We, Spirit Motor Holdings Limited (trading as Spirit Hyundai), take information security and data protection very seriously. We are committed to ensuring that your privacy is protected. This Privacy Policy describes how we use the personal data we collect from you, or that you provide when you:

• visit any of our websites or portals (the "Website");
• view and enquire on vehicles in one of our showrooms or online;
• purchase a vehicle, parts, accessories or a service plan from us;
• have your vehicles serviced with us;
• make an online booking with us;
• or otherwise, contact us

Please read this Privacy Policy carefully before submitting any personal data to us.

Definitions
The "Company"
Spirit Motor Holdings Limited (trading as Spirit Hyundai), a company incorporated in England and Wales under registered number 02574496 and whose registered office is 1 Rushmills, Northampton, Northamptonshire, United Kingdom, NN4 7YB. For the Data Protection Legislation, the Company is the data controller.

"Customer Services"
Spirit Hyundai, 1 Rushmills, Northampton, Northamptonshire, United Kingdom, NN4 7YB can also be contacted by calling 0160 441 7850.

"Data Protection Legislation"
The General Data Protection Regulation 2016, and all other applicable laws and regulations relating to privacy and the processing of personal data.

"Third-Party" / "Third-Parties"
Any company with which personal data is shared:

• The vehicle manufacturer;
• Providers of automotive products and value-added services, namely insurance, finance, marketing, loyalty products, vehicle condition reporting, etc.;
• Third-Party processors for data hosting, print production, data transfer, SMS, email, direct mail, analytics, credit searches and fraud prevention.

"Personal Data"
Any information relating to an identified or identifiable natural person.


"Website"
We collect Personal Data from you through the use of forms, which may be on paper or our Website. There are various reasons that we need to collect Personal Data from you:

• Orders: So that we can fulfil any order for vehicles, parts, accessories or services that you place with us, we will need to collect your name, contact details (address, email address and telephone number) and payment details;
• Records:As part of our business, we maintain guarantee and service records for the vehicles and parts that we sell and/or service, and in keeping with these records, we will need to identify you as the owner of that vehicle;
• Safety issues: Where the vehicle manufacturer notifies us of any safety issues which may affect your vehicle, we will contact you using the details held in our records.
• Services: Where you have a service plan or have otherwise asked us to do so, or where it is part of our contract with you, we will contact you using the details held in our records with information and/or reminders about servicing and MOTs for your vehicle;
• Enquiries:Where you contact us with an enquiry or request a brochure, we will respond to you using the contact details you have provided;
• Surveys: From time-to-time, to improve our customer service or for research purposes, we may ask you to complete a survey or similar. Any personal data that you provide when completing a survey will be retained for that survey;
• Marketing: We may wish to tell you about other products and services we think may be of interest to you, or to share new and exclusive offers, news and events with you. We will only contact you with such marketing communications if you have provided your consent and given at least one preferred contact method, including direct mail, telephone, SMS or email;

We may also use Personal Data which you provide to you in any of the ways listed above and in the following ways:

• Your Personal Data may be shared with other subsidiaries of the Company and Third-Parties for the purposes set out above. Some Third Parties may be based outside the EEA, in countries that do not have the same standards of protection for personal information as the United Kingdom. We will, however, always comply with our obligations under the Data Protection Legislation before sending your Data to such countries, to ensure sufficient protections are in place to safeguard your Personal Data;
• We, and/or Third Parties may contact you with information about products and services that we, or the Third Parties, think may be of interest to you, where you have given your consent to receive marketing communications from us and/or Third Parties;
• To deliver our services to you and, as necessary, we may use Third Party processors. Such processing is conducted under the contract which contains the same protections for your Personal Data as are set out in this policy and we ensure that appropriate data protection and information security assurances are provided;
• Where it is necessary for the performance of our contract with you, including where we need to take steps to enforce any agreement which may be entered between us;
• Where we are under a legal duty to do so to comply with any legal obligation to which we are subject; To protect the rights, property or safety of our company, our staff and others;
• If we sell or buy any business or assets in which case we may disclose your Personal Data to the prospective seller or buyer as part of the sale or purchase process and disclosure is required to allow that transaction to proceed; or
• If we or substantially all of our assets are acquired by a Third Party, in which case personal data that we hold about our customers will be one of the transferred assets.

