MOTRIO UK PRIVACY NOTICE
Motrio UK trades under Renault UK Limited (hereinafter “we”, “us”, “our”, “Motrio UK”) which is a group company of Renault SAS (altogether “Renault Group”).
The purpose of this privacy notice is to provide you with detailed information about the processing of your personal data by Renault SAS, Motrio UK and the Motrio UK network of Motrio Service Centres (hereinafter “Motrio Service Repairer(s)”).
Renault Group continues to ensure compliance with regulations on the protection of personal data and puts it at the heart of its ethics, as described in its Group Personal Data Protection Policy available at https://www.renaultgroup.com/en/our-commitments/the-groupe-renault-and-your-personal-data/.
Indeed, Renault Group believes that personal data protection is essential for building a relationship of trust with its customers. As such, it intends to ensure the greatest transparency in the personal data processing that it carries out on the personal data that its customers provide or that it collects through the various contacts its customers may have with it.
1. WHO PROCESSES YOUR PERSONAL DATA?
Renault SAS and Motrio UK may collect and process personal data about you. Their responsibility for processing your personal data varies depending on the role they play in the various services or products provided.
Renault SAS and Motrio UK, process your personal data as independent data controllers within the meaning of applicable personal data protection regulations including the General Data Protection Regulation (EU) 2016/679, the UK General Data Protection Regulation (as defined in The Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019), the Data Protection Act 2018.
For further information about how the Motrio Service Repairers processes your personal data, please refer to the relevant Motrio Service Repairer privacy notice by contacting them directly.
For further information about how Renault UK Limited processes your personal data, please visit the Renault UK limited privacy notice available at: https://www.renault.co.uk/data-privacy.html.
For further information about how Renault SAS processes your personal data, please visit the Renault SAS privacy notice available at: https://www.renault.fr/donnees-personnelles.html.
Renault UK Limited is located at the Rivers Office Park, Denham Way, Maple Cross, Rickmansworth WD3 9YS. The contact details for its Data Protection Officer are as follows: dataprivacy@renault.co.uk.
The contact details for Renault SAS’ Data Protection Officer are as follows: Renault SAS, Direction juridique – Délégué à la protection des données, 13/15 quai le Gallo 92100 Boulogne-Billancourt.
The list of Motrio Service Repairers and their contact details are available on the Motrio UK website using the “Find a Motrio Service Centre” tool.
2. WHAT PERSONAL DATA DO WE PROCESS?
"personal data" means any information that can be used to identify you either directly (such as your name) or indirectly (such as a unique customer number).
Generally speaking, we undertake to collect only the personal data necessary for each of the purposes for which we process your personal data.
The personal data we collect depends on our interaction with you and may include information about:
· Your identity and contact details (surname, first name, postal address, email address, telephone, city etc.),
· Data relating to our commercial relationship, in particular our interactions and contracts (order history, after-sales operations, service agreements),
· Your vehicle identification data (brand, model, registration number, licence plate),Data related to the use of the vehicle (mileage etc),
· Data concerning the use of our websites, as well as our communications (number of visits, page visited, messages opened, etc.).
As such, the data required to respond to your request or meet the needs of a contract or legal obligation is pointed out in the collection forms. If you do not wish to provide the mandatory data, we may not be able to process your request or provide you with the relevant services.
We encourage you to keep us regularly informed in writing of any changes to your personal data. The products and services that we offer are primarily for adults. Therefore, we do not carry out any specific processing on minors.
3. WHAT IS YOUR PERSONAL DATA USED FOR?
We will provide you with explanations relating to the context of collection of your personal data, the purposes for which we process them and the duration for which we retained them.
3.1 CONTEXT OF COLLECTION
We collect your personal data in particular when:
· You contact us by means of an online form, email, through a Motrio Service Repairer visit or any other means,
· You participate in a contest or an event, or subscribe to one of our newsletters,
· You respond to one of our studies or satisfaction surveys,
We will use your personal data for the purposes for which we collected it, unless we reasonably consider that we need your personal data for another reason and such reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify and explain our legal basis which allows us to do so.
3.2. OBJECTIVES OF PERSONAL DATA PROCESSING
A – Manage our initial interactions
Objective: Monitoring of visits to our websites, and management of their operation and security.
