PARK LANE LTD PRIVACY POLICY
ICO Registration Number: Z5813613
We understand that you trust us with your personal data.
Park Lane Ltd will only use your personal data for clearly described purposes, and in line with your data protection rights.
This privacy policy explains how Park Lane Ltd, as an authorised MINI Retailer will collect and use your personal data.
Alternative authorised MINI Retailers do exist and they are independent businesses who also provide sales, service, approved parts, and repair to MINI customers. These alternative MINI Retailers may also process your data for their own purposes; and collect extra personal data about you. Their activity is not covered by this privacy policy.
WHAT COMPANIES ARE DATA CONTROLLERS IN THIS POLICY?
A data controller is a company that decides what happens to your personal data when you provide it. Personal data is information that could be used to identify you.
Data controllers must follow the law and give you certain information about how your data will be collected and used. This is described in this policy.
Park Lane Ltd as a data controller and our responsibilities.
Park Lane Ltd (hereinafter also referred to as, “us” or "we”) serves as the data controller of your personal data that we receive through our websites, telephone calls, electronic services such as email, and in our sales and aftersales centres.
Park Lane Ltd has its registered place of business at MINI Park Lane, 70 Park Lane, London, W1K 7TT.
As Park Lane Ltd, we are a legally and economically independent company and not part of BMW (UK) Limited, Summit One, Summit Avenue, Farnborough, Hampshire, GU14 0FB (hereinafter referred to as “MINI UK”).
As an authorised MINI Retailer, we utilise the brands MINI and BMW for selling, leasing and distributing automobiles and motorcycles, original parts and accessories of these brands and for brand-related maintenance and repair.
We are responsible for the processing of any personal data that you provide to us in connection with your concerns and customer support related to the areas of sales and service. We also process your data when MINI UK transmits it to us, such as in connection with purchase contracts with MINI UK that are managed through us.
You can obtain information regarding data processing by MINI UK, in the MINI UK data privacy policy here.
As explained in more detail below, we and MINI UK are also joint controllers within the meaning of the UK GDPR with respect to certain specific data processing operations.
CHANGES TO THIS PRIVACY POLICY.
We may modify or update this privacy policy occasionally.
If we change this privacy policy, we will notify you of the changes by publishing an updated policy on this website. Where changes to this privacy policy will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you a forewarning so that you may exercise any rights (e.g. to object to the processing).
WHEN DO WE COLLECT YOUR PERSONAL DATA?
These are the main ways we collect your personal data:
If you contact us directly via our websites or visit the retail centre or through our customer telephone lines to request information about our products and services,
If you buy or lease products directly from us or when we facilitate purchases (e.g. vehicles or parts or accessories),
If you buy services directly from us (e.g. maintenance or repair of a vehicle),
If you request information about our products and services (e.g. electronic transmission of brochures or price lists),
If you give us your consent to receive promotional (marketing) communications or respond to our direct marketing campaigns, such as when you fill out a response form or when you submit your data online on one of our websites (e.g. www.miniparklane.co.uk),
If MINI UK provides us with personal data about you, e.g. if you identify yourself to us via a QR code in your MINI App and we receive relevant data from MINI UK,
If authorised third parties give us your personal data,
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 MINI Financial Services.
If you give personal data on behalf of someone else, you must have their permission and provide them with this privacy policy before giving their personal data.
If you are under 16, please do not provide us with any of your information.
Please help us keep your personal data up to date by informing us of any changes to your contact details or preferences. You may change or review your preferences by emailing updateinfo@bmwparklane.co.uk.
If you already have a MINI ID Online Account, you can also make these changes there. You can amend your data (e.g. contact details, consent to MINI UK promotional communications, selection of your preferred MINI Retailer and your mapped vehicles) at any time.
Your MINI ID Online Account (e.g. displayed via the MINI App) also has a unique QR code that you can use to identify yourself at our business premises. By scanning that QR code, we can receive relevant information from your profile. After the first time you identify yourself at one of our premises, you will receive an email notification.
