OLD EMPIRE TRADING CO LTD. T/A ENGLISH ELECTRIC MOTOR CO. (EEMC)
Last Revision: 22nd January 2019.
ABOUT THIS POLICY
Your privacy is important to us and we want you to feel comfortable with how we use and share your personal information, this policy sets out how English Electric and its third parties handle your personal information, including when and why it is collected, used and disclosed and how it is kept secure.
Our contact details can be found at the bottom of this policy should you have any questions, including how to update or access your personal information or to make a complaint.
This policy is subject to change, so please check this page from time to time to ensure that you’re happy with any changes.
WHO WE ARE
English Electric is a UK company comprising Old Empire Trading Co. Ltd. The ‘controller’ of your personal information will be the company in our group that you are interacting with namely English Electric or with whom your information has been shared. A ‘controller’ decides why and how your personal information is processed.
Where this policy refers to we, our or us below, unless it mentions otherwise, it’s referring to the particular company that is the controller of your personal information.
PERSONAL INFORMATION WE COLLECT AND HOW WE COLLECT IT
We may collect and process the following personal information about you
Personal information you give to us: This is information about you that you give to us by entering information via our websites, third-party websites, social media pages or by corresponding with us by phone, email or otherwise and is provided entirely voluntarily. The information you give to us includes your name, contact details such as phone number, email address and postal address, enquiry details and your opinion of our products.
Personal information we collect about you: We may automatically collect the following personal information: our web servers store as standard, details of your browser and operating system, the website from which you visit our website, the pages that you visit on our website, the date of your visit, and, for security reasons, e.g. to identify attacks on our website, the IP address assigned to you by your internet service. We collect some of this information using cookies, please see separate ‘Cookies’ section for further information. We may also collect any personal information you allow to be shared that is part of your public profile on a third-party social network.
Personal information we may receive from other sources: We obtain certain personal information about you from sources outside our business which may include third-party companies; the personal information received is as described in the two paragraphs above and will not be used for marketing purposes unless you have opted into receiving our communications.
Please see further ‘How we use your personal information’ for details of the purposes for which we use the personal information we obtain from these sources and the legal basis on which we rely to process that information. The remaining provisions of this policy also apply to any personal information we obtain from these sources.
HOW WE USE YOUR PERSONAL INFORMATION
Where you have provided consent
We may use and process your personal information where you have consented for us to do so for the following purposes:
- to arrange test rides, fulfil enquiries or information requests.
- to supply brochures and other material you have specifically requested from us.
- to contact you via email, text message, post or telephone with marketing information about Wheels Motorcycles events and other products and services (see Marketing section below for further details).
- to share your personal information with manufacturers and third parties for them to contact you with marketing information about their products and services. Please see the Marketing section below in this policy to find out more about these third parties.
Where required to perform a contact with you
We may use and process your personal information where it is necessary to fulfil a contract with you, for safety purposes or in order to take steps you requested prior to entering into a contract with you including for the following purposes:
- to exchange information for warranty/product recalls/aftersales.
- to allow for the provision of third-party service plans by our provider.
- to inform you of any safety recalls issued by the manufacturer or supplier regarding the vehicle or any associated fitted parts/accessories.
Where it is in the interests of safety
We may use your personal information to contact you if there are any urgent safety or product recall notices where we reasonably believe that the processing of your personal information will prevent or reduce any potential harm to you. It is in the interests of your safety for us to use your personal information in this way.
Where required to comply with our legal obligations
We will use your personal information to comply with our legal obligations including: to assist HMRC, the Police, the DVLA or any other public authority or criminal investigation body; to identify you when you contact us and to verify the accuracy of data that we hold about you.
Where there is a legitimate interest
We may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business for the following purposes:
- for analysis, and profiling to inform our marketing strategy, and to enhance and personalise your customer or visitor experience.
- to improve the relevance of products and services that we deliver to you.
- to administer our websites and for internal operations, including troubleshooting, testing and statistical purposes.
- for marketing activities (other than where we rely on your consent) for example to tailor marketing communications or send targeted marketing messages via social media platforms such as Facebook, Instagram, Twitter and other third-party platforms.
- for the prevention of fraud, money laundering and other criminal activities.
- to undertake credit checks for finance.
- to correspond and communicate with you.
- to create a better understanding of you as a customer or visitor.
- for network and information security in order for us to take steps to protect your information against loss or damage, theft and unauthorised access.
- to comply with a request from you in connection with the exercise of your rights for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request and the General Data Protection Regulation.
- for the purposes of corporate restructure or reorganisation or sale of our business or assets.
- for efficiency, accuracy or other improvements of our databases and systems.
- to enforce or protect our contractual or other legal rights or to bring or defend legal proceedings.
- for general administration including managing your queries, complaints, or claims, and to send service messages to you.
OTHERS WHO MAY RECEIVE OR HAVE ACCESS TO YOUR PERSONAL INFORMATION
Our suppliers and service providers
We may disclose your information to our third-party service providers, agents, subcontractors and other organisations for the purposes of providing services to us or directly to you on our behalf. Such third parties may include cloud services providers (such as hosting and email management) or advertising agencies, administrative services or other third parties who provide services to us.
