PROTECTING YOUR PRIVACY
Introduction
This Privacy Policy explains in detail the types of personal data we may collect about you when you interact with us as a business on our web site and in our shops. It also explains how we will store, use and handle that data, and keep it and you safe.
We know that there’s a lot of information written here, but we really want you to be fully informed about your legal rights, and how the BAS Corporation (BAS Remaps) uses your data
We hope the following paragraphs will help to answer any questions you may have but if not, please do not hesitate get in touch with us with specific questions should you have any.
We will make regular updates to this Privacy Policy , you are welcome to come back and re read it whenever you wish.
Explaining the legal bases
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data.
Consent
In some situations we can collect and process your data with your consent generally by the means of a tik box or Opt-In box.
For example, when you tick a box to receive email newsletters should you Opt-In for them.
When collecting your personal data we will always make it clear to you which data is necessary in connection with a particular service, for example using your email address so we can send you the latest offers or product information, as well as using it to give technical support for products.
Contractual obligations
In certain circumstances, we need your personal data to comply with our contractual obligations.
For example, if you order products from us for delivery to your home or work address, we will collect these address details to be able to deliver your purchase and we will pass them directly on to our used courier services (Normally UPS or Royal Mail).
Legal compliance
If the law requires us to, we may need to collect and process your data.
For example, we may pass on all held details of people involved in fraud or other criminal activity affecting our company to the local law enforcement police.
Legitimate interest
In specific situations we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our main business and which does not materially impact your rights, freedom or interests in any way.
For example, we may use your purchase history to send to you or make available for you personalised product offers.
We may also use shopping cart history of many customers to identify the most common trends and purchases to ensure that we can keep up with order demand, or develop new products and services.
When do we collect your personal data
When you visit our website to buy products and or services, or on the phone and in a workshop.
When you make an online purchase and check out as a guest we just collect transaction-based data.
When you create an web shop account with us.
When you purchase a product or service in our workshop store or by phone but don’t have a web account.
When you engage with us on social media, Facebook, Twitter, LinkedIn are some of the social media platforms we use.
When you download or install one of our apps from both Apple iTunes store and also Google Play store.
When you make any purchase from BAS Corporation.
When you contact us by any means with queries and or complaints etc, we save information here so we can offer you the best service possibile.
When you ask one of our Dealers or trading Partners to email you information about a product or service.
When you book any kind of appointment with us or book to attend an event, for example a trade show event.
When you comment on or review our products and services on our web site.
When you fill in any forms on our web site or in our store workshop as well as at trade shows we attend.
We may also collect data information on an accident happens in our workshops for insurance purposes, at this point we may collect your personal data and share it with a third party.
When you have given a third party permission to share with us the information they hold about you.
What sort of personal data do we collect
If you have a web account with us we will collect:
your name,
gender,
date of birth,
billing and delivery addresses,
orders and receipts,
email, fax and telephone numbers.
For your security we will also keep an encrypted record of your login password so you can re visit our web shop without having to make a new account every time.
We may also for example collect notes from our conversations with you both on the phone or in emails, as well as details of any complaints or comments you make, any details of purchases you made and bespoke items that require specific information held for their use, items viewed on our web shop and or added to your basket, any web pages you have visited and how and when you contact us.
Copies of documents you provide to prove your age or identity where the law requires this. (including your passport and driver’s licence). This will include details of your full name, address, date of birth and facial image. If you provide a passport, the data will also include your place of birth, gender and nationality.
Details of your shopping and purchase preferences.
Details of your visits to our websites or use from any of our smart phone or tablet apps, and which site you came from to ours.
Payment card information.
Your comments and product reviews.
Your image may be recorded on our workshop CCTV when you visit our workshop or park in our car park.
Your car number plate may also be recorded.
To deliver the best possible web and app use experience we may also collect technical information about your internet connection and browser type, pc type as well as the country and telephone code where your computer is located via your ip addresses and the web pages viewed during your visit including all web chat text.
How and why do we use your personal data
We want to always give you the best possible customer experience, one of the ways to achieve this is to get the best picture we can of who you are by whilst combining the data we have about you.
We then use this to offer you promotions, products and services as well as product support and technical information directly related.
The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.
If you wish to change how we use your data, you will see more details in the ‘What are my rights?’ section below.
Please remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services or products you have asked for.
For example, if you’ve asked us to let you know when an item comes back into stock, or have asked us to create software products for you and let you know when they are ready we can’t do that if you have withdrawn your general consent to hear from us.
Here’s how we’ll use your personal data and why
To process any orders that you make by using our websites, apps or in store. If we don’t collect your personal data during checkout, we will not be able to process your order and comply with our legal obligations.
For example, your details may need to be passed to a third party to supply or deliver the product or service that you ordered, and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds, guarantees and so on.
