you in relation to such requests, queries, complaints and claims)
To register your vehicle with the DVLA	(a) Identity (b) Contact (c) Vehicle	Necessary to comply with a legal obligation
If you make a request, to generate a Certificate of Conformity	(a) Identity (b) Financial (c) Transaction (d) Contact (e) Profile (f) Vehicle	Performance of a contract with you
Corporate
To enforce or protect our contractual or other legal rights or to bring or defend legal proceedings	(a) Identity (b) Financial (c) Transaction (d) Contact (e) Profile (f) Usage (g) Marketing and Communications (h) Technical (i) Vehicle	Necessary for our legitimate interests (necessary to enforce and protect our legal rights)
For the purposes of corporate restructures, reorganisations, or sale of our business or assets	(a) Identity (b) Financial (c) Transaction (d) Contact (e) Profile (f) Usage (g) Marketing and Communications (h) Technical (i) Vehicle	Necessary for our legitimate interests (necessary to enable the restructure, reorganisation, sale, or integration of our business)
For the purposes of providing a report on fuel economy data to the UK Government and European Commission. This may involve us sharing the data with SMC for submission to the European Commission and UK Government.	(a) Vehicle	Necessary to comply with a legal obligation.

Profiling

We may from time to time profile your personal data to help us understand your motivations, values and needs. It only takes place to help us make the content of our marketing and communications more relevant to you.  We use your Identity, Contact, Financial, Profile and Vehicle Data to carry out this profiling.  You can always object to our profiling by emailing us at privacy@suzuki.co.uk or by writing to us at Attn. Data Protection Officer, Suzuki GB PLC, Steinbeck Crescent, Snelshall West, Milton Keynes, Buckinghamshire, MK4 4AE. Any profiling data that we hold about you will be refreshed every 3 months.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage, Profile, Marketing and Communications, and Vehicle 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 products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased products or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the Suzuki GB PLC group of companies for marketing purposes.

Opting out

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you, by contacting us at any time at customerservices@suzuki.co.uk, or by completing the form at https://cars.suzuki.co.uk/contact-us/update-my-preferences/.  You can ask third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies

Like many websites, we use “cookies” to enable us to personalise your visits to our Sites, keep track of your preferences and to track the usage of our Sites.

You can manage your cookies from within our cookie preference centre. If you disable or refuse cookies, please note that some parts of the Sites may become inaccessible or not function properly. For more information about the cookies we use, please see https://cars.suzuki.co.uk/privacy/cookie-policy/.

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.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Policy.

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 and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

The personal data we collect from you may be transferred outside the European Economic Area (“EEA”).

It may also be processed by staff operating outside the EEA who work for us or for one of the suppliers or contractors. Territories outside of the EEA may not have equivalent legal protections to those that apply within the EEA but we are under a duty to make sure that our suppliers and contractors located outside of the EEA continue to take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Policy. By submitting your personal data to us, you agree to this transfer, storing or processing.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. DATA SECURITY

All information that you provide to us is stored on our secure servers and any payment transaction are protected using SSL technology.

The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to us or our Sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

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.

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

8. DATA RETENTION

How long will you use my personal data for?

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.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances you can ask us to delete your data, see below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

• The right to ask us not to process your personal data at any time.
• The right to use our products, services and Sites without consenting to marketing and communication services that we provide. We will inform you (before collecting your data) if we intend to use your personal data for such purposes or if we intend to disclose your information to any third party for such purposes.
• The right to request access to or rectification of your personal data which we hold about you.
• The right to erase your personal data to restrict the processing of your personal data.
• The right to receive your personal data that you have provided to us.
• The right to object to our processing of your personal data.
• The right to request that we transmit your personal data to another data controller.

Where we process your personal data because you have given us your consent to do so, you have the right to withdraw your consent at any time.

To exercise any of the rights, please contact the Data Protection Officer whose contact details are provided earlier in this Policy.  

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), or to the national supervisory authority responsible for data protection issues in your EU member state. The national supervisory authority for data protection issues in Ireland is the Data Protection Commissioner (www.dataprotection.ie). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

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 may exercise our right not 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 may 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.

10. GLOSSARY

LAWFUL BASIS

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 personal 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 or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Vital Interests means processing your personal data is necessary in order to protect the vital interests of the data subject or of another natural person.

Consent means that you have agreed to the processing of your personal data by providing us with a freely given, specific, informed and unambiguous indication of your wishes by a statement or by a clear affirmative action.

THIRD PARTIES

Internal Third Parties

Other companies in the Suzuki GB PLC group, including SMC, which are based outside of the European Union. Where your personal data is transferred outside of the European Economic Area, we will ensure that we have put in place adequacy measures which comply with the GDPR to enable the lawful transfer of your personal data.

External Third Parties

• Dealers and partners in our network acting as controllers or joint controllers based in the United Kingdom and Ireland who provide pre-sales, sales and after-sales services in relation to our products and services.
• Service providers acting as processors based in the United Kingdom and Germany who provide IT, e-commerce and system administration services.
• Service providers acting as processors based in the United Kingdom who provide marketing and research services.
• Service providers acting as processors based in the United Kingdom who provide, warranty registration, motor insurance, courtesy car, and accident, breakdown and recovery services.
• Service providers acting as processors based in the United Kingdom who provide delivery and fulfilment services.
• Service providers acting as processors based in the United Kingdom who provide assistance with product recalls.
• Professional advisers acting as processors, controllers or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, privacy consultants, insurance and accounting services.
• DVLA, HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

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: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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.

SUZUKI GB PLC

PRIVACY POLICY

INTRODUCTION

Welcome to Suzuki GB PLC's consumer privacy policy (referred to as the “Policy”).

We respect your privacy and are committed to protecting your personal data. This Policy describes how we look after your personal data, including when you visit our websites (regardless of where you visit them from), and tells you about your privacy rights and how the law protects you. Please read this Policy carefully.

This Policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this Policy.

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY
11. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of the Policy

This Policy aims to give you information on how we collect and process your personal data. 

This Policy applies to all processing of your personal data across all the products and services we provide at Suzuki and all the websites, portals, applications and social media platforms we use to support and deliver those products and services.

It is important that you read this Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data. This Policy supplements other notices and privacy policies and is not intended to override them.

We operate a network of dealers and work with other partners. Our dealers and partners are independently owned and operated businesses. We may share your personal data with our dealer network. When this happens we will do so in accordance with this policy. If you have concerns about how your personal data is processed by one of our dealers or partners, please contact them directly in the first instance.

Where we process your personal data through any third party platform such as Facebook, Instagram and/or any other social network, the privacy policies of those platforms will in addition to this privacy policy, apply to the processing of your personal data. Please note that any processing of your personal data within those platforms other than by us, is outside of our control. If you have concerns about how your personal data is processed within those platforms, please contact them directly in the first instance.

Who we are

Suzuki GB PLC (company number 00768587) of Steinbeck Crescent, Snelshall West, Milton Keynes, Buckinghamshire, MK4 4AE (referred to as “Suzuki”, “we”, “us” or “our”) is the controller and responsible for the websites, applications and social media accounts listed here  (referred to as our “Sites”).