Sharing your Personal Data
The information you share with us will only be disclosed to relevant employees to be used for the relevant purpose stated above. We will not otherwise disclose your Personal Data to any third party unless one of the following applies:

• Your Personal Data may be shared with other subsidiaries of the Company and Third-Parties for the purposes set out above. Some Third Parties may be based outside the EEA, in countries that do not have the same standards of protection for personal information as the United Kingdom. We will, however, always comply with our obligations under the Data ProtectionLegislation before sending your Personal Data to such countries, to ensure sufficient protections are in place to safeguard your Personal Data;
• We, and/or Third Parties may contact you with information about products and services that we, or the Third Parties, think may be of interest to you, where you have given your consent to receive marketing communications from us and/or Third Parties;
• To deliver our services to you and, as necessary, we may use Third Party processors. Such processing is conducted under the contract which contains the same protections for your Personal Data as are set out in this policy and we ensure that appropriate data protection and information security assurances are provided;
• Where it is necessary for the performance of our contract with you, including where we need to take steps to enforce any agreement which may be entered between us;
• Where we are under a legal duty to do so to comply with any legal obligation to which we are subject;
• To protect the rights, property or safety of our company, our staff and others;
• If we sell or buy any business or assets in which case we may disclose your Personal Data to the prospective seller or buyer as part of the sale or purchase process and disclosure is required to allow that transaction to proceed; or
• If we or substantially all of our assets are acquired by a Third Party, in which case personal data that we hold about our customers will be one of the transferred assets.

Data retention
You can select your marketing preferences by ticking the relevant boxes on any form where we collect personal data from you. We will not contact you for marketing purposes unless you have given us your prior consent. If you have opted-in to receive marketing material from us, we will use your chosen contact methods to send this information.

If, at any time, you no longer wish to receive marketing information, please send a written request to customerservices@spirit-hyundai.co.uk or on all of our e mail marketing communication it will give you the option to opt-out of receiving further marketing communications.

Please note that you will still receive emails directly related to an enquiry you have made via our online enquiry portal or under any other contract you have with us.


Data security
The security of your Personal Data is of the utmost importance to us. We are committed to providing appropriate security controls to protect your personal information against foreseeable hazards.

All information you provide to us is stored on our secure servers which are located in the United Kingdom only. Any payment transactions will be encrypted.

Please be aware that the transmission of data over the internet is not always completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the complete security of your data transmitted to us electronically; any transmission is at your own risk. Once we have received your Personal Data, we will use strict procedures and security features to restrict unauthorised access to your Personal Data.


Cookie usage
We use cookies to help improve our website and make your browsing experience more useful, relevant and tailored to you. Please see our Cookie Policy for more information.


Website links
We may add links to and from our Website to our partner networks, advertisers and affiliates from time to time. If you follow a link to any of these websites, please note that these websites will contain their privacy policies. We do not accept any responsibility or liability for these policies. Please check these policies before you submit any Personal Data to these websites.


Changes to this Privacy Policy
We keep our Privacy Policy under regular review; the updates will appear on our Website. Please check it each time you visit this Website or provide us with any Personal Data.

We last updated this Privacy Policy on 6 March 2019.


Policy feedback
If you have any questions about this Privacy Policy or any Personal Data which we hold about you please contact Customer Services.


Complaints
If you are unhappy with how we have collected or processed your Personal Data or have any other complaint concerning our handling of your Personal Data you can make a complaint to the Information Commissioner, further information can be found on the Information Commissioner’s website at www.ico.org.uk or via their helpline on 0303 123 1113.

Regulated Complaints
Complaints where you are operating under Automotive Compliance’s FCA permissions, the following contact details need to be on this page for complaints:

Regulated Complaints Post: Automotive Compliance Ltd, The Factory, 44 Alfred Street, Gloucester, GL1 4DD Telephone: 01452671560 E-mail: complaints@automotive-compliance.co.uk

Financial Ombudsman Service, the following information must also be added to this page: If we cannot resolve your complaint within 8 weeks, you may refer your dispute to the Financial Ombudsman Service. This service is free to use. Their consumer helpline is available on 0800 023 4567 or 0300 123 9123 or you can visit their website at www.financial-ombudsman.org.uk.