To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account.
We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest.
For example, by checking your password when you login and using automated monitoring of IP addresses to identify possible fraudulent log-ins from unexpected locations.
To protect our customers, premises, assets and Partners from crime, we operate CCTV systems in our workshop and car park which record images for security. We do this on the basis of our legitimate business interests.
To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We aim is to protect the individuals we interact with from criminal activities.
With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, telephone and through our contact centres about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on.
Of course, you are free to opt out of hearing from us by any of these channels at any time.
To send you relevant, personalised communications by post in relation to updates, offers, services and products. We’ll do this on the basis of our legitimate business interest.
You are free to opt out of hearing from us by post at any time.
To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, product recall or warranty notices, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
To display the most interesting content to you on our websites or apps, we will use data we hold about your favourite brands or products and so on. We do so on the basis of your consent to receive app notifications and or for our website to place cookies or similar technology on your device.
For example, we might display a list of items you’ve recently looked at, or offer you recommendations based on your purchase history and any other data you have shared with us.
To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.
For example, we will record your browsers Session ID to help us understand more when you leave us online feedback about any problems you’re having.
To send you survey and feedback requests to help improve our products and services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you.
Of course, you are free to opt out of receiving these requests from us at any time by updating your preferences in your online account.
To build a rich picture of who you are and what you like, and to inform our business decisions, we will combine data collected from across the BAS Corporation dealer network, third parties and data from publicly available lists as we have described in the section ‘What Sort of Personal Data do we collect?’ We will do this on the basis of our legitimate business interest.
For example, combining this data, this will help us personalise your experience and decide which content to share with you. We also use anonymised data from customer purchase histories to identify trends in different areas of the country.
To process your booking appointment requests. Sometimes we will need to share your details with a third party who is providing a service (such as delivery couriers or a fitter visiting your home). We do so to maintain our appointment with you. Without sharing your personal data, we’d be unable to fulfil your request.
Combining your data for personalised direct marketing
We want to bring you offers and promotions that are most relevant to your interests at particular times. To help us form a better overall understanding of you as a customer, we will combine your personal data gathered as described above, for example your shopping and purchase history at both on the web shop and in our workshop shop as well as at trade shows. For this purpose we also combine the data that we collect directly from you with data that we obtain from third parties to whom you have given your consent to pass that data onto us.
How we protect your personal data
We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.
We secure access to all transactional areas of our websites and apps using ‘https’ technology, as well as country blocking and also an advanced web site firewall.
Access to your personal data is password protected, and sensitive data (such as payment card information) is secured by SSL encryption.
We regularly monitor our system for possible vulnerabilities and attacks and carry out penetration testing to identify ways to further strengthen security.
How long will we keep your personal data
Whenever we collect or process your personal data we will only keep it for as long as is necessary for the purpose for which it was collected.
At the end of that retention period your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non identifiable way for statistical analysis and business planning.
Some examples of customer data retention periods
Orders. When you place an order we will keep the personal data you give us for at least five years so we can comply with our legal and contractual obligations. In the case of certain products such as electrical and tuning or remapping items, we’ll keep the data for upto 10 years.
Warranties. If your order included a warranty the associated personal data will be kept until the end of the warranty period.
Who do we share your personal data with
We sometimes share your personal data with trusted third parties.
For example, delivery couriers, technicians visiting your home, for fraud management, to handle complaints and to help us personalise our offers to you and so on.
Here is the policy we apply to those organisations to keep your data safe and protect your privacy.
We provide only the information they need to perform their specific services.
They may only use your data for the exact purposes we specify in our contract with them.
We work closely with them to ensure that your privacy is respected and protected at all times.
Examples of the kind of third parties we work with are.
IT companies who support our website and other business systems.
Operational companies such as delivery couriers, UPS and Royal mail mainly.
Direct marketing companies who help us manage our electronic communications with you.
Google, Facebook to show you products that might interest you while you’re browsing the internet.
This is based on either your marketing consent or your acceptance of cookies on our websites. See our Cookies Notice for details.
Sharing your data with third parties for their own purposes
We will only do this in very specific circumstances for example.
With your consent given at the time you supply your personal data we may pass that data to a third party for their direct marketing purposes.
For fraud management we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body in your country of origin or elsewhere upon a valid request to do so. These requests are assessed on a case by case basis and take the privacy of our customers into consideration.
We may from time to time expand reduce or sell the business and this may involve the transfer of divisions or the whole business to new owners. If this happens your personal data will where relevant be transferred to the new owner or controlling party under the terms of this Privacy Policy.
Where your personal data may be processed
Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA), such as Australia or the USA.
If you are based outside the UK and place an order with us we will transfer the personal data that we collect from you to any parties that are needed to fulfil your order.
The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway. We may transfer personal data that we collect from you to third party data processors in countries that are outside the EEA.