Important note: If you have more than one MINI ID Online Account, changes to one account may not automatically update your other accounts. Please make sure you update all your online accounts with important changes, like your contact details, or marketing preferences.
WHAT PERSONAL DATA MAY BE COLLECTED ABOUT YOU?
The following types of personal data about you may be collected:
Contact details: Name, address, phone number and email address,
Contract data: Customer number, contract number, purchase contract, booked Connected Services, relevant payment information, Vehicle Identification Number,
Interests: Information you provide about your interests, including the types of vehicles you like, hobbies and other personal preferences,
Other personal data: Information that you provide such as date of birth and size of household,
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. For more information, please see our Cookie Policy here,
Consent to promotional (marketing) communications: Information about any consent that you have given to receive any promotional or marketing communications,
Transaction and interaction data: Information about any purchases of products and services; including interactions with us such as complaints and claims,
Call recording: We record inbound calls to our switchboards,
Closed circuit television: Where we use CCTV to monitor our premises,
Credit and anti-fraud information such as driving licences, passports, and utility bills, information about payment transactions, requests for credit, non-payment of debts with us and third parties, credit ratings from credit reference agencies, data about fraud, criminal offences, suspicious transactions, politically exposed persons, sanctions lists where your details are included, employment history, address history and bank details,
Information about vehicle functions and settings: Information about the functions and current settings of your vehicle (identified using the vehicle identification number); e.g. MINI TeleServices, MINI Connected Services or MINI CarData and the MINI App,
Vehicle geolocation data: Information about the location of your vehicle or mobile device. We may receive limited data to locate the vehicle where this is necessary for the purpose of fulfilling a contract (e.g. as part of MINI Roadside Assistance). We will only use this data in the ways described in the terms and privacy policies for those services. Location data is carefully protected, as described later in this policy in the section titled “Security measures for location data”,
Data that is generated or processed in the vehicle about how it is configured, being used, performing or malfunctioning. You can configure your vehicle to decide what data is transmitted by it.
If you buy or lease products directly from us or when we facilitate purchases, and you choose for someone else to collect it for you, we may ask you to provide their full name, date of birth and contact details so we can check their details against sanction lists; so, you must have the person’s permission to provide their data and you must tell them how we will use it.
HOW YOUR PERSONAL DATA MAY BE USED.
Legal grounds for using your personal data.
To use your personal data, we must have grounds under UK data protection law, these grounds are explained below:
If you have given us permission to use your data for marketing. You can change or withdraw your consent at any time by emailing updateinfo@bmwparklane.co.uk,
Where needed to form or perform our contract with you,
Where we need to use it to comply with our legal obligations,
Where we have legitimate reasons to use your data, and our reasons for using it outweigh the impact on your data protection rights. Our legitimate reasons for using your data may include but are not limited to:
Research and development of vehicle related products and services,
To inform you about safety recalls or important maintenance,
Assessing your credit worthiness and detecting fraud and criminal activities,
Protecting our selective distribution system, for example identifying unauthorised retailers selling MINI or BMW products.
MINI ID
To use some MINI UK services, you will need a MINI ID Online Account. When you set up a MINI ID Online Account, you will get a MINI ID which is normally your email address. Your MINI ID can then be used to login to your MINI ID Online Account, customer portals, or MINI App in the future. Your MINI ID can also be used to identify yourself when you visit us or an alternative MINI Retailer or need help from MINI UK.
To provide your MINI ID Online Account, BMW AG stores your MINI ID, password, and name. This information is provided to BMW Group companies so you can login to your account on their website and other customer portals.
Important note: If you have more than one MINI ID Online Account, changes to one account may not automatically update your other accounts. Please make sure you update all your online accounts with important changes, like your contact details, or marketing preferences.
