Pulman Group Privacy Policy

1. Introduction

Pulman Group respects your privacy and is committed to protecting your personal information.

This Privacy Policy explains how we collect, use, store, share and protect personal information when you interact with us. This includes when you use our websites, submit an enquiry, visit one of our dealerships, contact our customer service teams, buy, lease, finance, rent, service or repair a vehicle, make a complaint, respond to marketing, or otherwise deal with a Pulman Group business.

This policy applies to our vehicle sales, fleet, leasing, contract hire, finance and insurance, aftersales, service, repair, warranty, parts, rental, customer support, marketing, website, telephone and CRM activities.

We may update this policy from time to time. The latest version will be available on our website.


2. Who we are

Pulman Group is the trading group of Mike Pulman Holdings Limited. References in this policy to “Pulman”, “Pulman Group”, “we”, “us” or “our” mean the relevant Pulman company, dealership, authorised repairer, trading style or business that you interact with.

The Pulman businesses and trading styles covered by this policy include:

·         Pulman Volkswagen;

·         Volkswagen Van Centre Durham;

·         Pulman Fleet;

·         National Vehicle Solutions;

·         Pulman SEAT;

·         CUPRA Durham;

·         CUPRA Sunderland;

·         Pulman Škoda Durham;

·         Pulman Škoda Cramlington;

·         any other Pulman dealership, authorised repairer, fleet, leasing, contract hire, website, customer service or aftersales channel that links to this policy.

The relevant operating company will depend on which Pulman business you deal with.

Pulman Volkswagen, Volkswagen Van Centre Durham, Pulman Fleet and National Vehicle Solutions are trading styles of Mike Pulman Limited.

Pulman SEAT, CUPRA Durham and CUPRA Sunderland are trading styles of Pulman SEAT Limited.

Pulman Škoda Durham and Pulman Škoda Cramlington are trading styles of Pulman Škoda Limited.

Pulman Volkswagen, Volkswagen Van Centre Durham, Pulman Fleet and National Vehicle Solutions are trading styles of Mike Pulman Limited, which is authorised and regulated by the Financial Conduct Authority for credit broking and insurance distribution activities under reference number 308745. We are a credit broker, not a lender.

Pulman SEAT Limited and Pulman Škoda Limited are Appointed Representatives of Mike Pulman Limited, which is authorised and regulated by the Financial Conduct Authority for credit broking and insurance distribution activities under reference number 308745. We are a credit broker, not a lender.

Where Pulman Group companies share systems, staff, customer service, compliance, IT, marketing, reporting or management functions, your personal information may be processed within the Pulman Group for the purposes described in this policy.


3. How to contact us about data protection

If you have any questions about this policy, how we use your personal information, or if you wish to exercise your data protection rights, please contact:

Data Protection Team
Pulman Group
Abbey Road
Framwellgate Moor
Durham
DH1 5HA

Email: [email protected]
Telephone: 0800 0720 228

If these details change, the latest contact details will be available on our website.


4. What personal information we collect

The personal information we collect depends on how you interact with us. We may collect and use the following categories of information:

Identity and contact details

This may include your name, title, address, email address, telephone number, date of birth, driving licence details, proof of identity and proof of address where required.

Business and fleet information

Where you interact with us as a business, fleet, leasing or company vehicle customer, we may collect your business name, trading name, company number, VAT number, job title, business address, business email address, business telephone number, fleet size, replacement cycle, vehicle requirements and other relevant business information.

Vehicle information

This may include vehicle registration number, VIN, make, model, specification, mileage, ownership history, service history, MOT information, warranty information, repair history, diagnostic data, manufacturer records, recall information, valuation data and vehicle usage information you provide to us.

Enquiry and CRM information

This may include the details of your enquiry, vehicle interest, finance or leasing requirements, part-exchange details, test drive requests, service booking requests, quote requests, website form submissions, notes of conversations, customer preferences, contact preferences and enquiry outcomes.

Transaction and contract information

This may include vehicle orders, sales invoices, service invoices, repair orders, finance proposals, insurance product information, warranty products, payment information, deposits, refunds, delivery or collection arrangements and contract documentation.

Finance and insurance information

Where you ask us to assist with finance, leasing, insurance or related products, we may collect information required to discuss your needs and submit proposals. This may include employment details, affordability information, financial information, credit application details, bank details, income and expenditure information, product suitability information, documentation required by lenders or insurers, and records of discussions.

Communications information

This may include emails, letters, web forms, live chat, SMS messages, social media messages, telephone call records, call recordings, voicemail, call metadata and notes made by our staff.

Website, device and technical information

When you use our websites, we may collect information such as IP address, device type, browser type, pages visited, time spent on pages, referral source, website journey, cookie identifiers, analytics information and marketing attribution information.

Marketing information

This may include your marketing preferences, communication preferences, consent records, opt-out records, campaign activity, email engagement, events attended and areas of interest.

