1. IntroductionThis Privacy Statement explains the ways in which we collect, manage, process, store and share information about you as a result of you visiting this site, and provides you with information about how you can have control over our use of your data.
Victor Holdings Limited is committed to protecting and respecting your privacy. In doing so, we observe UK and Republic of Ireland data protection legislation and are committed to protecting and respecting your privacy and rights. We act as “Data Controller” in respect of the information gathered and processed by this website.
If you have any comments or queries regarding our use of your data, please contact our Data Protection Officer by email at firstname.lastname@example.org or write to us at Victor Holdings Limited, Units 1 & 2, Cotton Court, Middlewich Road, Holmes Chapel, CW4 7ET
2. What information do we collect about you?In general terms, we seek to collect information about you so that we can:
- fulfil orders that you may make via this website;
- provide high-levels of customer care and support;
- communicate with you effectively about your order, or so that you don't miss out on great promotions, offers and helpful reminders.
The information that we need for these purposes is known as your “personal data”. This includes:
- Personal and contact details such as your name, title, home address, fitting address, mobile number and e-mail address.
- Transaction data including information such as details of your purchase i.e. order number, order value, the type of time slot that you have booked and the way in which you made your purchase.
- Financial data including your credit or debit card details. However please note that we do not store any of your card information.
- Product and services that you have purchased from us, or have shown an interested in
- Vehicle information such as the make and model of your car, its age, the tyres that are fitted to the vehicle as well as their tread depth. Some of this data is captured when you place
andorder with us, and some iscaptured when we fit your tyres.
- Marketing and analysis data that identify your communications preferences, when we have communicated to you in the past, whether you engaged with or clicked on any links within those communications, the channels that you used to visit our website. We also analyse data to decide how best to communicate
toyou, and to send offers that we think you will be interested in.
- Information gathered from 3rd parties such as details about your vehicle to improve the experience that you have on our website, and to provide you with relevant products at a time when you will be interested in them.
- Profile data including when and what you purchased from us, your preferences, any feedback from you and survey responses.
- Technical data such as the device that you use to visit our website, your internet protocol (IP) address, browser type and version, browser plug-in types and versions, operating system and platform.
- Insights about you and our customers that is gained from deriving, processing and analysing the data outlined above.
We collect this data in a number of different ways. For example, you may provide it to us directly when filling in forms on this website, or when corresponding with us by telephone, e-mail or letter.
Please also be advised that by using this website, we will not be collecting any special categories of data about you (i.e. data about your ethnicity, religion, health etc).
When you visit this website, cookies will be used to collect information about your visit such as the pages you viewed or searched for, page response times, download errors etc. We do this so that we can measure our website’s performance and make improvements in the future. Cookies are also used to enhance this website’s functionality and personalisation, which includes sharing data with
We buy, rent or licence information about your vehicle to help improve our products and services from HaynesPro.
3. How will we use your personal data?We use the data collected from you for the specific purposes listed in the table below. Please note that this table also explains:
- the lawful basis for processing your data, linked to each processing purpose;
- in what circumstances your data will be shared with a third party organisation; and
- for how long we keep data collected by this website.
|Where data is stored and any 3rd party organisations with whom data is shared||Data retention|
|To fulfil purchases and orders which you may make via this website, including recording your order details, keeping you informed about the status of your order, processing payments and refunds, collecting money owed to us and assisting with any fraud prevention.||To perform our contract with you.||Details will be held within our customer database in order to fulfil your order.||10 years from the end of a customer’s last interaction.|
|Car registration (VRM) data is captured during the ordering process to streamline the ordering process and assess the accuracy of||This is necessary for our legitimate interests as it is in customers’ interest that we can provide them with tyres that are suitable for their vehicle.||VRM data is matched to the data of our partner, Haynes, who provide us with the make, model and age of the vehicle. This data is then associated||10 years from the end of a customer’s last interaction.|
|During the ordering||To perform our contract with you.||Postcode data is stored against a customer's order when they place an order with us.||10 years from the end of a customer’s last interaction.|
|To process customer requests for finance (please note that this includes processing for the purposes of fraud prevention)||Customers will be asked to provide informed consent before their data is processed for the purposes of seeking finance.||We offer finance to our customers through our partners, PayPal & Afford it Now. Any data relating to finance is processed and stored by these parties, and no data is stored on our systems.||No payment data is retained by Victor Holdings Limited. Please refer to the finance providers terms and conditions about the data that they store and process.|
|To ask for feedback on your shopping experience using onsite polls and surveys||This is deemed legitimate as it is in your interest to be able to provide feedback directly us, in order to address any specific issues or||Customer details will be held in our customer database and emails will be sent||10 years from the end of a customer’s last interaction.|