We will collect and use your personal data in the following ways:
As part of the vehicle sales process,
When your vehicle is serviced, maintained, or repaired,
To improve the service we provide,
To provide you with customer service and support,
To send you marketing promotions if you have consented to this.
Further details are provided here:
Vehicle sales process.
During the sales process, we use your personal data to help you with your choice of MINI, set up test drives, and administer your purchase. The following types of data are collected and used during the sales process:
Contact details,
Contract data,
Identification information,
Payment data,
Online account data,
Vehicle technical data,
Vehicle configuration data,
Vehicle ownership data,
Credit and anti-fraud information.
Vehicle servicing, maintenance, and repair.
Technical data will be read from the vehicle and used by technicians to diagnose and repair problems. We may use your personal data (e.g. contact details) to inform you about any problems found.
Service improvement.
This data is used to improve processes, and train staff so they can deliver better service to you and other customers.
Customer service and support.
We may use your personal data to:
Process your contract or provide you with service or support. This includes dealing with problems or complaints,
Contact you if there is a problem with your vehicle or it needs to be recalled for safety reasons,
Identify you when you contact us for help,
Send you customer surveys or information about related products after you have made a purchase. You can tell us to stop sending these types of communications at any time,
We may communicate with you using various channels including email, phone, SMS, or in writing.
Marketing promotions.
You will also be asked how you want to receive information (e.g. by email, or the MINI App, or through the in-car display, or by phone or SMS). We will use the data you provide us, and the products you show an interest in, to send you information that is relevant to you.
You can change or withdraw consent at any time by contacting us.
Data transfer to selected third parties
Data will be shared with the following companies, among others, if the necessary data protection requirements are met:
To affiliated companies, for example, insofar as this is necessary for customer support,
To MINI UK, e.g. in order to be able to submit specific offers or answer your specific enquiries within the scope of the sale of new MINI vehicles or Young Used MINI vehicles, to update your address and your vehicle for the purpose of customer support, as well as other personal data (e.g. hobbies and interests) if your consent to advertising purposes permits this or also vehicle data used by MINI UK in particular for the purpose of product monitoring and development,
To carefully selected and screened service providers and business partners with whom we work to provide you with products and services,
To other third parties (e.g. public authorities) if we are lawfully requested to hand over data or insofar as we have our own legitimate interest in the transfer (e.g. as part of the investigation of criminal charges or in legal proceedings).
Young Used MINI vehicles are used MINI Vehicles which are owned by MINI UK and which are not new, but not older than 18 months from first registration (excluding the time for refurbishment and sales offering) and which are designated by MINI UK for sale via MINI Retailers.
Joint control with MINI UK in context of the distribution of new MINI vehicles and Young Used MINI vehicles
In connection with the sale of new MINI vehicles and Young Used MINI vehicles, we and MINI UK collaborate together closely. We have a shared interest in offering you a smooth and convenient buying experience with the aim of providing the best possible customer service. With your MINI ID, you may switch between the MINI website, the MINI App or face-to-face at any MINI Retailer. For example, if you have configured a new vehicle and saved the configurations in your MINI ID Online Account, then you may use your MINI ID to authorise us to view relevant information (e.g. name, contact details, vehicle of interest, test drives) from your MINI ID Online Account so that we can, for example, further explain your desired model to you on site and offer it to you for a test drive. Or you can conveniently order your desired model, which you may have test-driven with us, in your MINI ID Online Account.
In order for us and MINI UK to be able to offer this comprehensive and always up-to-date care and support, whether in context of the conclusion or execution of a contract, general customer care or in context of marketing based on your consent to promotional communication, it is necessary that we and MINI UK have access to your current and relevant customer data. For example, if you have already saved your desired model in your MINI ID Online Account, then we may in an onsite, face-to-face conversation seamlessly explain to you a corresponding offer for this vehicle based on this information. To enable the data exchange required in that case, MINI UK will provide us, as a service provider, with a central system for customer data management. We and MINI UK routinely exchange customer data via this system.