Legal Basis: This processing is based on your consent to the cookies deposited/read in your terminal (see our cookies policy[GJ(1] ), and on our legitimate interest (to provide you with secure sites and applications).
Objective: Information requests, for example customers making queries in respect of costing of parts and/or information in connection with the coverage of Motrio Service Repairer locations or information relating to specific services or vehicles.
Legal Basis: This processing is justified by the pre-contractual relationship resulting from your request.
Objective: Appointment scheduling and management including bookings for parts and/or servicing. You will be directed to the Motrio Service Repairer who will manage the booking.
Legal Basis: This processing is justified by the pre-contractual relationship resulting from your request.
Objective: Requests relating to you joining the UK Motrio Service Repairer network.
Legal Basis: This processing is justified by the pre-contractual relationship resulting from your request.
B - Manage our commercial relationship
Objective: Managing your complaints, including where you make a complaint to a Motrio Service Repairer and they cannot resolve the complaint themselves.
Legal basis: This processing is based on our legitimate interest (prevention of legal actions)
Objective: Respond to any requests to exercise your rights in relation to your personal data (see the section on “what are your rights”).
Legal basis: This processing is based on our legal obligations and may require verification of your identity where we cannot reasonably identify you based on the information you have provided.
Objective: The management of our satisfaction surveys, the management and response to your opinions, in order to improve customer satisfaction and our products and services.
Legal basis: This processing is based on our legitimate interest (to improve our products and services).
C - Manage our marketing operations
Objective: Sending advertising campaigns (digital or not), newsletters.
Legal basis: This processing is based on your consent or our legitimate interest (providing you with relevant content).
3.3 THE LENGTH OF TIME FOR WHICH WE KEEP YOUR DATA
In accordance with the regulations, we are committed to keeping your personal data only for the time necessary to achieve the objective pursued, to meet your needs, or to meet our legal obligations.
In determining this time, we take into account, in particular, the following:
· The length of your contract,
· The time required to process your request or complaint,
· Your interest in our brand
· The need to keep a record of your interactions with us, to effectively manage our business relationship. This period will vary depending, in particular, on a service such as repair, or whether you have only interacted with us without entering into contracts with us, and,
· Our legal or regulatory obligations (this is particularly the case for issues arising out of product / service warranties).
When we no longer need to use your personal data, it is deleted from our systems and records or made anonymous so that we can no longer identify you. However, it may be necessary to archive some of your personal data in order to be able to respond to any legal proceedings, throughout the statute of limitations provided for in the applicable legislation.
4. WHO HAS ACCESS TO YOUR PERSONAL DATA?
Within Renault Group (including Renault UK Limited and Renault SAS, and other Renault Group companies), we ensure that only people duly authorised with regard to their functions and their tasks to process your personal data are authorised to do so.
We may share your personal data with such Renault Group companies under our or under such companies’ legitimate interest (ensuring always that your interests or fundamental rights and freedoms are not overridden) or in order to fulfil our contractual obligations. Your consent will be obtained where consent is required by the regulations. These entities may act as data controller, in accordance with their personal data protection policy, or as processor, to perform tasks according to the instructions we give them. Where we intend to share personal data with other Renault entities other than those listed above, we will inform you prior to the sharing of your personal data and give you an opportunity to object.
In order to process all or part of your personal data, we call upon trusted third-party providers, acting as processors, in accordance with our instructions and solely on our behalf, to fulfil the following functions:
· The hosting, operation or maintenance of our databases, websites,
· The provision of authentication services,
· A purchaser or potential purchaser of our business or otherwise in the event of a merger, re-organisation or similar event,
· Customer relationship management (supply of communication tools, etc.),
· The provision of services relating to our marketing, in particular the sending of commercial offers where we intend to send electronic marketing communications (your consent will be collected where required by applicable regulations),
· Third party courier companies who delivers your orders (for example, DHL),
· The organization of contests, events,
· Performance of studies and surveys,
· Any associated or connected motor manufacturer from whom we purchase or hire goods (and their group companies)
· The police, fraud prevention and identity authentication entities, other law enforcement agencies, government and tax authorities in the United Kingdom or abroad in order to detect, investigate and prevent crime (please note that fraud prevention agencies may also enable law enforcement agencies to access and use your information to detect, investigate and prevent crime);
· The courts in the United Kingdom or abroad as necessary to comply with a legal requirement, for the administration of justice, to protect vital interests and to protect the security or integrity of our business operations.
