Park Lane Ltd as a Data Controller and our responsibilities:
- Park Lane Ltd is the Data Controller of your personal information that we receive through our websites, telephone, electronic services such as email and in our sales and aftersales centres.
How do we collect your personal information:
These are the main ways we collect your information:
- If you contact us directly via our websites, visit the retail centre or via our customer hotlines to request information about our products and services.
- If you buy a product or service directly from us.
- If you reply to our direct marketing campaigns.
- If your contact details are transferred from BMW Group UK or other third parties.
- If your vehicle data (incl. vehicle identification number) is transferred to BMW AG while you’re having your vehicle serviced or repaired.
- If other BMW Group legal entities or business partners transfer your personal data to us.
- If we acquired your personal data from other sources, for example: social media sites.
- When you apply for finance from BMW Financial Services or MINI Financial Services.
If you are under 16 please do not provide us with any of your information unless you have the permission of your parent or guardian to do so.
Please help us to keep your information up to date by informing us of any changes to your contact details or preferences. You may change or review your preferences by emailing firstname.lastname@example.org or by visiting the relevant section of our websites.
What information may be collected about you:
The following types of personal information about you may be collected:
- Phone numbers
- Email address
- Information you provide us about your interests
- Including the type of vehicles you are interested in
Website and Communication Usage
- How you use our website and whether you open or forward our communications, including information collected through cookies and other tracking technologies
Sales and Services Information
- Relating to purchases and services, including complaints and claims.
Credit and Anti-Fraud Information
- Which establishes your identity, such as driving licences, passports and utility bills
- Information about transactions, requests for credit and non-payment of debts with us and third parties
- Fraud, offences, suspicious transactions, politically exposed person and sanctions lists where your details are included
Device and Service Usage
- How you use your device (mobile or vehicle) and services offered on the device
Vehicle Configuration Details
- Information about the features and current settings of your vehicle (identified by the Vehicle Identification Number)
Vehicle Technical Information
- About how the engine and systems within the vehicle perform
Vehicle / Device Location Information
- Your vehicle’s or mobile device’s location
How your personal information may be used:
Use of personal information under UK data protection laws must be justified under one of a number of legal grounds and we are required to set out the grounds in respect of each use in this policy.
The main uses of your information are:
- Customer Support and Marketing - to respond to enquiries and to bring you news and offers.
- In order to ensure that you receive relevant and personalised communications, we will use your data to create an individual customer profile and we may share your personal data between BMW Group companies. This may include data you have provided to these companies, or which is generated by your use of BMW or MINI products, for example contact details, preferences, customer history, vehicle data, app usage and online behaviour.
- Park Lane Ltd use your personal data for customer care and for personalised communication of BMW Group product and service information, where necessary with your consent.
- Vehicle Sales & Service – to process your sale, configure and service your vehicle.
- If you have a finance agreement with BMW Financial Services they may pass on your agreement details (term, monthly payment, rate, mileage, final payment, and agreement number and vehicle details) to us to discuss your end of contract options, and if you agree, to discuss any future financing with BMW Financial Services. They may also provide BMW (UK) Limited with your contact details and the start and end dates of your agreement so they can send you news on products and services which may interest you.
- Park Lane Ltd will obtain Contact Details, Vehicle Configuration Details, Vehicle Technical Information and Sales and Services Information when you purchase, service or repair a vehicle with us as part of the sale or service and will use it to provide the services you request and notify you of issues in relation to your vehicle. This information may be accessed by BMW Group UK and BMW AG to troubleshoot technical or other issues relating to the delivery of these services.
Compliance with legal requests for your information – to comply with our legal obligations to law enforcement, regulators and the court service:
- We may be legally required to provide your information to law enforcement agencies, regulators and courts and third party litigants in connection with proceedings or investigations anywhere in the world. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime.
Legal grounds for processing of your personal information:
The use of your information set out above is permitted under UK data protection law on the basis of these principal legal grounds:
- Where you have consented to the use (you will have been presented with a consent form in relation to any such use and may withdraw your consent at any time through the Park Lane websites or:
- by calling 020 7409 3355
- or sending an email to: email@example.com
- or by writing to us at: Marketing Department, MINI Park Lane, 77 Park Lane, London. W1K 7TP
- Where necessary to enter into or perform our contract with you.
- Where we need to use it to comply with our legal obligations.
- Where we use it to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights (our legitimate interests include promoting the BMW Group business and tailoring news and offers to your profile, research and development of vehicle related products and services, detecting fraud and criminal activities)
- Where necessary for us to defend, prosecute or make a claim against you, us or a third party.
- There may be uses that are permitted on the basis of other grounds; where this is the case we will use reasonable endeavours to identify the ground and communicate it you as soon as possible after becoming aware of the new basis.
Transfer to 3rd Parties:
Personal information which we collected may be transferred to 3rd parties on your behalf, only with your consent. This is only shared in a secure manner, using a consistent security protocol. When we share with other parties we ensure that they only use your personal data for the purpose it was collected and do not allow them to abuse this agreement.
