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©Copyright Graham Hill 2018

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This publication is intended to provide accurate information in regard to the subject-matter covered. Readers entering into transactions on the basis of such information should seek the services of a competent professional advisor, as the publication is made available on the understanding that neither the publisher nor the author is engaged in rendering legal or accounting advice or other professional services.

The publisher, author and editor expressly disclaim all and any liability and responsibility to any person, whether a purchaser or reader of this publication or not, in respect of anything, and of the consequences of anything, done or omitted to be done by any such person in reliance, whether wholly or partially, upon the whole or any part of the contents of this publication.

Downloading any publication on this website constitutes acceptance of these terms and conditions. 

Published by:

GHAF Publishing

PRIVACY POLICY

1. Background

This privacy notice lets you know what happens to any personal data that you give to us, or any that we may collect from or about you. It applies to all products and services, and instances where we collect your personal data.

This privacy notice applies to personal information processed by or on behalf of Graham Hill Training

The Graham Hill Training privacy policy

Use the links below to find out more about how we use your personal information:

  • Who are we and how do you contact us and our Data Protection Officer?
  • What kinds of personal information about you do we process?
  • What is the source of your personal information?
  • What are the legal grounds for our processing of your personal information (including when we share it with others)?
  • What should you do if your personal information changes?
  • For how long is your personal information retained by us?
  • What are your rights under data protection laws?
  • How can you opt out of marketing communications?

Changes to this privacy notice

We may change this privacy notice from time to time by updating this page in order to reflect changes in the law and/or our privacy practices. We encourage you to check this privacy notice for changes whenever you visit our website – https://grahamhilltraining.com/.

Graham Hill Training and our Data Protection Officer

We’re Graham Hill T/A, 6 Kelsey Court, Burgess Hill, RH15 0TU. Graham Hill is the Data Controller of your personal data. The Graham Hill group of companies provide your product or service as named at the start of these terms and conditions.

We have a dedicated data protection officer who can be contacted via the Contact Us page.


2. What kinds of personal information about you do we process?

Personal information that we’ll process in connection with all of our products and services provided via this website.

  • Personal and Contact Details, such as full name, contact details and contact details
  • Records of your contact with us such as via the phone, email or website contact form.
  • Products and services you hold with us.
  • The usage of our products and services, any downloads, both free and paid for, consultancy services and other chargeable items.
  • Marketing to you and analysing data, including history of those communications, whether you open them or click on links, and information about products or services we think you may be interested in, and analysing data to help target offers to you that we think are of interest or relevance to you. Offers may include our car finance deals, books, reports, training, videos and consultancy services.
  • Information about your use of products or services held with our business partners, such as car finance and associated products.
  • Fraud and money laundering information, including details of any attempts at committing fraud or money laundering through the abuse of information provided via this website.
  • Details about all of your existing and previous vehicle finance, if relevant to the provision of advice or guidance.
  • Insights about you, gained from analysis or profiling of customers.

3. What is the source of your personal information?

We’ll collect personal information from the following general sources:

  • From you directly
  • Business partners (for example those providing goods and services as introduced by us)

4. What do we use your personal data for?

We use your personal data, including any of the personal data listed in section 1 above, for the following purposes:

  • Updating and maintaining information and services supplied to you either for free or chargeable
  • Managing the product or service you have with us
  • Updating your records
  • Managing any aspect of the product or service
  • To perform and/or test the performance of, our products, services and internal processes
  • To improve the operation of our business and that of our business partners
  • To follow guidance and best practice under the change to rules of governmental and regulatory bodies
  • For management and auditing of our business operations including accounting
  • To monitor and to keep records of our communications with you and our staff (see below)
  • To administer our good governance requirements and those of other members of the Graham Hill Group in meeting compliance obligations
  • For market research and analysis and developing statistics
  • For direct marketing communications and related profiling to help us to offer you relevant products and service, including deciding whether or not to offer you certain products and service. We’ll send marketing to you by SMS, email, phone, post, social media and digital channels (for example, using Facebook and other social media sites.
  • To develop new products and services and to review and improve current products and services
  • To comply with legal and regulatory obligations, requirements and guidance
  • To provide insight and analysis of our customers both for ourselves and for the benefit of business partners either as part of providing products or services, helping us improve products or services, or to assess or improve the operating of our businesses
  • To facilitate the sale of one or more parts of our business

5. What are the legal grounds for our processing of your personal information (including when we share it with others)?

We rely on the following legal bases to use your personal data:

    1. Where it is needed to provide you with our products or services, such as:

a) Assessing an application for a product or service you hold with us, including consider whether or not to offer you the product and the conditions to attach
b) Managing products and services you hold with us, or an application for one
c) Updating your records.
d) Sharing your personal information with business partners and services providers when you apply for a product to help manage your product
e) All stages and activities relevant to managing the product or service including enquiry, application, administration and management.

