INEOS AUTOMOTIVE PRIVACY NOTICE

INEOS Automotive Limited (“INEOS Automotive”) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy notice

This privacy notice aims to give you information on how INEOS Automotive collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, take a survey, purchase a product or service, indicate an interest in purchasing a product or service or take part in a competition

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

INEOS Automotive

INEOS Automotive is part of the INEOS group of companies (the “INEOS Group”), details of which can be found here https://www.ineos.com/

INEOS Automotive has appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

Full name of legal entity: INEOS Automotive Limited, an English limited liability company (Company number 11201576)

Name or title of DPO: Head of Legal

Email address: dataprotection@ineosgrenadier.com

Postal address: Anchor House, 15 – 19 Britten Street, London, SW3 3TX, United Kingdom

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version of the privacy notice was last updated on 7 December 2020.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous or anonymised data).

INEOS Automotive may at various times collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third-party service providers and your communication preferences.
• Social Network Data includes information that you share publicly or is part of your profile on a third party social network (including but not limited to user ID, location, profile picture, list of friends, photos, videos, personal stories or similar media).
• Market Research Data includes questions in our voluntary survey about your automotive purchase and usage behaviour, vehicle preferences, etc.

When we mention “INEOS Automotive”, in this privacy notice, we are referring to the relevant company in the INEOS Group responsible for processing your data. INEOS Automotive is one of the controllers and is jointly responsible for this website.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Throughout this privacy notice, references to “we”, “us” or “our” are to INEOS Automotive as controller of your personal data as set out above.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED

We use different methods to collect data from and about you including through:

• Direct interactions. From time to time, you may give us your Identity, Contact, Social Network and Financial Data by filling in forms or by corresponding with us by post, telephone, email, social media or otherwise. This includes personal data you provide when you:
  • apply for or purchase our products or services;
  • create an account on our website;
  • subscribe to our services or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey;
  • comment on our social media pages;
  • create content and share such content with us via third-party social networks;
  • provide information in connection with our careers web pages; and/or
  • give us some feedback or otherwise contact us.
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
  • Technical Data from the following parties:
    • analytics providers such as Google based outside the EU (using, in particular, Google Analytics, Google Tag Manager and Hotjar); and
    • search information providers based inside or outside the EU.
    • Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside or outside the EU.
    • Identity and Contact Data from data brokers or aggregators based inside or outside the EU.
    • Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
    • Social Network Data from third party social network sites or applications.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

If we rely on consent as a legal basis for processing your personal data (for example, in relation to sending third party direct marketing communications to you via email or text message), you have the right to withdraw consent to marketing at any time by contacting us at dataprotection@ineosgrenadier.com.

Purposes for which we will use your personal data

We have set out in a table format (accessible via the link below) a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at dataprotection@ineosgrenadier.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Click here to view the table pdf.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage, Social Network and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this process “marketing” in this privacy notice).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time at dataprotection@ineosgrenadier.com.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

Change of purpose

We will only use your personal data for the purposes for which we originally collected it. If we need to use your data for another purpose, we may do so as long as it is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at dataprotection@ineosgrenadier.com.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• 1. Internal Third Parties as set out in the Glossary.
• 2. External Third Parties as set out in the Glossary.
• 3. Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

We may share your personal data within the INEOS Group. This will involve transferring your data outside the European Economic Area (the “EEA”). It should also be noted that INEOS Automotive itself is based in the UK.

In addition, if you seek to obtain our products or use our services when you are located outside the EEA, your information may be transferred outside the EEA in order to provide you with those products or services.

Many of our external third-party service providers are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it, including by ensuring that there is a legal agreement in place which covers such transfer of personal data (which may include using specific contracts approved by the European Commission which give personal data the same protection it has in the EEA).

Please contact dataprotection@ineosgrenadier.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. DATA RETENTION

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data – please contact us for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case, as such information would cease to be personal data, we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us at dataprotection@ineosgrenadier.com.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at dataprotection@ineosgrenadier.com.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

Other companies in the INEOS Group acting as joint controllers or processors and who are based the EU and/or UK. This may include INEOS Group companies whose products we feel may be of interest to you.

External Third Parties

• Service providers acting as processors who provide IT and system administration services, process credit cards and payments, shipping and deliveries, host, manage and service our websites and/or data, distribute emails, research and analysis, manage brand and product promotions as well as administering certain services and features. When using third party service providers we enter into agreements that require them to implement appropriate technical and organisational measures to protect your personal data.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, insurers and other organisations who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
• Authorised dealers in our network who may use your personal data in connection with one of the lawful bases set out above or in connection with products and/or services which complement our own range of products and services, for example finance or insurance products.
• Any other third party where you have provided your consent to such processing.

YOUR LEGAL RIGHTS

You have the right to:

Request access

to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.