For example this might be required in order to fulfil your purchase order or to process your payment details or to also provide support services.
If we do this we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA. For example our contracts with third parties stipulate the standards they must follow at all times. Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Policy.
What are your rights over your personal data
You have the right to request access to the personal data we hold about you, free of charge in most cases.
You have the right to request the correction of your personal data when incorrect out of date or incomplete.
For example, when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end (such as the end of a warranty).
You have the right to request that we stop using your personal data for direct marketing (either through specific channels, or all channels).
You have the right to request that we stop any consent based processing of your personal data after you withdraw that consent.
You have the right to request a copy of any information about you that our business holds at any time and also to have that information corrected if it is inaccurate.
To ask for your information, please contact our Data Protection Officer, by recorded letter using the following address:
Data protection request information
PO Box 735
YORK
YO1 0HY
To ask for your information to be amended please update your online account or contact our support team via letter or web chat.
If we choose not to action your request we will explain to you the reasons for our refusal.
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation, we must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
You have the right to stop the use of your personal data for direct marketing activity through all channels or selected channels. We must always comply with your request.
To protect the confidentiality of your information, we may ask you to verify your identity before proceeding with any request you make under this Privacy Policy.
If you have authorised a third party to submit a request on your behalf we will ask them to prove they have your permission to act.
How can you stop the use of your personal data for direct marketing
There are several ways you can stop direct marketing communications from us:
Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails from that particular division.
If you have an account, log in into your web shop account, visit the ‘My Account’ area and change your preferences.
If you live outside the UK
For all non-UK customers by using our services or providing your personal data to us, you expressly consent to the processing of your personal data by us or on our behalf. Of course, you still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes.
Sometimes we will need to transfer your personal data between countries to enable us to supply the goods or services you’ve requested. In the ordinary course of business we may transfer your personal data from your country of residence to ourselves and to third parties located in the UK.
By dealing with us you are giving your consent to this overseas use transfer and disclosure of your personal data outside your country of residence for our ordinary business purposes.
This may occur because our information technology storage facilities and servers are located outside your country of residence and could include storage of your personal data on servers in the UK.
We will ensure that reasonable steps are taken to prevent third parties outside your country of residence using your personal data in any way that’s not set out in this Privacy Policy. We will also make sure we adequately protect the confidentiality and privacy of your personal data.
Australia
For the purposes of this Privacy Policy, personal data means any information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether or not the information or opinion is true, and whether or not the information or opinion is recorded in a material form.
If you are in Australia you may submit any questions comments or complaints to our UK based Protection Officer who will come back to you within 30 days.
If you are contacting us to complain about an alleged breach of this Privacy Policy or our legal privacy obligations please provide us with as much detail as possible in relation to your complaint.
We will take every privacy complaint seriously and assess it with the aim of resolving all issues quickly and efficiently. We would be grateful for your cooperation with us during this process by providing us with any relevant information that we made need.
If we have not come back to you within 30 days or you are not happy with the response that you have received, you may submit a complaint to the Office of the Australian Information Commissioner.
We are committed to keeping your personal information secure and will take all reasonable precautions to protect it from loss, misuse or unauthorised access or alteration. However, except to the extent liability cannot be excluded due to the operation of statute we exclude all liability (including in negligence) for the consequences of any unauthorised access to, disclosure of, misuse of or loss or corruption of your personal information.
Nothing in this Privacy Policy restricts, excludes or modifies or purports to restrict, exclude or modify any statutory consumer rights under any applicable law including the Competition and Consumer Act 2010 (Cth).
Canada
As your data may be transferred to third parties outside Canada, local police or other enforcement, regulatory or Government bodies may have access to that data, with or without our knowledge.
The personal data we process may be accessed by people within the Partnership, or by our third party service providers, who require access for the purposes indicated in this Privacy Policy, or as may be permitted or required by applicable law. The personal data we collect is mostly held in the UK.
If you have any questions, please contact our Data Protection Officer.
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal information, you have the right to lodge a complaint with the Office of the Privacy Commissioner of Canada, or in some Canadian provinces, your local Privacy Commissioner.
South Korea, Malaysia, Singapore, Qatar
Terms used in this Privacy Notice shall have the meanings assigned to them by the Personal Data Protection Act 2010 (also known as the PDPA).
By placing an order with us, opening an account, browsing our website and or agreeing to receive digital direct marketing communications, you agree that we may process your personal data as described in this Privacy Notice and our Cookies Notice, including for analytics and research into website use.
Hong Kong
If you are in Hong Kong you may submit a complaint to our UK-based Data Protection Officer who will come back to you within 30 days. If we have not come back to you or you are not happy with the response that you receive, you may submit a complaint to the Office of the Privacy Commissioner for Personal Data.