CCTV and site security information

If you visit one of our premises, CCTV may capture your image, vehicle or registration number. We may also keep visitor, incident or site security records where necessary.

Customer feedback and complaints

This may include survey responses, reviews, complaints, investigation records, correspondence, call recordings and evidence provided by you or third parties.

Vulnerability and additional support information

Where you tell us about a vulnerability, disability, health condition, financial difficulty, bereavement, communication need or other circumstance that may affect how we support you, we may record relevant information so that we can provide appropriate support.

We will only record vulnerability or additional support information where it is necessary and proportionate.


5. Where we collect information from

We may collect personal information directly from you when you:

·         use one of our websites;

·         submit an enquiry;

·         contact us by phone, email, web form, live chat, SMS, post or social media;

·         visit a showroom, workshop, office or event;

·         request a quote, valuation, test drive, finance proposal, leasing quote, insurance product, service booking, MOT, repair, warranty claim or callback;

·         purchase, lease, finance, insure, rent, service or repair a vehicle;

·         enter into a contract with us;

·         make a complaint;

·         exercise your data protection rights;

·         respond to marketing or customer surveys.

We may also receive information from third parties, including:

·         vehicle manufacturers and importers;

·         finance providers, lenders, brokers and leasing companies;

·         insurers, warranty providers and roadside assistance providers;

·         credit reference agencies and fraud prevention agencies;

·         vehicle valuation, vehicle history and data providers;

·         website, advertising, lead generation and vehicle listing platforms;

·         CRM, dealer management, telephone, marketing and technology providers;

·         DVLA, DVSA, Companies House and other lawful public sources;

·         your employer, fleet manager, company representative or authorised contact;

·         professional advisers, regulators, ombudsman services and public authorities.


6. Our lawful bases for using personal information

We only use personal information where we have a lawful basis under data protection law. Depending on the circumstances, we may rely on one or more of the following lawful bases.

Performance of a contract

We use personal information where it is necessary to enter into or perform a contract with you, such as selling, leasing, servicing, repairing or delivering a vehicle.

Steps before entering into a contract

We use personal information where you ask us to provide a quote, discuss a potential purchase, arrange a test drive, provide a leasing proposal, submit a finance proposal or respond to a service request before a contract is entered into.

Legitimate interests

We use personal information where it is necessary for our legitimate business interests and your interests, rights and freedoms do not override those interests.

Our legitimate interests may include:

·         responding to enquiries;

·         managing customer relationships;

·         operating our dealerships, websites, systems and contact centres;

·         recording and monitoring calls;

·         improving customer service;

·         managing complaints and disputes;

·         preventing fraud and protecting our business;

·         carrying out business reporting and analysis;

·         maintaining accurate customer and vehicle records;

·         sending certain business-to-business communications;

·         sending postal marketing where lawful;

·         managing service reminders and customer care;

·         protecting our legal rights.

Where we rely on legitimate interests, we consider the impact on individuals and use personal information in a way that is proportionate and within reasonable expectations.

Legal obligation

We use personal information where necessary to comply with legal obligations, including tax, accounting, consumer protection, vehicle safety, health and safety, financial services, data protection and regulatory obligations.

Consent

We rely on consent where required, for example for certain types of electronic marketing, some cookies and, in some circumstances, processing special category information.

You can withdraw consent at any time where we rely on consent.

Vital interests

In rare cases, we may use personal information where necessary to protect someone’s life or safety.


7. How we use your personal information

We use personal information for the purposes set out below.

To respond to enquiries and requests

We use your information to respond to enquiries, provide quotations, discuss vehicles or services, arrange test drives, book appointments, answer questions, provide fleet or leasing information, and manage follow-up relating to your specific request.

Where you submit an enquiry, we may contact you using the contact details you have provided for the purpose of responding to that enquiry.

Declining marketing does not prevent us from responding to a specific enquiry, order, booking, complaint or service request. However, if you do not provide a contact method, or you tell us that you do not want to be contacted at all, we may be unable to respond to your enquiry.

To sell, lease, finance, rent or supply vehicles and services

We use your information to process orders, prepare documentation, arrange payment, arrange vehicle delivery or collection, administer contracts, manage part-exchanges, provide invoices, process refunds, and support the customer relationship.

To provide aftersales, service, repair, parts and warranty support

We use your information to book and carry out servicing, repairs, MOTs, warranty work, recalls, technical checks, diagnostic work, parts supply, goodwill requests and manufacturer support.

We may use vehicle, mileage, service and repair information to remind you about servicing, MOT, repair, warranty, recall, safety or aftersales requirements.

To assist with finance, leasing and insurance

Where you ask us to assist with finance, leasing, insurance or related products, we use your information to:

·         discuss your requirements;

·         assess product suitability where required;

·         submit proposals to lenders, funders, brokers or insurers;

·         support affordability and eligibility checks;

·         verify identity and prevent fraud;

·         keep records of regulated activity;

·         respond to questions, complaints or disputes;

·         meet FCA and other regulatory obligations.