Suzuki GB PLC is a subsidiary of Suzuki Motor Corporation, Japan (“SMC”). SMC is a separate legal entity.  It may collect personal data directly from you, or through Suzuki GB PLC or any other third party, and has its own processes and procedures for handling your personal data.  SMC’s privacy policy is available here www.globalsuzuki.com/cookies/index.html

Contacting us

If you would like to stop receiving marketing and communications from us and our nominated third parties, please contact us via email at customerservices@suzuki.co.uk, follow this link https://cars.suzuki.co.uk/contact-us/update-my-preferences/, write to the Customer Services Department at Suzuki GB PLC, Steinbeck Crescent, Snelshall West, Milton Keynes, Buckinghamshire, MK4 4AE, or call us on 08085 011959 or  01 619 3671.

If you have any questions about this Policy, including any requests to exercise your legal rights as a data subject, please contact our Data Protection Officer via email at privacy@suzuki.co.uk, write to us at Attn. Data Protection Officer, Suzuki GB PLC, Steinbeck Crescent, Snelshall West, Milton Keynes, Buckinghamshire, MK4 4AE, or call us on 08085 011959.

Changes to the Policy and your duty to inform us of changes

This version was last updated on 28^th November 2022.

Any changes we may make to this Policy in the future will be posted on this page and, where appropriate notified to you by email. Please check back frequently to see any updates or changes to this Policy.

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.

Third-party links

The Sites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave the Sites, we encourage you to read the privacy policy of every website you visit.

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. It does not include data where the identity has been removed (anonymous data).

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, age, marital status, title, date of birth, gender and household details (such as other members of your household).
• Contact Data includes house number or name, street name, town/city, county, postcode, phone number, mobile number, email address, social media account details and social media handles.
• Financial Data includes bank account, payment card details and income.
• Transaction Data includes details about how you heard about us, whether you are a Motability customer, the preferred date and time of your test drive, details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, GPS location 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 the Sites.
• Profile Data includes your username (or similar identifier) and password, purchases or orders made by you, your life stage, number of children, interests, preferences, feedback and survey responses (including your opinions of our products and services), records and recordings of telephone calls made by us, records of telephone calls made by our dealers, records and transcripts of help desk conversations conducted over ebay, and photographs, images or video of you.
• Usage Data includes information about how you use the Sites, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third party partners and your communication preferences.
• Vehicle Data includes details of your historic and current brand and model of vehicle, model description, vehicle colour, vehicle capacity, Vehicle Identification Number, vehicle registration number, key number, engine number, engine type, selected optional equipment, ownership option (purchase, rental or leasing), number of cars in your household, annual mileage, motor fuel spend, vehicle purchase spend, motor insurance spend, motoring maintenance costs, and total motoring expenditure.
• Criminal Records Data includes details of driving offences and the number of points on your driving licence.
• Health Data: May include injury details as part of an accident form.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.

We do not routinely 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). It is possible that some Special Categories of Personal Data could be collected, used, stored and transferred as part of managing and responding to your requests, queries and complaints about our products, services or dealers.  This will only occur where you volunteer this information in an email, during a telephone call or live chat, or in an open text box form on the Sites.

We will only process Criminal Records Data where we meet a specific condition in Schedule 1 of the Data Protection Act 2018 and comply with the additional safeguards set out in that Act.

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 (for example, to provide you with products or services). In this case, we may have to cancel a product or 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, Financial, Transaction, Profile and Vehicle Data by filling in forms or by corresponding with us by post, phone, email, live chat function, direct messages or comments within social media, or otherwise. This includes personal data you provide when you:
  • apply for, order, or purchase our products or services;
  • create an account on one of our Sites;
  • subscribe to our services, publications or mailing lists;
  • search for your local dealer using our Sites;
  • book a test drive;
  • book a service;
  • make an enquiry in person or online;
  • request a brochure or other marketing materials to be sent to you;
  • enter a competition, promotion or survey, or take part in a promotional event;
  • ask us a question;
  • call, email or chat to us;
  • give us some feedback; or
  • communicate with us via social media.
• Automated technologies or interactions. As you interact with our Sites, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details and to manage your cookie preferences.
• Third parties or publicly available sources. We may receive personal data about you from various third parties, including our dealer network, our partners, and public sources as set out below:
  • Technical Data from the following parties:
    • analytics providers such as Google based outside the EU. Details of how Google collects and processes data can be found here www.google.com/policies/privacy/partners/;
    • advertising networks based inside and outside the EU; and
    • search information providers based inside and outside the EU.
  • Contact, Financial and Transaction Data from providers of technical, payment, and delivery and fulfilment services inside and outside the EU.
  • Identity, Contact, Financial, Profile, Vehicle and Marketing and Communications Data from data brokers or aggregators based inside and outside the EU.
  • Identity and Contact Data from publicly availably sources based inside and outside the EU such as Companies House, the Driver and Vehicle Licensing Agency, the Electoral Register, Registration Office Ireland and the Register of Electors.
  • Identity, Contact, Financial, Transaction Data, Profile and Vehicle Data from our dealer network based inside and outside the EU.
  • Identity, Contact, Profile and Vehicle Data from our motor insurance, courtesy car, and accident, breakdown and recovery service providers based inside and outside the EU.
  • Identity, Contact, Financial, Transaction, Profile, Marketing and Communications, and Vehicle Data from our e-commerce providers based inside and outside the EU.
  • Identity, Contact, Financial, Transaction, Profile, Marketing and Communications, and Vehicle Data from our marketing and research providers based inside and outside the EU.

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 (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