When we use third-party service providers, we only disclose to them any personal information that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.
Third parties who provide products and services
We work closely with various third parties to bring you a range of products and services which are complimentary to ours.
When you enquire about or purchase one or more of these products or services through us, the relevant third-party may use your details to provide you with information and carry out their obligations arising from any contracts you have entered into with them.
Other ways we may share your personal information
We may transfer your personal information to a third-party as part of a sale of some or all of our business and assets to any third-party or as part of any business restructuring or reorganisation. We may also transfer your personal information if we’re under a duty to disclose or share it in order to comply with any legal obligation, to detect or report a crime, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our visitors and customers, we will always take steps to ensure that your privacy rights continue to be protected.
WHERE WE STORE YOUR PERSONAL INFORMATION OUTSIDE THE EEA
All information you provide to us may be transferred to countries outside the European Economic Area (EEA). By way of example, this may happen where any of our group companies are incorporated in a country outside of the EEA or if any of our servers or those of our third-party service providers are from time to time located in a country outside of the EEA. These countries may not have similar data protection laws to the UK.
If we transfer your information outside of the EEA in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this policy. These steps include imposing contractual obligations on the recipient of your personal information or ensuring that the recipients are subscribed to international policies that aim to ensure that personal data is processed, handled and stored securely.
HOW LONG WE KEEP YOUR PERSONAL INFORMATION FOR
If we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws.
We do not retain personal information in an identifiable format for longer than is necessary to perform our business obligations.
We may need your personal information to establish, bring or defend legal claims, in which case we will retain your personal information for 7 years after the last occasion on which we have used your personal information in one of the ways specified in ‘How we use your personal information’.
The only exceptions to this are where:
- the law requires us to hold your personal information for a longer period, or delete it sooner.
- you exercise your right to have the information erased and we do not need to hold it in connection with any of the reasons permitted in this section, or because we are required under the law as specified in ‘Erasing your personal information or restricting its processing’.
- and in limited cases, the law permits us to keep your personal information indefinitely provided we put the required protections in place.
You have a number of rights in relation to your personal information under data protection law. We may ask you for information to confirm your identity and to help us to search for your personal information. We will respond to you within 30 days from the date we receive your information request.
Accessing your personal information
You have the right to ask for a copy of the information that we hold about you by emailing or writing to us at the address at the end of this policy. There may be occasions where we are unable to provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.
Correcting and updating your personal information
The accuracy of your information is important to us, if any of your information changes such as your name, address/email address, or any of the information we hold about you is inaccurate or out of date, please let us know by contacting us, our contact details can be found at the bottom of this policy.
Withdrawing your consent
Where we rely on your consent as the legal basis for processing your personal information, as set out in ‘How we use your personal information’, you may withdraw your consent at any time by contacting us using the details at the end of this policy. If you would like to withdraw your consent to receiving any direct marketing to which you previously opted-in, you can also do so using the unsubscribe links provided on all of our electronic communications. Any communication sent prior to your removal request remain lawful.
Objecting to our use of your personal information and automated decisions made about you.
Where we rely on our business interests as the legal basis for processing your personal information, as described in ‘How we use your personal information’, you may object to us using your personal information for these purposes by emailing or writing to us at the address provided at the end of this policy. Except for the obligatory purposes for which we can continue to process your personal information, we will temporarily stop processing your personal information in line with your request. If we reach an agreement that your request is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise we will provide you with our justification as to why we need to continue using your data.
You may object to us using your personal information for direct marketing purposes and we will automatically comply with your request. If you would like to do so either contact us using the information provided at the end of this policy or use the unsubscribe links provided on all of our electronic communications.
Erasing/restricting the processing of your personal information
In certain circumstances, you may ask for your personal information to be removed from our systems by emailing or writing to us at the address at the end of this policy. Unless there is a reason that the law allows us to use your personal information for longer, we will process your request within 30 days of the receipt of your request.
You may also ask us to restrict processing your personal information in the following situations:
- where you believe it is unlawful for us to do so, or
- you have objected to its use and an investigation is pending or we are retaining your information in relation to any legal proceedings.
In these situations, we may only process your personal information during the restrictive period if we have your consent or we are legally required to do so, for example to protect the rights of another individual or company or in relation to any legal proceedings.
Transferring your personal information to you
Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with your contract, as described in ‘How we use your personal information’, you may ask us to provide you with a digital copy of the personal information we hold about you. We will provide this to you electronically in a secured data file, such as a compressed CSV or an XLSX file.
You can ask us to send your personal information directly to another service provider, and we will do so if this is technically and legally possible. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.
Complaining to the UK data protection regulator
You have the right to complain to the Information Commissioners Office (ICO) if you are concerned about the way we have processed your personal information. Please visit the ICO’s website for further details.