|Taking payment for orders placed over the telephone & online||To perform our contract with you.||We partner with Sage Pay, PayPal & Braintree as payment gateways for possessing payments online and over the telephone. No data relating to a payment (such as bank and card details) are stored on our systems other the format in which the payment was made.||No payment data is retained by Victor Holdings Limited|
|To communicate with you via email, SMS text or telephone in order to update you as necessary about your specific order or purchase, for||To perform our contract with you and for our legitimate interests.||Order activities will be recorded on our customer database, and we will use it to send out emails and SMS text messages to you. These will be sent directly from us,||10 years from the end of a customer’s last interaction.|
|After-sales data processing|
|To provide customer services support by telephone, email, SMS or letter: this includes the recording of telephone conversations for monitoring and quality purposes||This is necessary for our legitimate interests as it is in customers’ interest that we can access their data in order to resolve any queries, questions, concerns or complaints.||Customer services information will be recorded on our customer database and call recordings will be stored by our partner, NewVoiceMedia.||Call recordings and the telephone number used to make the call will be stored for 6 months from the date that the call was made, and we will store data on our customer database for 10 years from the end of a customer’s last interaction.|
|To send you emails asking you to complete a review of our service and products.||This is deemed legitimate as it is in customers’ interest to be able to provide feedback upon the products that they have purchased to better inform the wider public||Customer details will be held in our customer database. Please note that your data will only be shared with our review partner, TrustPilot, or within our own data warehouse.||10 years from the end of a customer’s last interaction.|
|We capture data via an app that is used by our technicians to log information about your tyre tread, brake condition and depth and wheel condition. We also store an image of your signature and an image of||This is deemed legitimate as it is in customers’ interest to||We store all data within our in-house database as well as our customer databases managed by our partners RedEye and Peak.||10 years from the end of a customer’s last interaction.|
|Data processing for online services|
|To personalise the information delivered to you via our website based on your||This is deemed legitimate as it is in customers’ interest to see products and services that are relevant to them and/or that they have specifically told us is of most benefit or value to them.||We store data about what you have viewed or purchased from us in the past and use this data to make your purchasing journeys with us in the future more streamlined.||10 years from the end of a customer’s last interaction.|
|Data processing for marketing|
|To send emails about special offers and promotions that are relevant to you, as well as helpful reminders: this includes, for example, emails about||This is deemed legitimate as it is in customers’ interest to see products and services that are relevant to them and/or that they have specifically told us is of most benefit or value to them. Customers can opt out of receiving emails from us at any time.||Customer details will be held in our customer database which is managed on our behalf RedEye and Peak.||10 years from the end of a customer’s last interaction.|
|To||This is deemed legitimate as it is in customers’ interest to gain a discount or incentive to refer us||A customer's name and potentially other identifying information will be stored in our partner's database (Mention Me), to be used in order to track who has been referred to us and by whom. This data will also be stored within our data warehouse.||10 years from the end of a customer’s last interaction.|
|To use customer data (primarily email addresses) to deliver advertising across various online marketing platforms (e.g. Google, Facebook)||This is deemed legitimate as it is in our interest that we understand how customers use our products and services, to develop them, to grow our business and inform our marketing strategy.||Customer data will be shared with various advertising partners; however, in all instances, this data will be anonymised before sharing||10 years from the end of a customer’s last interaction.|
|Other data processing|
|To process competition entries and inform winners||Customers give consent when they submit competition entries: this is separate to consent for marketing purposes||Details will be held in our customer database and may be shared with any third parties identified||10 years from the end of a customer’s last interaction.|
|To administer, protect and improve our business and our website||This is deemed legitimate as it is our interest so that we can run our business effectively, for the provision of administration and IT services, network security and to detect and identify fraud. It is also necessary to comply with a legal obligation.||Customer details will be held in our customer database||10 years from the end of a customer’s last interaction.|
|To match data that we hold in order to acquire improved insight about our customers both individually and at aggregated level: this requires us to profile you as described more fully in section 5.8 below||This is deemed legitimate as it is in customers’ interest that we understand their preferences and buying behaviours so that the information we provide is tailored to them||Customer details will be held in our in-house customer database and within our database managed by our partner, Peak.||10 years from the end of a customer’s last interaction.|
5. Your rightsUnder the terms of data protection legislation, you have the following rights as a result of using this website:
5.1 Right to be informedThis Privacy Statement, together with our Cookies Policy, fulfils our obligation to tell you about the ways in which we use your information as a result of you using this website.
5.2 Right to accessYou have the right to ask us, in writing, for a copy of any personal data that we hold about you. This is known as a “Subject Access Request”. Except in exceptional circumstances (which we would discuss and agree with you in advance), you can obtain this information at no cost and we will send you a copy of the information.