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
Sales
To register you as a new customer	(a) Identity (b) Contact	Performance of a contract with you
To find your local dealer using our Sites, including when you contact us via our live chat function	Contact	Necessary for our legitimate interests (necessary to fulfil requests you make to us relating to our dealer network)
To arrange a test drive/ride, which will include sharing your personal data with our dealers	(a) Identity (b) Contact	Necessary for our legitimate interests (necessary to fulfil requests you make to us relating to our products and services)
To send you a brochure and to allow you to sign-up to mailing lists for our products and services	(a) Identity (b) Contact	Necessary for our legitimate interests (necessary to fulfil requests you make to us relating to our products and services)
To configure your vehicle or product	(a) Identity (b) Contact	(a) Performance of a contract with you (b) Necessary for our legitimate interests (necessary to respond to your needs for a particular product)
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications (f) Vehicle	(a) Performance of a contract with you (b) Necessary for our legitimate interests (necessary to provide you with a product that meets your order and necessary to recover debts due to us)
To validate ownership of a vehicle when brought to a dealer, and maintain ownership records	(a) Identity (b) Contact (c) Vehicle	Performance of a contract with you
Marketing
To enable you to take part in a prize draw, competition or complete a survey and, if you win, to deliver prizes to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	Necessary for our legitimate interests (necessary for promoting our business, brand, products and services)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	(a) Necessary for our legitimate interests (to develop our products/services and grow our business) (b) You have provided your consent to us to process your personal data for the purpose of direct marketing
To notify you about the opening and closing of Suzuki dealers in your area	(a) Identity (b) Contact (c) Vehicle	Necessary for our legitimate interests (to keeping to informed about where you can access sales and after-sales services)
To evaluate the success of dealer promotional events	(a) Identity (b) Contact (c) Profile (d) Vehicle	Necessary for our legitimate interests (necessary for promoting our business, brand, products and services and necessary for measuring the marketing performance of our dealers)
To process requests for sponsorship, complimentary or promotional products and merchandise, or to provide you with such items	(a) Identity (b) Contact (c) Vehicle	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to offer and provide you with ancillary products and services from us and our partners)
To measure your experience when receiving services from our dealers	(a) Identity (b) Financial (c) Transaction (d) Contact (e) Profile (f) Vehicle	Necessary for our legitimate interests (necessary for promoting our business, brand, products and services and necessary for measuring the performance of our dealers)
To profile your motivations, values and needs so that we can make the content of our marketing and communications more relevant to you, see “Profiling” paragraph below	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Vehicle	Necessary for our legitimate interests (necessary for promoting our business, brand, products and services)
To enable you to take part in promotional events and advertising, and to allow us to create and share marketing content	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Vehicle	You have given your consent to the processing
To include your comments, opinions, content and photos in our marketing activities	(a) Identity (b) Vehicle	You have given your consent to the processing
IT and Administration
To administer and protect our business and the Sites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (necessary to administer our business, ensure network security and prevent fraud (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical (g) Vehicle	Necessary for our legitimate interests (necessary to analyse how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics and profiling to improve the Sites, products/services, marketing, customer relationships and experiences	(a) Identity (b) Contact (c) Technical (d) Profile (e) Usage (f) Marketing and Communications (g) Vehicle	Necessary for our legitimate interests (to define types of customers for our products and services, to keep the Sites updated and relevant, to develop our business and to inform our marketing strategy)
Aftersales and Customer Care
If you take insurance cover, to monitor the performance and take-up of such insurance	Vehicle	Necessary for our legitimate interests (necessary for management reporting)
To register your warranty, provide you with warranty and after-sales services, or to determine whether a repair can be undertaken under warranty	(a) Identity (b) Contact (c) Vehicle	Performance of a contract with you
To offer and allow for the provision of accident, breakdown and recovery services by our third party providers	(a) Identity (b) Contact (c) Vehicle	Performance of a contract with you
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or Policy (b) Asking you to leave a review or take a survey (c) Checking and updating the information we hold about you (d) Analysing how you use our products and services (e) Complying with requests from you to exercise your data subject rights	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Vehicle	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (necessary to administer our business)
To manage and investigate reports of product defects	(a) Identity (b) Contact (c) Vehicle (d) Health Data	Necessary for our legitimate interests (necessary for ensuring the safety and performance of our products) Necessary to comply with a legal obligation
To contact you in the event of any urgent safety or product recall notices	(a) Identity (b) Contact (c) Vehicle	Necessary in order to protect your vital interests or the vital interests of another person
To manage and respond to your requests, queries and complaints about our products, services or dealers	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Vehicle	Necessary for our legitimate interests (necessary for managing your requests, queries, complaints and claims, and for sending communications to you in relation to such requests, queries, complaints and claims)
To register your vehicle with the DVLA	(a) Identity (b) Contact (c) Vehicle	Necessary to comply with a legal obligation
If you make a request, to generate a Certificate of Conformity	(a) Identity (b) Financial (c) Transaction (d) Contact (e) Profile (f) Vehicle	Performance of a contract with you
Corporate
To enforce or protect our contractual or other legal rights or to bring or defend legal proceedings	(a) Identity (b) Financial (c) Transaction (d) Contact (e) Profile (f) Usage (g) Marketing and Communications (h) Technical (i) Vehicle	Necessary for our legitimate interests (necessary to enforce and protect our legal rights)
For the purposes of corporate restructures, reorganisations, or sale of our business or assets	(a) Identity (b) Financial (c) Transaction (d) Contact (e) Profile (f) Usage (g) Marketing and Communications (h) Technical (i) Vehicle	Necessary for our legitimate interests (necessary to enable the restructure, reorganisation, sale, or integration of our business)
For the purposes of providing a report on fuel economy data to the UK Government and European Commission. This may involve us sharing the data with SMC for submission to the European Commission and UK Government.	(a) Vehicle	Necessary to comply with a legal obligation.

Profiling

We may from time to time profile your personal data to help us understand your motivations, values and needs. It only takes place to help us make the content of our marketing and communications more relevant to you.  We use your Identity, Contact, Financial, Profile and Vehicle Data to carry out this profiling.  You can always object to our profiling by emailing us at privacy@suzuki.co.uk or by writing to us at Attn. Data Protection Officer, Suzuki GB PLC, Steinbeck Crescent, Snelshall West, Milton Keynes, Buckinghamshire, MK4 4AE. Any profiling data that we hold about you will be refreshed every 3 months.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage, Profile, Marketing and Communications, and Vehicle 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 products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased products or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the Suzuki GB PLC group of companies for marketing purposes.

Opting out

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you, by contacting us at any time at customerservices@suzuki.co.uk, or by completing the form at https://cars.suzuki.co.uk/contact-us/update-my-preferences/.  You can ask third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies

Like many websites, we use “cookies” to enable us to personalise your visits to our Sites, keep track of your preferences and to track the usage of our Sites.

You can manage your cookies from within our cookie preference centre. If you disable or refuse cookies, please note that some parts of the Sites may become inaccessible or not function properly. For more information about the cookies we use, please see https://cars.suzuki.co.uk/privacy/cookie-policy/.

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.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Policy.

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 and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

The personal data we collect from you may be transferred outside the European Economic Area (“EEA”).

It may also be processed by staff operating outside the EEA who work for us or for one of the suppliers or contractors. Territories outside of the EEA may not have equivalent legal protections to those that apply within the EEA but we are under a duty to make sure that our suppliers and contractors located outside of the EEA continue to take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Policy. By submitting your personal data to us, you agree to this transfer, storing or processing.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. DATA SECURITY

All information that you provide to us is stored on our secure servers and any payment transaction are protected using SSL technology.

The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to us or our Sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

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.

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

8. DATA RETENTION

How long will you use my personal data for?

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.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances you can ask us to delete your data, see below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

• The right to ask us not to process your personal data at any time.
• The right to use our products, services and Sites without consenting to marketing and communication services that we provide. We will inform you (before collecting your data) if we intend to use your personal data for such purposes or if we intend to disclose your information to any third party for such purposes.
• The right to request access to or rectification of your personal data which we hold about you.
• The right to erase your personal data to restrict the processing of your personal data.
• The right to receive your personal data that you have provided to us.
• The right to object to our processing of your personal data.
• The right to request that we transmit your personal data to another data controller.

Where we process your personal data because you have given us your consent to do so, you have the right to withdraw your consent at any time.

To exercise any of the rights, please contact the Data Protection Officer whose contact details are provided earlier in this Policy.  

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), or to the national supervisory authority responsible for data protection issues in your EU member state. The national supervisory authority for data protection issues in Ireland is the Data Protection Commissioner (www.dataprotection.ie). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

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 may exercise our right not 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 may 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.

10. GLOSSARY

LAWFUL BASIS

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 personal 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 or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Vital Interests means processing your personal data is necessary in order to protect the vital interests of the data subject or of another natural person.