For all of this data sharing, we make sure to only work with trusted companies and to secure these relationships (contracts, audits, guarantees and security tests, etc.).
Finally, we may be required to communicate your personal data to third parties in order to comply with a legal obligation or an administrative or legal decision.
5. WHAT ARE YOUR RIGHTS?
5.1- Your rights
You have several rights under personal data protection regulations:
A right to object to the processing of your personal data, provided you have grounds connected with your particular situation, and the right to request the limitation of your personal data processing, in some cases as provided for in regulations.
A right to object to any commercial solicitation: you can ask at any time not to receive our communications related to our offers, news and events. This right may, in particular, be exercised via the unsubscribe link in each marketing email. You can also object to profiling.
A right to withdraw your consent at any time, for the purposes for which we obtained your consent. The withdrawal of your consent shall not affect our lawful basis for processing before your consent was withdrawn.
A right to information: you have the right to obtain clear, transparent and understandable information about how we use your personal data and about your rights. This policy is an example of this.
A right of access to your personal data: you have the right to obtain clear information concerning the processing of your personal data (including the data that is used, for what purposes, etc.) and a copy thereof.
A right of rectification: you have the right to correct your data if it is inaccurate or incomplete, despite our efforts to keep it up to date, enabling us to comply with our obligation to have up-to-date data about you.
A right to the portability of your data, i.e., under certain conditions, the right to receive the personal data you have provided to us, in a structured, commonly used computerised format, and for it to be transmitted to a third party if technically possible.
A right to erasure (or right to be forgotten): you have the right to have your data erased or deleted. This right may be limited in light of our contractual or legal obligations (contract in progress) (prevention of legal action in particular).
A right to define directives, either general or specific regarding certain types of processing, with respect to the retention, deletion and communication of your personal data in the event of your death. You may change or delete these guidelines at any time. You may share these special guidelines with us by writing to the address below.
Finally, you have the right to lodge a complaint with the Information Commissioner’s Office (“ICO”) about the processing of your personal data. We encourage you to contact us prior to any claim, so that we may attempt to resolve your problem together.
5.2- How to exercise them?
You can update your contact details and where applicable manage your consents to commercial prospecting by contacting Motrio UK using the details mentioned in Section one (1) above.
· To exercise any of your rights regarding the processing of personal data by Renault Group including Renault SAS, Motrio UK, you can unsubscribe from receiving our mailings at any time in the future by using the link that appears in the footer of every email that we send to you, you can also send us your request at any time to the addresses mentioned in Section one (1) above.
· To exercise your rights concerning the processing carried out by your Motrio Service Repairer, we invite you to contact them directly.
We may ask you for certain information or documents (identity document, registration card) only when we are unable to reasonably identify you.
6.HOW IS YOUR PERSONAL DATA KEPT SECURE?
Your personal data is stored on secure servers. We put in place, and require from our processors and partners, appropriate data security and data protection measures in line with the latest technologies. When personal data processing involves transferring data, we ensure that this transfer is carried out under appropriate conditions that ensure an adequate level of protection, security and confidentiality.
Whenever possible, your data is processed in the European Economic Area (EEA) or United Kingdom. However, as some of our service providers or their processors are located in countries outside of the EEA and/or United Kingdom, your personal data may be processed in those countries. Some of these countries may have different personal data regulations from those of the European Union and/or United Kingdom. In such a case, (i) we pay particular attention to ensuring that this transfer is carried out in accordance with the applicable regulations and (ii) we put in place safeguards ensuring an adequate level of protection of your privacy and fundamental rights (in particular by using the European Commission's standard contractual clauses and/or the UK’s International Data Transfer Addendum (as applicable)). Upon simple request sent to the address indicated in the "What are your rights?" section, we can provide you with more information on such transfers (in particular the European Commission’s standard contractual clauses or UK International Data Transfer Addendum).
7. MODIFICATION OF INFORMATION
We may change this information from time to time. We will inform you and/or seek your consent whenever necessary or required. We therefore recommend that you consult this privacy notice each time you visit our website in order to review the latest version.
Last modified: December 21, 2022