    1. Where it is in our legitimate interests to do so, such as:

a) Managing your products and services and updating your records.
b) To perform and/or test the performance of, our products, services and internal processes
c) To follow guidance and recommended best practice of government and regulatory bodies
d) For management and audit of our business operations including accounting
e) To carry out monitoring and to keep records of our communications with you and our staff (see below)
f) For market research and analysis and developing statistics
g) For direct marketing communications and related profiling to help us to offer you relevant products and services, including deciding whether or not to offer you certain products and service. We will send marketing to you by SMS, email, phone, post and social media and digital channels (for example, using Facebook and other social media).
h) Subject to the appropriate controls, to provide insight and analysis of our customers to business partners either as part of providing products or services, helping us improve products or services, or to assess or to improve the operating of our businesses
i) For some of our profiling and other automated decision making
j) Where we need to share your personal information with people or organisations in order to run our business or comply with any legal and/or regulatory obligations

    1. To comply with our legal obligations
    2. With your consent or explicit consent

6. When do we share your personal information with other organisations?

We may share information with the following third parties for the purposes listed above:

  • Graham Hill Group companies
  • Governmental and regulatory bodies such as the Financial Conduct Authority, the Financial Ombudsman, the Information Commissioner’s Office
  • Market research organisations who help us to develop and improve our products and services

7. How and when can you withdraw your consent?

Where we’re relying upon your consent to process personal data, you can withdraw this at any time by contacting us using the details below.


8. Is your personal information transferred outside the UK or the EEA?

We’re based in the UK so we will have no need to transfer information outside the UK.


 

9. What should you do if your personal information changes?

You should tell us so that we can update our records using the details in the Contact Us section of our website. We’ll then update your records if we can.


10. Do you have to provide your personal information to us?

We’re unable to provide you with our products or services if you do not provide certain information to us. In cases where providing some personal information is optional, we’ll make this clear.


11. Do we do any monitoring involving processing of your personal information?

In this section monitoring means any: listening to, recording of, viewing of, intercepting of, or taking and keeping records (as the case may be) of calls, email, text messages, social media messages, in person (face to face) meetings and other communications.

We may monitor where permitted by law and we’ll do this where the law requires it, or to comply with regulatory rules, to prevent or detect crime, in the interests of protecting the security of our communications systems and procedures and for quality control and staff training purposes. This information may be shared for the purposes described above.


 

12. For how long is your personal information retained by us?

Unless we explain otherwise to you, we’ll hold your personal information based on the following criteria:

  • For as long as we have reasonable business needs, such as managing our relationship with you and managing our operations
  • For as long as we provide goods and/or services to you and then for as long as someone could bring a claim against us; and/or
  • Retention periods in line with legal and regulatory requirements or guidance.

13. What are your rights under data protection laws?

Here is a list of the rights that all individuals have under data protection laws. They don’t apply in all circumstances. If you wish to use any of them, we’ll explain at that time if they are engaged or not. The right of data portability is only relevant from May 2018.

  • The right to be informed about the processing of your personal information
  • The right to have your personal information corrected if it is inaccurate and to haveincomplete personal information completed
  • The right to object to processing of your personal information
  • The right to restrict processing of your personal information
  • The right to have your personal information erased (the “right to be forgotten”)
  • The right to request access to your personal information and to obtain information about how we process it
  • The right to move, copy or transfer your personal information (“data portability”)

You have the right to complain to the Information Commissioner’s Office which enforces data protection laws: https://ico.org.uk/. You can contact us using the details below.


14. Your right to object

You have the right to object to certain purposes for processing, in particular to data processed for direct marketing purposes and to data processed for certain reasons based on our legitimate interests. You can contact us by going to the contact us section of our website to exercise these rights.


15. What are your marketing preferences and what do they mean?

We may use your home address, phone numbers, email address and social media or digital channels (for example, Facebook, Google and message facilities in other platforms) to contact you according to your marketing preferences.

You can opt out of any email or text marketing by following the unsubscribe links. If you receive a marketing call from us, you can ask the person who called you to opt you out. You can also write to us at Graham Hill, 6 Kelsey Court, Burgess Hill, RH15 0TU marking it for the attention of the DPO. Or send us an email on our Contact Us page


Contact Us

If you have any questions about this privacy notice, or if you wish to exercise your rights or contact the DPO, you can contact us by going to the Contact Us section of our website, marking it for the attention of the DPO.