Consent means that you have agreed to the processing of your personal data by providing us with a freely given, specific, informed and unambiguous indication of your wishes by a statement or by a clear affirmative action.

THIRD PARTIES

Internal Third Parties

Other companies in the Suzuki GB PLC group, including SMC, which are based outside of the European Union. Where your personal data is transferred outside of the European Economic Area, we will ensure that we have put in place adequacy measures which comply with the GDPR to enable the lawful transfer of your personal data.

External Third Parties

• Dealers and partners in our network acting as controllers or joint controllers based in the United Kingdom and Ireland who provide pre-sales, sales and after-sales services in relation to our products and services.
• Service providers acting as processors based in the United Kingdom and Germany who provide IT, e-commerce and system administration services.
• Service providers acting as processors based in the United Kingdom who provide marketing and research services.
• Service providers acting as processors based in the United Kingdom who provide, warranty registration, motor insurance, courtesy car, and accident, breakdown and recovery services.
• Service providers acting as processors based in the United Kingdom who provide delivery and fulfilment services.
• Service providers acting as processors based in the United Kingdom who provide assistance with product recalls.
• Professional advisers acting as processors, controllers or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, privacy consultants, insurance and accounting services.
• DVLA, HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

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: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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.

SUZUKI GB PLC

PRIVACY POLICY

INTRODUCTION

Welcome to Suzuki GB PLC's consumer privacy policy (referred to as the “Policy”).

We respect your privacy and are committed to protecting your personal data. This Policy describes how we look after your personal data, including when you visit our websites (regardless of where you visit them from), and tells you about your privacy rights and how the law protects you. Please read this Policy carefully.

This Policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this Policy.

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY
11. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of the Policy

This Policy aims to give you information on how we collect and process your personal data. 

This Policy applies to all processing of your personal data across all the products and services we provide at Suzuki and all the websites, portals, applications and social media platforms we use to support and deliver those products and services.

It is important that you read this Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data. This Policy supplements other notices and privacy policies and is not intended to override them.

We operate a network of dealers and work with other partners. Our dealers and partners are independently owned and operated businesses. We may share your personal data with our dealer network. When this happens we will do so in accordance with this policy. If you have concerns about how your personal data is processed by one of our dealers or partners, please contact them directly in the first instance.

Where we process your personal data through any third party platform such as Facebook, Instagram and/or any other social network, the privacy policies of those platforms will in addition to this privacy policy, apply to the processing of your personal data. Please note that any processing of your personal data within those platforms other than by us, is outside of our control. If you have concerns about how your personal data is processed within those platforms, please contact them directly in the first instance.

Who we are

Suzuki GB PLC (company number 00768587) of Steinbeck Crescent, Snelshall West, Milton Keynes, Buckinghamshire, MK4 4AE (referred to as “Suzuki”, “we”, “us” or “our”) is the controller and responsible for the websites, applications and social media accounts listed here  (referred to as our “Sites”).

Suzuki GB PLC is a subsidiary of Suzuki Motor Corporation, Japan (“SMC”). SMC is a separate legal entity.  It may collect personal data directly from you, or through Suzuki GB PLC or any other third party, and has its own processes and procedures for handling your personal data.  SMC’s privacy policy is available here www.globalsuzuki.com/cookies/index.html

Contacting us

If you would like to stop receiving marketing and communications from us and our nominated third parties, please contact us via email at customerservices@suzuki.co.uk, follow this link https://cars.suzuki.co.uk/contact-us/update-my-preferences/, write to the Customer Services Department at Suzuki GB PLC, Steinbeck Crescent, Snelshall West, Milton Keynes, Buckinghamshire, MK4 4AE, or call us on 08085 011959 or  01 619 3671.

If you have any questions about this Policy, including any requests to exercise your legal rights as a data subject, please contact our Data Protection Officer via email at privacy@suzuki.co.uk, write to us at Attn. Data Protection Officer, Suzuki GB PLC, Steinbeck Crescent, Snelshall West, Milton Keynes, Buckinghamshire, MK4 4AE, or call us on 08085 011959.

Changes to the Policy and your duty to inform us of changes

This version was last updated on 28^th November 2022.

Any changes we may make to this Policy in the future will be posted on this page and, where appropriate notified to you by email. Please check back frequently to see any updates or changes to this Policy.

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.

Third-party links

The Sites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave the Sites, we encourage you to read the privacy policy of every website you visit.

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. It does not include data where the identity has been removed (anonymous data).

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, age, marital status, title, date of birth, gender and household details (such as other members of your household).
• Contact Data includes house number or name, street name, town/city, county, postcode, phone number, mobile number, email address, social media account details and social media handles.
• Financial Data includes bank account, payment card details and income.
• Transaction Data includes details about how you heard about us, whether you are a Motability customer, the preferred date and time of your test drive, details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, GPS location 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 the Sites.
• Profile Data includes your username (or similar identifier) and password, purchases or orders made by you, your life stage, number of children, interests, preferences, feedback and survey responses (including your opinions of our products and services), records and recordings of telephone calls made by us, records of telephone calls made by our dealers, records and transcripts of help desk conversations conducted over ebay, and photographs, images or video of you.
• Usage Data includes information about how you use the Sites, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third party partners and your communication preferences.
• Vehicle Data includes details of your historic and current brand and model of vehicle, model description, vehicle colour, vehicle capacity, Vehicle Identification Number, vehicle registration number, key number, engine number, engine type, selected optional equipment, ownership option (purchase, rental or leasing), number of cars in your household, annual mileage, motor fuel spend, vehicle purchase spend, motor insurance spend, motoring maintenance costs, and total motoring expenditure.
• Criminal Records Data includes details of driving offences and the number of points on your driving licence.
• Health Data: May include injury details as part of an accident form.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.

We do not routinely 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). It is possible that some Special Categories of Personal Data could be collected, used, stored and transferred as part of managing and responding to your requests, queries and complaints about our products, services or dealers.  This will only occur where you volunteer this information in an email, during a telephone call or live chat, or in an open text box form on the Sites.

We will only process Criminal Records Data where we meet a specific condition in Schedule 1 of the Data Protection Act 2018 and comply with the additional safeguards set out in that Act.