To make a Subject Access Request, please write to our Data Protection Officer at Victor Holdings Limited, Units 1 & 2, Cotton Court, Middlewich Road, Holmes Chapel, CW4 7ET
5.3 Right to rectificationIf any of the information that we hold about you is inaccurate, you can contact our Data Protection Officer at email@example.com. Any corrections that you request will be made as soon as possible.
5.4 Right to be forgottenFrom 25 May 2018, you can ask that we erase all personal information that we hold about you. Where it is appropriate that we comply, your request will be fully actioned. For further information, please contact our Data Protection Officer at firstname.lastname@example.org.
5.5 Right to objectYou have the right to object to:
- the continued use of your data for any purpose listed in section 3 of this Privacy Statement for which consent is identified as the lawful basis of processing (i.e. you have the right to withdraw your consent at any time);
- the continued use of your data for any purpose listed in section 3 of this Privacy Statement for which the lawful basis of processing is that it has been deemed legitimate.
In some circumstances (i.e. consent to email marketing communications), you can exercise your objection by unsubscribing using the link at the bottom of any of the emails that we send.
For all other circumstances, you can contact our Data Protection Officer at email@example.com.
5.6 Right to restrict processingIf you wish us to restrict the use of your data because (i) you think it is inaccurate but this will take time to validate, (ii) you believe our data processing is unlawful but you do not want your data erased, (iii) you want us to retain your data in order to establish, exercise or defend a legal claim, or (iv) you wish to object to the processing of your data, but we have yet to determine whether this is appropriate, please contact our Data Protection Officer at firstname.lastname@example.org. Please note that we are allowed to retain sufficient information about you to ensure that the restriction is respected in the future.
5.7 Right to data portabilityIf you would like us to move, copy or transfer the data that we hold about you to another organisation, please contact our Data Protection Officer at email@example.com.
Please be advised that this only applies to certain data which has been submitted by you electronically for specific purposes only. Our Data Protection Officer can provide further advice.
5.8 Rights related to automated decision-makingIn order that we can understand your interests and preferences - and deliver communications that will be most of interest to you - we employ profiling techniques (which include automated decision-making) based upon the information that you have provided to us, as well as your purchasing history and engagement with us. We do not believe that these processes have any potential to significantly or negatively affect you i.e. they will not lead to any form of discrimination against you or impact your legal rights.
Examples of how we use profiling are as follows:
- If you purchased tyres for a BMW in the past, we may send you targeted emails that are more relevant to your vehicle.
- If you do not engage or interact with special offer emails that we send you (even though you will have consented to receive these), we are likely to send you fewer emails than customers who are more actively involved with us.
If you do not want us to undertake this form of data processing, you may either:
- object to the processing of your data (see section 4.5 of this Privacy Statement above); or
- request that Victor Holdings Limited erases all personal data about you (see section 4.4 of this Privacy Statement above).
6. Data privacy and securityWe maintain a comprehensive data management work programme, which includes processes for ensuring that data protection is a key consideration of all new and existing IT systems that hold your personal data. Where any concerns, risks or issues are identified, we conduct relevant impact assessments in order to determine any actions that are necessary to ensure optimum privacy.
We also maintain an active information security work programme which seeks to protect the availability, confidentiality and integrity of all physical and information assets. Specifically, this helps us to:
• protect against potential breaches of confidentiality;
• ensure all IT facilities are protected against damage, loss or misuse;
• increase awareness and understanding of the requirements of information security, and the responsibility of our colleagues to protect the confidentiality and integrity of the information that they handle; and
• ensure the optimum security of this website.
We recognise that the security of data and transactions on this website is of primary importance. We
7. DisclaimersEvery effort is made to ensure that the information provided on this website, and in this Privacy Statement, is accurate and up-to-date, but no legal responsibility is accepted for any errors or omissions contained herein.
We cannot accept liability for the use made by you of the information on this website or in this Privacy Statement, nor do we warrant that the supply of the information will be uninterrupted. All material accessed or downloaded from this website is obtained at your own risk. It is your responsibility to use appropriate anti-virus software.
This Privacy Statement applies solely to the data collected by
8. AccessibilityWe are committed to providing a website in which content is accessible to everyone. We
For example, users can control the text size of each page within their browser. On a PC, holding the “Ctrl” key while pressing the “+” (plus) key will increase text size, and holding the “Ctrl” key while pressing the “-“ (minus) key will decrease the text size.
Questions and comments regarding this Privacy Statement are welcomed and should be sent to our Data Protection Officer at firstname.lastname@example.org.
You can also contact our Data Protection Officer if you have any concerns or complaints about the ways in which your personal data has been handled as a result of you using this website.
Alternatively, you have the right to lodge a complaint with the Information Commissioner’s Office who may be contacted at Wycliffe House, Water Lane, Wilmslow SK9 5AF or https://ico.org.uk.
This privacy notice was last updated on 25th May (Version v1.1)