The types of third parties apart from the BMW Group companies already stated are:
- Marketing agencies who run and manage marketing campaigns on our behalf.
- Event companies who run and manage sponsored events on our behalf.
How do we keep your personal information safe:
We use a variety of security measures, including encryption and authentication tools, to help protect and maintain security, integrity and availability of your information.
Although data transmission over the Internet or website cannot be guaranteed to be secure, we and our business partners work hard to maintain physical, electronic and procedural safeguards to protect your information in accordance with applicable data protection requirements.
Our main security measures are:
- tightly restricted personal access to your data on a "need to know“ basis and for the communicated purpose only
- transferred collected data only in encrypted form
- highly confidential data stored only in encrypted form - e.g. credit card information
- firewalled IT systems to prohibit unauthorised access - e.g. from hackers
- permanently monitored access to IT systems to detect and stop misuse of personal data
If you have a personal password which enables you to access certain parts of BMW Group websites or any other portal, app or service BMW Group operate, do not forget it is your responsibility for keeping this password confidential. It is recommended that you do not share your password with anyone.
How long we keep your personal information for:
- We retain your information only as long as is necessary for the purpose for which we obtained them and any other permitted linked purposes. If information is used for two purposes we will retain it until the purpose with the latest period expires; but we will stop using it for the purpose with a shorter period once that period expires.
- We restrict access to your information to only those persons who need to use it for the relevant purpose.
- Our retention periods are based on business needs and your information that is no longer needed is either irreversibly anonymised or destroyed securely.
- Use for marketing - We retain your personal information for as long as is necessary, but only for the relevant purpose that we collected it for. You retain the right to remove this consent at any point.
- Use to perform a contract - In relation to your information used to perform any contractual obligation with you we may retain that data whilst the contract remains in force plus one year to deal with any queries or claims thereafter.
- When we do not have a contract with you, but you have asked us to do something (e.g. arrange a test drive or provide a quotation) and we need to process your personal data to do what you have asked.
- Where claims are contemplated - In relation to any information where we reasonably believe it will be necessary to defend or prosecute or make a claim against you, us or a third party, we may retain that data for as long as that claim could be pursued.
Who may we share your information with:
- BMW is a global company. Your personal information may be accessed by our staff, agents or contractors from a country outside the European Economic Area (EEA) for any of the purposes set out, in which data protection laws may be of a lower standard than in the EEA. We will ensure that any of your information that is accessible outside the EEA is handled subject to appropriate safeguards.
- Certain countries outside the EEA, such as Canada and Switzerland, have been approved by the European Commission as providing essentially equivalent protection to EEA data protection laws and therefore no additional legal safeguards are required. In countries which have not had such approval, we will either ask for your consent to the transfer or transfer it subject to European Commission approved contractual terms that impose equivalent data protection obligations directly on the recipient unless we are permitted under applicable data protection law to make such transfers without such formalities.
Please contact our data privacy officer if you would like to request to see a copy of the specific safeguards applied to the export of your information.
How to change your privacy preferences:
You can change your preferences, or withdraw your consent in relation to how Park Lane Ltd use your personal information in one of the following ways:
- You can make individual preference changes on our websites using our web forms.
- You are also able to request information about your data stored at Park Lane Ltd as well as request the correction, deletion or restriction of your personal data for analytics and/or marketing use.
- By contacting the Park lane customer hotline on: 020 7409 3355
- Or by sending an email to firstname.lastname@example.org
- Or by writing to us at: Marketing Department - MINI Park Lane, 77 Park Lane, London. W1K 7TP
If you have any questions in relation to our use of your information you should first contact Park Lane in one of the following ways:
- Customer hotline on: on 020 7409 3355
- Or by sending an email to email@example.com
- Or by writing to us at: Marketing Department, MINI Park Lane, 77 Park Lane, London. W1K 7TP
- In addition you may contact our data privacy officer
Under certain conditions you have the right to require us to:
- Provide you with further detail on the use we make of your information.
- Provide you with a copy of your information.
- Update any inaccuracies in the information we hold about you.
- Delete any information about you that we no longer have a lawful ground to use.
- Remove you from any direct marketing lists when you object or withdraw your consent.
- Provide you with your personal information in a usable electronic format and transmit it to a third party (right to data portability)
- Restrict our use of your personal information.
- Cease carrying out certain processing activities based on the legitimate interests grounds unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights.
Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime), our interests (e.g. the maintenance of legal privilege) and the rights of third parties.
If you are dissatisfied with our use of your information or our response to any exercise of these rights you have the right to complain to your data protection authority, this in the UK is the Information Commissioner's Office: www.ico.org.uk
Data Privacy Officer Contact Details:
If you have questions in relation to our use of your personal information you should contact our Data Privacy Officer:
Park Lane Ltd
Tel: 020 7409 3355