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 (for example, to provide you with products or services). In this case, we may have to cancel a product or 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, Financial, Transaction, Profile and Vehicle Data by filling in forms or by corresponding with us by post, phone, email, live chat function, direct messages or comments within social media, or otherwise. This includes personal data you provide when you:
  • apply for, order, or purchase our products or services;
  • create an account on one of our Sites;
  • subscribe to our services, publications or mailing lists;
  • search for your local dealer using our Sites;
  • book a test drive;
  • book a service;
  • make an enquiry in person or online;
  • request a brochure or other marketing materials to be sent to you;
  • enter a competition, promotion or survey, or take part in a promotional event;
  • ask us a question;
  • call, email or chat to us;
  • give us some feedback; or
  • communicate with us via social media.
• Automated technologies or interactions. As you interact with our Sites, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details and to manage your cookie preferences.
• Third parties or publicly available sources. We may receive personal data about you from various third parties, including our dealer network, our partners, and public sources as set out below:
  • Technical Data from the following parties:
    • analytics providers such as Google based outside the EU. Details of how Google collects and processes data can be found here www.google.com/policies/privacy/partners/;
    • advertising networks based inside and outside the EU; and
    • search information providers based inside and outside the EU.
  • Contact, Financial and Transaction Data from providers of technical, payment, and delivery and fulfilment services inside and outside the EU.
  • Identity, Contact, Financial, Profile, Vehicle and Marketing and Communications Data from data brokers or aggregators based inside and outside the EU.
  • Identity and Contact Data from publicly availably sources based inside and outside the EU such as Companies House, the Driver and Vehicle Licensing Agency, the Electoral Register, Registration Office Ireland and the Register of Electors.
  • Identity, Contact, Financial, Transaction Data, Profile and Vehicle Data from our dealer network based inside and outside the EU.
  • Identity, Contact, Profile and Vehicle Data from our motor insurance, courtesy car, and accident, breakdown and recovery service providers based inside and outside the EU.
  • Identity, Contact, Financial, Transaction, Profile, Marketing and Communications, and Vehicle Data from our e-commerce providers based inside and outside the EU.
  • Identity, Contact, Financial, Transaction, Profile, Marketing and Communications, and Vehicle Data from our marketing and research providers based inside and outside the EU.

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 (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

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
Sales
To register you as a new customer	(a) Identity (b) Contact	Performance of a contract with you
To find your local dealer using our Sites, including when you contact us via our live chat function	Contact	Necessary for our legitimate interests (necessary to fulfil requests you make to us relating to our dealer network)
To arrange a test drive/ride, which will include sharing your personal data with our dealers	(a) Identity (b) Contact	Necessary for our legitimate interests (necessary to fulfil requests you make to us relating to our products and services)
To send you a brochure and to allow you to sign-up to mailing lists for our products and services	(a) Identity (b) Contact	Necessary for our legitimate interests (necessary to fulfil requests you make to us relating to our products and services)
To configure your vehicle or product	(a) Identity (b) Contact	(a) Performance of a contract with you (b) Necessary for our legitimate interests (necessary to respond to your needs for a particular product)
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications (f) Vehicle	(a) Performance of a contract with you (b) Necessary for our legitimate interests (necessary to provide you with a product that meets your order and necessary to recover debts due to us)
To validate ownership of a vehicle when brought to a dealer, and maintain ownership records	(a) Identity (b) Contact (c) Vehicle	Performance of a contract with you
Marketing
To enable you to take part in a prize draw, competition or complete a survey and, if you win, to deliver prizes to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	Necessary for our legitimate interests (necessary for promoting our business, brand, products and services)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	(a) Necessary for our legitimate interests (to develop our products/services and grow our business) (b) You have provided your consent to us to process your personal data for the purpose of direct marketing
To notify you about the opening and closing of Suzuki dealers in your area	(a) Identity (b) Contact (c) Vehicle	Necessary for our legitimate interests (to keeping to informed about where you can access sales and after-sales services)
To evaluate the success of dealer promotional events	(a) Identity (b) Contact (c) Profile (d) Vehicle	Necessary for our legitimate interests (necessary for promoting our business, brand, products and services and necessary for measuring the marketing performance of our dealers)
To process requests for sponsorship, complimentary or promotional products and merchandise, or to provide you with such items	(a) Identity (b) Contact (c) Vehicle	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to offer and provide you with ancillary products and services from us and our partners)
To measure your experience when receiving services from our dealers	(a) Identity (b) Financial (c) Transaction (d) Contact (e) Profile (f) Vehicle	Necessary for our legitimate interests (necessary for promoting our business, brand, products and services and necessary for measuring the performance of our dealers)
To profile your motivations, values and needs so that we can make the content of our marketing and communications more relevant to you, see “Profiling” paragraph below	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Vehicle	Necessary for our legitimate interests (necessary for promoting our business, brand, products and services)
To enable you to take part in promotional events and advertising, and to allow us to create and share marketing content	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Vehicle	You have given your consent to the processing
To include your comments, opinions, content and photos in our marketing activities	(a) Identity (b) Vehicle	You have given your consent to the processing
IT and Administration
To administer and protect our business and the Sites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (necessary to administer our business, ensure network security and prevent fraud (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical (g) Vehicle	Necessary for our legitimate interests (necessary to analyse how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics and profiling to improve the Sites, products/services, marketing, customer relationships and experiences	(a) Identity (b) Contact (c) Technical (d) Profile (e) Usage (f) Marketing and Communications (g) Vehicle	Necessary for our legitimate interests (to define types of customers for our products and services, to keep the Sites updated and relevant, to develop our business and to inform our marketing strategy)
Aftersales and Customer Care
If you take insurance cover, to monitor the performance and take-up of such insurance	Vehicle	Necessary for our legitimate interests (necessary for management reporting)
To register your warranty, provide you with warranty and after-sales services, or to determine whether a repair can be undertaken under warranty	(a) Identity (b) Contact (c) Vehicle	Performance of a contract with you
To offer and allow for the provision of accident, breakdown and recovery services by our third party providers	(a) Identity (b) Contact (c) Vehicle	Performance of a contract with you
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or Policy (b) Asking you to leave a review or take a survey (c) Checking and updating the information we hold about you (d) Analysing how you use our products and services (e) Complying with requests from you to exercise your data subject rights	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Vehicle	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (necessary to administer our business)
To manage and investigate reports of product defects	(a) Identity (b) Contact (c) Vehicle (d) Health Data	Necessary for our legitimate interests (necessary for ensuring the safety and performance of our products) Necessary to comply with a legal obligation
To contact you in the event of any urgent safety or product recall notices	(a) Identity (b) Contact (c) Vehicle	Necessary in order to protect your vital interests or the vital interests of another person
To manage and respond to your requests, queries and complaints about our products, services or dealers	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Vehicle	Necessary for our legitimate interests (necessary for managing your requests, queries, complaints and claims, and for sending communications to you in relation to such requests, queries, complaints and claims)
To register your vehicle with the DVLA	(a) Identity (b) Contact (c) Vehicle	Necessary to comply with a legal obligation
If you make a request, to generate a Certificate of Conformity	(a) Identity (b) Financial (c) Transaction (d) Contact (e) Profile (f) Vehicle	Performance of a contract with you
Corporate
To enforce or protect our contractual or other legal rights or to bring or defend legal proceedings	(a) Identity (b) Financial (c) Transaction (d) Contact (e) Profile (f) Usage (g) Marketing and Communications (h) Technical (i) Vehicle	Necessary for our legitimate interests (necessary to enforce and protect our legal rights)
For the purposes of corporate restructures, reorganisations, or sale of our business or assets	(a) Identity (b) Financial (c) Transaction (d) Contact (e) Profile (f) Usage (g) Marketing and Communications (h) Technical (i) Vehicle	Necessary for our legitimate interests (necessary to enable the restructure, reorganisation, sale, or integration of our business)
For the purposes of providing a report on fuel economy data to the UK Government and European Commission. This may involve us sharing the data with SMC for submission to the European Commission and UK Government.	(a) Vehicle	Necessary to comply with a legal obligation.