ONLINE SECURITY / WEBSITE COOKIES / LINKS / SOCIAL LINKS / ONLINE TRANSACTIONS
Security measures we put in place to protect your personal information
English Electric use technical and organisational security measures to protect the personal information supplied by you and managed by us against manipulation, loss, destruction, and access by third parties. Our security measures are continually reviewed to ensure your personal information is secure.
English Electric uses SSL (Secure Sockets Layer) which is the standard security technology for establishing an encrypted link between a web server and a browser. This link ensures that all data passed between the web server and browsers remain private and integral.
Unfortunately, the transmission of information via the internet is not completely secure however we will do our best to protect your personal information, we cannot guarantee the security of your information whilst in transit to our website and any transmission is at your own risk.
Where we have issued, or where you have chosen a password which enables you to access any of our websites or services, you are responsible for keeping this password secure. To prevent unauthorised access to your personal information we ask you not to share your password with anyone.
‘Cookies’ are small files which are sent back and forth with website pages which can be used to identify that you have previously visited a site, or to store small bits of information locally with you.
Where can I find more information about cookies, and how do I turn cookies off or delete cookies?
Find out more about cookies including how to disable/enable and delete them at the following website www.aboutcookies.org.
You can opt-out of receiving cookies from a range of ad servers (including, among others, Doubleclick, Videology, AudienceScience, Flashtalking and Microsoft) by visiting www.youronlinechoices.com and following the instructions provided.
Generally, you can’t delete Flash cookies (also known as local shared objects) with browser controls, but Adobe’s website at www.adobe.com provides information on how to delete or disable Flash cookies. Click here for details. Please note that if you disable Flash cookies, you will not be able to play content on the ITV Player.
If you want to delete cookies from the browser on your mobile phone, you will need to refer to your handset manual.
In addition, if you linked to our website from a third-party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third-party website and recommend that you check the policy of that third-party website.
We use links to social networks such as Facebook, Google+, Instagram, Twitter and others.
After their activation, a direct link to the respective social network is established. The contents of the link are then transmitted from the social network directly to your browser and incorporated in the website.
After activation of a social link the social network can retrieve data, independently of whether you interact with the link or not. If you are logged on to a social network, the network can assign your visit to our website to your user account. A social network cannot assign a visit to websites operated by our other group companies unless and until you activate the respective link there as well.
If you are a member of a social network and do not wish it to combine data retrieved from your visit to our websites with your membership data, you must log out from the social network concerned before activating any links.
We have no influence over the data that is collected by the social networks through their respective links. The data use policies of the social networks provide information on the purpose and extent of the data that they collect, how this data is processed and used, the rights available to you and the settings that you can use to protect your privacy.
We do not handle your card transactions, nor do we store any card details whatsoever. All payments made via our online shop are handled by Shopify/Sage Pay – globally trusted secure online payment gateways. For more information please refer to their respective policies. (http://www.sagepay.com/ | https://pay.shopify.com/en/tos-privacy-policy#privacy-policy)
We collect your personal information to send you marketing information directly from us by email/SMS including:
- if you register an account with us online, make a purchase online or instore; or
- if you book a test ride, make an enquiry or request we contact you
We will only do so if you have consented to receiving such marketing information directly from us.
We may contact you with targeted online advertising via third-party websites and social media platforms by using your personal information to make marketing more relevant to you unless you object.
If you opt-in to receiving marketing from our recommended third parties, you will receive marketing from the third parties listed in the table below via your preferred communication methods indicated by you:
From time to time, we may ask you to update your information by asking you to confirm that you wish to continue receiving marketing communications from us.
We will use ‘opt in’ data to distribute occasional SMS messages throughout the year. If for any reason you desire NOT to continue to receive our messages, you can easily unsubscribe by using the short code included at the end of the message or request to have your number removed from our active list of SMS recipients by contacting us using the information provided at the end of this policy.
If you have any questions, please feel free to call or email us for assistance.
Zero Motorcycles, Vmoto ltd (Supersoco), Sinnis (NIU), OSET, Kuberg, Sur-ron, Diginow
Our Vehicle Finance Providers
Our Retail Finance Providers
You have the right to opt-out of our marketing communications at any time. Please see the section entitled ‘Withdrawing Consent’ for further details on how you can do this.
CHANGES TO THIS POLICY
We may review this policy from time to time and any changes will be made by posting an updated version on our website. Any changes will take effect 7 days after the date we post the modified terms on our website. We recommend you regularly check for changes and review this policy when you visit our website. If you do not agree with any aspect of the updated policy, you must promptly notify us and request that your information is removed from our database.
If you have any questions or concerns about how we collect or use your personal information or wish to contact us to amend/update or delete your marketing preferences, please contact our Data Protection office using the details below.
Data Protection Contact:
English Electric Motor Co.
Data Protection Office
Unit 1 , Hall Farm, Church Road, Redgrave, Diss, Norfolk, IP22 1RJ
Telephone: 01379 898987
Old Empire Trading Co Ltd. T/A English Electric Motor Co.
Unit 1, Hall Farm, Church Road, Redgrave, Diss, Norfolk, IP22 1RJ.
Main Switchboard: 01379 898987
Company number: 09826273