Such data includes contact data (e.g. name, postal address, email address, telephone number), offer information and essential contract information (including e.g. vehicle identification number, vehicle connections, billing information, company relations, data necessary for compliance checks (e.g. checks against sanction lists or lists of politically exposed persons, anti-money laundering checks, such as date of birth, place of birth, nationality), interaction data (contact history, sales history); additional customer service information (e.g. preferences and interests, information about your consent to promotional communications, preferred language).
We and MINI UK are joint data controllers within the meaning of Art. 26 of the UK GDPR with regard to this mutual exchange of customer data and the associated maintenance of current customer data.
The subsequent use of your data by us or MINI UK – such as for the purpose of contract processing or for marketing purposes – is then the sole responsibility of us or MINI UK.
If you would like to learn more about the processing of your data under the joint control and responsibility of MINI UK and us, or if you would like to exercise your rights as data subject, then you may contact MINI UK at any time: by email at data_protection@bmw.co.uk.
COMPLIANCE WITH LEGAL REQUESTS FOR YOUR PERSONAL DATA.
We may be legally required to provide your personal data 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 DATA.
The use of your personal data as 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 may withdraw your consent at any time through the MINI Park Lane website or:
Calling: 0370 7005223,
Sending an email to: updateinfo@bmwparklane.co.uk,
Writing to us at: Marketing Department, MINI Park Lane, 70 Park Lane, London, W1K 7TT.
Where necessary to enter into or perform our contract with you,
To comply with our legal obligations,
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),
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 to you as soon as possible after becoming aware of the new basis.
THIRD PARTIES TO WHOM WE MAY TRANSFER YOUR DATA.
Personal data which we collect from you may be transferred to or accessed by third parties on our behalf, with your consent where necessary. The types of recipients, apart from the BMW companies already stated are:
Marketing and research companies who run and manage marketing campaigns,
Government Organisations e.g. DVLA,
Event companies who run and manage events,
Third party companies that provide customer services (e.g. roadside assistance),
IT providers who provide us with systems and services,
Finance providers and Insurance Administrators,
Card Payment Service providers who operate payment platforms,
Logistics and courier companies who transport our products to or from you,
Law firms who provide legal advice to us (e.g. where there is a customer dispute).
This is only shared in a secure manner. 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.
Park Lane Ltd may also transfer your personal data to a recipient without your consent if it is in its legitimate interest or if there is a contractual obligation to do so.
HOW DO WE KEEP YOUR PERSONAL DATA SAFE?
We use a variety of security measures, including encryption and authentication tools, to help protect and maintain security, integrity and availability of your data.
Although data transmission over the Internet or websites cannot be guaranteed to be secure, we and our business partners work hard to maintain physical, electronic and procedural safeguards to protect your personal data in accordance with applicable data protection requirements. Our main security measures are:
Tightly restricted access to your data and for the communicated purpose only,
Transferring collected data only in encrypted form,
Highly confidential data stored only in encrypted form,
Firewalled IT systems to prohibit unauthorised access,
Permanently monitored access to IT systems to detect and stop misuse of personal data.
Security measures for location data
Certain services can only be offered if you share your or your vehicle’s location. BMW Group take the confidentiality of location data very seriously.
Location data (including data accessed as part of vehicle maintenance) is protected with the following safeguards:
It will only be stored in a way that can be attributed to you or your vehicle for as long as needed for the purpose you agreed to,
Location data is only collected and accessed to provide the service you requested,
Location data is also collected and accessed if we are contractually or legally required to store or hand over the data,
Data for locating the vehicle and or your mobile device will be linked only if it is necessary to provide the service your requested,
Location data analysed for any other reason will not be attributable to you.
BMW Group may have access to the location data of your mobile device via the services it provides, like, MINI Connected.
You will be told what location data will be shared with us when you:
Test drive,
Buy a vehicle,
Activate or update MINI Connected Services,
Use the MINI App.