Profiling

We may from time to time profile your personal data to help us understand your motivations, values and needs. It only takes place to help us make the content of our marketing and communications more relevant to you.  We use your Identity, Contact, Financial, Profile and Vehicle Data to carry out this profiling.  You can always object to our profiling by emailing us at privacy@suzuki.co.uk or by writing to us at Attn. Data Protection Officer, Suzuki GB PLC, Steinbeck Crescent, Snelshall West, Milton Keynes, Buckinghamshire, MK4 4AE. Any profiling data that we hold about you will be refreshed every 3 months.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage, Profile, Marketing and Communications, and Vehicle 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 products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased products or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the Suzuki GB PLC group of companies for marketing purposes.

Opting out

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you, by contacting us at any time at customerservices@suzuki.co.uk, or by completing the form at https://cars.suzuki.co.uk/contact-us/update-my-preferences/.  You can ask third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies

Like many websites, we use “cookies” to enable us to personalise your visits to our Sites, keep track of your preferences and to track the usage of our Sites.

You can manage your cookies from within our cookie preference centre. If you disable or refuse cookies, please note that some parts of the Sites may become inaccessible or not function properly. For more information about the cookies we use, please see https://cars.suzuki.co.uk/privacy/cookie-policy/.

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.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Policy.

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 and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

The personal data we collect from you may be transferred outside the European Economic Area (“EEA”).

It may also be processed by staff operating outside the EEA who work for us or for one of the suppliers or contractors. Territories outside of the EEA may not have equivalent legal protections to those that apply within the EEA but we are under a duty to make sure that our suppliers and contractors located outside of the EEA continue to take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Policy. By submitting your personal data to us, you agree to this transfer, storing or processing.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. DATA SECURITY

All information that you provide to us is stored on our secure servers and any payment transaction are protected using SSL technology.

The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to us or our Sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

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.

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

8. DATA RETENTION

How long will you use my personal data for?

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.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances you can ask us to delete your data, see below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

• The right to ask us not to process your personal data at any time.
• The right to use our products, services and Sites without consenting to marketing and communication services that we provide. We will inform you (before collecting your data) if we intend to use your personal data for such purposes or if we intend to disclose your information to any third party for such purposes.
• The right to request access to or rectification of your personal data which we hold about you.
• The right to erase your personal data to restrict the processing of your personal data.
• The right to receive your personal data that you have provided to us.
• The right to object to our processing of your personal data.
• The right to request that we transmit your personal data to another data controller.

Where we process your personal data because you have given us your consent to do so, you have the right to withdraw your consent at any time.

To exercise any of the rights, please contact the Data Protection Officer whose contact details are provided earlier in this Policy.  

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), or to the national supervisory authority responsible for data protection issues in your EU member state. The national supervisory authority for data protection issues in Ireland is the Data Protection Commissioner (www.dataprotection.ie). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

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 may exercise our right not 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 may 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.

10. GLOSSARY

LAWFUL BASIS

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 personal 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 or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Vital Interests means processing your personal data is necessary in order to protect the vital interests of the data subject or of another natural person.

Consent means that you have agreed to the processing of your personal data by providing us with a freely given, specific, informed and unambiguous indication of your wishes by a statement or by a clear affirmative action.

THIRD PARTIES

Internal Third Parties

Other companies in the Suzuki GB PLC group, including SMC, which are based outside of the European Union. Where your personal data is transferred outside of the European Economic Area, we will ensure that we have put in place adequacy measures which comply with the GDPR to enable the lawful transfer of your personal data.

External Third Parties

• Dealers and partners in our network acting as controllers or joint controllers based in the United Kingdom and Ireland who provide pre-sales, sales and after-sales services in relation to our products and services.
• Service providers acting as processors based in the United Kingdom and Germany who provide IT, e-commerce and system administration services.
• Service providers acting as processors based in the United Kingdom who provide marketing and research services.
• Service providers acting as processors based in the United Kingdom who provide, warranty registration, motor insurance, courtesy car, and accident, breakdown and recovery services.
• Service providers acting as processors based in the United Kingdom who provide delivery and fulfilment services.
• Service providers acting as processors based in the United Kingdom who provide assistance with product recalls.
• Professional advisers acting as processors, controllers or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, privacy consultants, insurance and accounting services.
• DVLA, HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

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: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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.

SUZUKI GB PLC

PRIVACY POLICY

INTRODUCTION

Welcome to Suzuki GB PLC's consumer privacy policy (referred to as the “Policy”).

We respect your privacy and are committed to protecting your personal data. This Policy describes how we look after your personal data, including when you visit our websites (regardless of where you visit them from), and tells you about your privacy rights and how the law protects you. Please read this Policy carefully.

This Policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this Policy.

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY
11. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of the Policy

This Policy aims to give you information on how we collect and process your personal data. 

This Policy applies to all processing of your personal data across all the products and services we provide at Suzuki and all the websites, portals, applications and social media platforms we use to support and deliver those products and services.

It is important that you read this Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data. This Policy supplements other notices and privacy policies and is not intended to override them.

We operate a network of dealers and work with other partners. Our dealers and partners are independently owned and operated businesses. We may share your personal data with our dealer network. When this happens we will do so in accordance with this policy. If you have concerns about how your personal data is processed by one of our dealers or partners, please contact them directly in the first instance.

Where we process your personal data through any third party platform such as Facebook, Instagram and/or any other social network, the privacy policies of those platforms will in addition to this privacy policy, apply to the processing of your personal data. Please note that any processing of your personal data within those platforms other than by us, is outside of our control. If you have concerns about how your personal data is processed within those platforms, please contact them directly in the first instance.

Who we are

Suzuki GB PLC (company number 00768587) of Steinbeck Crescent, Snelshall West, Milton Keynes, Buckinghamshire, MK4 4AE (referred to as “Suzuki”, “we”, “us” or “our”) is the controller and responsible for the websites, applications and social media accounts listed here  (referred to as our “Sites”).

Suzuki GB PLC is a subsidiary of Suzuki Motor Corporation, Japan (“SMC”). SMC is a separate legal entity.  It may collect personal data directly from you, or through Suzuki GB PLC or any other third party, and has its own processes and procedures for handling your personal data.  SMC’s privacy policy is available here www.globalsuzuki.com/cookies/index.html

Contacting us

If you would like to stop receiving marketing and communications from us and our nominated third parties, please contact us via email at customerservices@suzuki.co.uk, follow this link https://cars.suzuki.co.uk/contact-us/update-my-preferences/, write to the Customer Services Department at Suzuki GB PLC, Steinbeck Crescent, Snelshall West, Milton Keynes, Buckinghamshire, MK4 4AE, or call us on 08085 011959 or  01 619 3671.

If you have any questions about this Policy, including any requests to exercise your legal rights as a data subject, please contact our Data Protection Officer via email at privacy@suzuki.co.uk, write to us at Attn. Data Protection Officer, Suzuki GB PLC, Steinbeck Crescent, Snelshall West, Milton Keynes, Buckinghamshire, MK4 4AE, or call us on 08085 011959.

Changes to the Policy and your duty to inform us of changes

This version was last updated on 28^th November 2022.

Any changes we may make to this Policy in the future will be posted on this page and, where appropriate notified to you by email. Please check back frequently to see any updates or changes to this Policy.

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.

Third-party links

The Sites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave the Sites, we encourage you to read the privacy policy of every website you visit.

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. It does not include data where the identity has been removed (anonymous data).

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, age, marital status, title, date of birth, gender and household details (such as other members of your household).
• Contact Data includes house number or name, street name, town/city, county, postcode, phone number, mobile number, email address, social media account details and social media handles.
• Financial Data includes bank account, payment card details and income.
• Transaction Data includes details about how you heard about us, whether you are a Motability customer, the preferred date and time of your test drive, details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, GPS location 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 the Sites.
• Profile Data includes your username (or similar identifier) and password, purchases or orders made by you, your life stage, number of children, interests, preferences, feedback and survey responses (including your opinions of our products and services), records and recordings of telephone calls made by us, records of telephone calls made by our dealers, records and transcripts of help desk conversations conducted over ebay, and photographs, images or video of you.
• Usage Data includes information about how you use the Sites, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third party partners and your communication preferences.
• Vehicle Data includes details of your historic and current brand and model of vehicle, model description, vehicle colour, vehicle capacity, Vehicle Identification Number, vehicle registration number, key number, engine number, engine type, selected optional equipment, ownership option (purchase, rental or leasing), number of cars in your household, annual mileage, motor fuel spend, vehicle purchase spend, motor insurance spend, motoring maintenance costs, and total motoring expenditure.
• Criminal Records Data includes details of driving offences and the number of points on your driving licence.
• Health Data: May include injury details as part of an accident form.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.

We do not routinely 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). It is possible that some Special Categories of Personal Data could be collected, used, stored and transferred as part of managing and responding to your requests, queries and complaints about our products, services or dealers.  This will only occur where you volunteer this information in an email, during a telephone call or live chat, or in an open text box form on the Sites.

We will only process Criminal Records Data where we meet a specific condition in Schedule 1 of the Data Protection Act 2018 and comply with the additional safeguards set out in that Act.

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 (for example, to provide you with products or services). In this case, we may have to cancel a product or 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, Financial, Transaction, Profile and Vehicle Data by filling in forms or by corresponding with us by post, phone, email, live chat function, direct messages or comments within social media, or otherwise. This includes personal data you provide when you:
  • apply for, order, or purchase our products or services;
  • create an account on one of our Sites;
  • subscribe to our services, publications or mailing lists;
  • search for your local dealer using our Sites;
  • book a test drive;
  • book a service;
  • make an enquiry in person or online;
  • request a brochure or other marketing materials to be sent to you;
  • enter a competition, promotion or survey, or take part in a promotional event;
  • ask us a question;
  • call, email or chat to us;
  • give us some feedback; or
  • communicate with us via social media.
• Automated technologies or interactions. As you interact with our Sites, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details and to manage your cookie preferences.
• Third parties or publicly available sources. We may receive personal data about you from various third parties, including our dealer network, our partners, and public sources as set out below:
  • Technical Data from the following parties:
    • analytics providers such as Google based outside the EU. Details of how Google collects and processes data can be found here www.google.com/policies/privacy/partners/;
    • advertising networks based inside and outside the EU; and
    • search information providers based inside and outside the EU.
  • Contact, Financial and Transaction Data from providers of technical, payment, and delivery and fulfilment services inside and outside the EU.
  • Identity, Contact, Financial, Profile, Vehicle and Marketing and Communications Data from data brokers or aggregators based inside and outside the EU.
  • Identity and Contact Data from publicly availably sources based inside and outside the EU such as Companies House, the Driver and Vehicle Licensing Agency, the Electoral Register, Registration Office Ireland and the Register of Electors.
  • Identity, Contact, Financial, Transaction Data, Profile and Vehicle Data from our dealer network based inside and outside the EU.
  • Identity, Contact, Profile and Vehicle Data from our motor insurance, courtesy car, and accident, breakdown and recovery service providers based inside and outside the EU.
  • Identity, Contact, Financial, Transaction, Profile, Marketing and Communications, and Vehicle Data from our e-commerce providers based inside and outside the EU.
  • Identity, Contact, Financial, Transaction, Profile, Marketing and Communications, and Vehicle Data from our marketing and research providers based inside and outside the EU.

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 (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

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
Sales
To register you as a new customer	(a) Identity (b) Contact	Performance of a contract with you
To find your local dealer using our Sites, including when you contact us via our live chat function	Contact	Necessary for our legitimate interests (necessary to fulfil requests you make to us relating to our dealer network)
To arrange a test drive/ride, which will include sharing your personal data with our dealers	(a) Identity (b) Contact	Necessary for our legitimate interests (necessary to fulfil requests you make to us relating to our products and services)
To send you a brochure and to allow you to sign-up to mailing lists for our products and services	(a) Identity (b) Contact	Necessary for our legitimate interests (necessary to fulfil requests you make to us relating to our products and services)
To configure your vehicle or product	(a) Identity (b) Contact	(a) Performance of a contract with you (b) Necessary for our legitimate interests (necessary to respond to your needs for a particular product)
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications (f) Vehicle	(a) Performance of a contract with you (b) Necessary for our legitimate interests (necessary to provide you with a product that meets your order and necessary to recover debts due to us)
To validate ownership of a vehicle when brought to a dealer, and maintain ownership records	(a) Identity (b) Contact (c) Vehicle	Performance of a contract with you
Marketing
To enable you to take part in a prize draw, competition or complete a survey and, if you win, to deliver prizes to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	Necessary for our legitimate interests (necessary for promoting our business, brand, products and services)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	(a) Necessary for our legitimate interests (to develop our products/services and grow our business) (b) You have provided your consent to us to process your personal data for the purpose of direct marketing
To notify you about the opening and closing of Suzuki dealers in your area	(a) Identity (b) Contact (c) Vehicle	Necessary for our legitimate interests (to keeping to informed about where you can access sales and after-sales services)
To evaluate the success of dealer promotional events	(a) Identity (b) Contact (c) Profile (d) Vehicle	Necessary for our legitimate interests (necessary for promoting our business, brand, products and services and necessary for measuring the marketing performance of our dealers)
To process requests for sponsorship, complimentary or promotional products and merchandise, or to provide you with such items	(a) Identity (b) Contact (c) Vehicle	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to offer and provide you with ancillary products and services from us and our partners)
To measure your experience when receiving services from our dealers	(a) Identity (b) Financial (c) Transaction (d) Contact (e) Profile (f) Vehicle	Necessary for our legitimate interests (necessary for promoting our business, brand, products and services and necessary for measuring the performance of our dealers)
To profile your motivations, values and needs so that we can make the content of our marketing and communications more relevant to you, see “Profiling” paragraph below	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Vehicle	Necessary for our legitimate interests (necessary for promoting our business, brand, products and services)
To enable you to take part in promotional events and advertising, and to allow us to create and share marketing content	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Vehicle	You have given your consent to the processing
To include your comments, opinions, content and photos in our marketing activities	(a) Identity (b) Vehicle	You have given your consent to the processing
IT and Administration
To administer and protect our business and the Sites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (necessary to administer our business, ensure network security and prevent fraud (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical (g) Vehicle	Necessary for our legitimate interests (necessary to analyse how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics and profiling to improve the Sites, products/services, marketing, customer relationships and experiences	(a) Identity (b) Contact (c) Technical (d) Profile (e) Usage (f) Marketing and Communications (g) Vehicle	Necessary for our legitimate interests (to define types of customers for our products and services, to keep the Sites updated and relevant, to develop our business and to inform our marketing strategy)
Aftersales and Customer Care
If you take insurance cover, to monitor the performance and take-up of such insurance	Vehicle	Necessary for our legitimate interests (necessary for management reporting)
To register your warranty, provide you with warranty and after-sales services, or to determine whether a repair can be undertaken under warranty	(a) Identity (b) Contact (c) Vehicle	Performance of a contract with you
To offer and allow for the provision of accident, breakdown and recovery services by our third party providers	(a) Identity (b) Contact (c) Vehicle	Performance of a contract with you
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or Policy (b) Asking you to leave a review or take a survey (c) Checking and updating the information we hold about you (d) Analysing how you use our products and services (e) Complying with requests from you to exercise your data subject rights	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Vehicle	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (necessary to administer our business)
To manage and investigate reports of product defects	(a) Identity (b) Contact (c) Vehicle (d) Health Data	Necessary for our legitimate interests (necessary for ensuring the safety and performance of our products) Necessary to comply with a legal obligation
To contact you in the event of any urgent safety or product recall notices	(a) Identity (b) Contact (c) Vehicle	Necessary in order to protect your vital interests or the vital interests of another person
To manage and respond to your requests, queries and complaints about our products, services or dealers	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Vehicle	Necessary for our legitimate interests (necessary for managing your requests, queries, complaints and claims, and for sending communications to you in relation to such requests, queries, complaints and claims)
To register your vehicle with the DVLA	(a) Identity (b) Contact (c) Vehicle	Necessary to comply with a legal obligation
If you make a request, to generate a Certificate of Conformity	(a) Identity (b) Financial (c) Transaction (d) Contact (e) Profile (f) Vehicle	Performance of a contract with you
Corporate
To enforce or protect our contractual or other legal rights or to bring or defend legal proceedings	(a) Identity (b) Financial (c) Transaction (d) Contact (e) Profile (f) Usage (g) Marketing and Communications (h) Technical (i) Vehicle	Necessary for our legitimate interests (necessary to enforce and protect our legal rights)
For the purposes of corporate restructures, reorganisations, or sale of our business or assets	(a) Identity (b) Financial (c) Transaction (d) Contact (e) Profile (f) Usage (g) Marketing and Communications (h) Technical (i) Vehicle	Necessary for our legitimate interests (necessary to enable the restructure, reorganisation, sale, or integration of our business)
For the purposes of providing a report on fuel economy data to the UK Government and European Commission. This may involve us sharing the data with SMC for submission to the European Commission and UK Government.	(a) Vehicle	Necessary to comply with a legal obligation.