You can decide whether location data is shared, using the settings in the MINI App or the vehicle. There may be situations where sharing cannot be prevented. If you decide to restrict location data sharing, we may not be able to provide certain services to you.
HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR.
We retain your personal data only as long as is necessary and only for the purpose for which we obtained them. We restrict access to your personal data to only those persons who need to use it for relevant purposes.
Our retention periods are based on business needs and your personal data that is no longer needed is either pseudonymised, irreversibly anonymised or destroyed securely.
Use for marketing: We retain your personal data for as long as is necessary, but only for the relevant purpose that we collected it for, unless you request the deletion of such data and there are no contractual or statutory retention obligations that conflict with deletion requests.
Use to perform a contract: In relation to your personal data used to perform any contractual obligation with you, we may retain that personal data whilst the contract remains in force plus six years to deal with any queries or claims thereafter.
Where claims are contemplated: In relation to any personal data 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 personal data for as long as that claim could be pursued.
Use of vehicle-related data for purposes of sales, service and administrative processes: The data related to a vehicle (e.g. service and maintenance information) will be retained for the lifetime of a vehicle.
Use of vehicle-related data for purposes of assurance of product quality, research and development of new products: The data related to a vehicle will be retained in de-personalised form for 10 years.
WHO WE SHARE YOUR PERSONAL DATA WITH.
Your personal data 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 personal data that is accessible outside the EEA is handled subject to appropriate safeguards.
Certain countries outside the EEA, such as Israel 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 personal data.
Data Protection Office, MINI UK, Summit One, Summit Avenue, Farnborough, Hampshire, GU14 0FB or at Dataprivacyofficer@bmw.co.uk.
CONTACTING US AND HOW TO CHANGE YOUR PRIVACY PREFERENCES.
If you have any questions in relation to our use of your personal data you should contact Park Lane Ltd. You can also change your preferences, or withdraw your consent in relation to how we use your personal data in one of the following ways:
Customer hotline on: 0370 7005223,
Sending an email to updateinfo@bmwparklane.co.uk,
Writing to us at: Marketing Department, MINI Park Lane, 70 Park Lane, London, W1K 7TT.
You are also able to request information about your personal data stored at Park Lane Ltd as well as request the correction, deletion or restriction of your personal data.
You also have the right to request us to:
Provide you with further detail on the use we make of your personal data,
Provide you with a copy of your personal data,
Update any inaccuracies in the personal data we hold about you,
Delete any personal data 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 data in a usable electronic format and transmit it to a third party (right to data portability),
Restrict our use of your personal data,
Cease carrying out certain processing activities based on the legitimate interest 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,
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.
We generally strive to comply with all requests within 30 days. This period may be extended, however, if necessary due to reasons related to the specific data subject right or the complexity of your request.
In certain situations when required by law, we may be unable to provide you with information about all of your personal data. If we have to refuse your request for information in such a case, then we will simultaneously inform you about the reasons for the refusal.
Insofar as you wish to exercise your data subject rights as explained above with regard to data processing that falls in the joint control of us and MINI UK, you may contact both us and MINI UK. To the extent necessary for compliance, we and MINI UK will exchange relevant information. Please note that in some situations, a party other than the one you have contacted will need to approach you in order to address and satisfy your data subject right. For example, if you request data access from us regarding the data processing that falls in the joint control of us and MINI UK, then the information may also be disclosed by MINI UK.
If you are dissatisfied with our use of your personal data or our response to any exercise of these rights, you have the right to complain to your data protection authority. In the UK, this is the Information Commissioner's Office: www.ico.org.uk.
DATA PRIVACY OFFICER CONTACT DETAILS.
The contact details for our Data Privacy Officer are here: Data Protection Office, MINI UK, Summit One, Summit Avenue, Farnborough, Hampshire, GU14 0FB or at Dataprivacyofficer@bmw.co.uk.