Profiling

We may from time to time profile your personal data to help us understand your motivations, values and needs. It only takes place to help us make the content of our marketing and communications more relevant to you.  We use your Identity, Contact, Financial, Profile and Vehicle Data to carry out this profiling.  You can always object to our profiling by emailing us at privacy@suzuki.co.uk or by writing to us at Attn. Data Protection Officer, Suzuki GB PLC, Steinbeck Crescent, Snelshall West, Milton Keynes, Buckinghamshire, MK4 4AE. Any profiling data that we hold about you will be refreshed every 3 months.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage, Profile, Marketing and Communications, and Vehicle 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 products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased products or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the Suzuki GB PLC group of companies for marketing purposes.

Opting out

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you, by contacting us at any time at customerservices@suzuki.co.uk, or by completing the form at https://cars.suzuki.co.uk/contact-us/update-my-preferences/.  You can ask third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies

Like many websites, we use “cookies” to enable us to personalise your visits to our Sites, keep track of your preferences and to track the usage of our Sites.

You can manage your cookies from within our cookie preference centre. If you disable or refuse cookies, please note that some parts of the Sites may become inaccessible or not function properly. For more information about the cookies we use, please see https://cars.suzuki.co.uk/privacy/cookie-policy/.

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.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Policy.

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 and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

The personal data we collect from you may be transferred outside the European Economic Area (“EEA”).

It may also be processed by staff operating outside the EEA who work for us or for one of the suppliers or contractors. Territories outside of the EEA may not have equivalent legal protections to those that apply within the EEA but we are under a duty to make sure that our suppliers and contractors located outside of the EEA continue to take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Policy. By submitting your personal data to us, you agree to this transfer, storing or processing.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. DATA SECURITY

All information that you provide to us is stored on our secure servers and any payment transaction are protected using SSL technology.

The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to us or our Sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

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.

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

8. DATA RETENTION

How long will you use my personal data for?

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.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances you can ask us to delete your data, see below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

• The right to ask us not to process your personal data at any time.
• The right to use our products, services and Sites without consenting to marketing and communication services that we provide. We will inform you (before collecting your data) if we intend to use your personal data for such purposes or if we intend to disclose your information to any third party for such purposes.
• The right to request access to or rectification of your personal data which we hold about you.
• The right to erase your personal data to restrict the processing of your personal data.
• The right to receive your personal data that you have provided to us.
• The right to object to our processing of your personal data.
• The right to request that we transmit your personal data to another data controller.

Where we process your personal data because you have given us your consent to do so, you have the right to withdraw your consent at any time.

To exercise any of the rights, please contact the Data Protection Officer whose contact details are provided earlier in this Policy.  

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), or to the national supervisory authority responsible for data protection issues in your EU member state. The national supervisory authority for data protection issues in Ireland is the Data Protection Commissioner (www.dataprotection.ie). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

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 may exercise our right not 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 may 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.

10. GLOSSARY

LAWFUL BASIS

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 personal 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 or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Vital Interests means processing your personal data is necessary in order to protect the vital interests of the data subject or of another natural person.

Consent means that you have agreed to the processing of your personal data by providing us with a freely given, specific, informed and unambiguous indication of your wishes by a statement or by a clear affirmative action.

THIRD PARTIES

Internal Third Parties

Other companies in the Suzuki GB PLC group, including SMC, which are based outside of the European Union. Where your personal data is transferred outside of the European Economic Area, we will ensure that we have put in place adequacy measures which comply with the GDPR to enable the lawful transfer of your personal data.

External Third Parties

• Dealers and partners in our network acting as controllers or joint controllers based in the United Kingdom and Ireland who provide pre-sales, sales and after-sales services in relation to our products and services.
• Service providers acting as processors based in the United Kingdom and Germany who provide IT, e-commerce and system administration services.
• Service providers acting as processors based in the United Kingdom who provide marketing and research services.
• Service providers acting as processors based in the United Kingdom who provide, warranty registration, motor insurance, courtesy car, and accident, breakdown and recovery services.
• Service providers acting as processors based in the United Kingdom who provide delivery and fulfilment services.
• Service providers acting as processors based in the United Kingdom who provide assistance with product recalls.
• Professional advisers acting as processors, controllers or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, privacy consultants, insurance and accounting services.
• DVLA, HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

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: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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.