We are a credit broker, not a lender. Finance providers, funders, insurers and product providers may act as independent controllers and will provide their own privacy information.

To support vulnerable customers and customers needing additional support

Where you tell us about a vulnerability or additional support need, we may use that information to provide appropriate support, make reasonable adjustments, communicate with you in a suitable way, handle your enquiry or complaint fairly, and meet our regulatory obligations, including Consumer Duty obligations.

We will only record information that is relevant, necessary and proportionate. Where the information is special category data, we will identify an appropriate lawful basis and special category condition.

To manage Pulman Fleet and National Vehicle Solutions enquiries

If you submit an enquiry through Pulman Fleet, National Vehicle Solutions or a fleet, leasing or contract hire website, we may use your information to respond to your enquiry, prepare quotations, discuss funding options, liaise with funders or suppliers, manage orders, support renewals and administer customer relationships.

For Pulman Fleet and National Vehicle Solutions activity, we may use Motor Complete as a website and CRM platform to manage enquiries, quotations, customer communications and related CRM records.

To operate our dealer management, CRM and business systems

We use systems to manage customer, vehicle, sales, aftersales, finance, insurance, fleet and enquiry records.

This includes Pinewood as our dealer management system. Pinewood is used to store and manage customer records, vehicle records, enquiries, sales activity, service and repair records, workshop activity, parts, warranty, CRM activity, reporting and related dealership processes.

We may also use other CRM, website, telephone, marketing, reporting, document management, payment, finance and business systems.

Where technology providers process personal information on our behalf, they are required to process it in accordance with applicable data protection law and our contractual requirements.

To record and monitor calls

We use a telephone system provided by Zoom to manage inbound and outbound calls. This may include call logs, call metadata, voicemail, call recordings, and where enabled, call summaries, SMS/MMS or related telephone records.

We may record calls for:

·         training;

·         monitoring;

·         quality assurance;

·         customer service;

·         complaint handling;

·         regulatory compliance;

·         fraud prevention;

·         dispute resolution;

·         confirming details of enquiries, bookings, orders, finance or insurance discussions.

Standard call recordings are usually retained for up to 365 days, unless they are required for a complaint, dispute, finance, insurance, regulatory, legal, safeguarding, vulnerability or investigation purpose. Where a call is relevant to one of those matters, we may retain the recording, transcript or note of the call for longer, normally up to 6 years where necessary.

To manage complaints, disputes and legal claims

We use personal information to investigate and respond to complaints, resolve disputes, liaise with manufacturers, finance providers, insurers, ombudsman services, regulators, legal advisers and other relevant parties, and protect our legal rights.

To meet legal, regulatory and FCA obligations

We may use personal information to meet legal and regulatory obligations relating to:

·         financial services;

·         insurance distribution;

·         Consumer Duty;

·         anti-fraud checks;

·         tax and accounting;

·         consumer protection;

·         product safety;

·         vehicle recalls;

·         warranty administration;

·         data protection;

·         health and safety;

·         complaints and dispute handling.

To send marketing communications

We may use your information to send marketing communications about vehicles, services, offers, events, finance or leasing offers, aftersales offers, warranty products, service plans, accessories and related products or services.

For email, SMS and similar electronic marketing, we will only send marketing where the law allows us to do so. This will usually be where you have given consent or where the soft opt-in applies.

You can opt out of marketing at any time by using the unsubscribe link in our messages or by contacting us.

If you opt out of marketing, we may retain limited information on a suppression list to ensure we respect your preference.

To carry out business analysis and improve our services

We may use personal information to understand business performance, improve our websites, improve customer service, manage staffing, measure response times, analyse sales and aftersales activity, review marketing performance, improve systems and plan future services.

Where possible, we use aggregated or anonymised information for reporting.

To protect our premises, people, systems and business

We use personal information for security, fraud prevention, system monitoring, CCTV, incident management, cyber security, access control, audit and business continuity purposes.


8. Contact preferences and declined contact

We distinguish between:

·         contacting you about a specific enquiry, order, booking, contract, complaint, safety issue or service matter; and

·         sending you marketing communications.

If you decline marketing contact, we will not use your information for marketing. We may still contact you where necessary about a specific enquiry you have submitted, an order, a service booking, a finance application, a complaint, a safety notice, a vehicle recall, a legal or regulatory matter, or another non-marketing purpose.

If you tell us that you do not want to be contacted at all, or you submit an enquiry without selecting any contact method, we may be unable to respond to your enquiry. We will not add you to marketing activity and may retain limited information to record and respect your preference.


9. Marketing and PECR

We comply with data protection law and the Privacy and Electronic Communications Regulations when sending marketing.

We may send marketing by email, SMS, telephone, post, social media or other channels where lawful.

For individual customers, sole traders and some partnerships, email and SMS marketing will usually require consent or a valid soft opt-in.

The soft opt-in may apply where:

·         you have given us your contact details during a sale or negotiation for a sale;

·         we are marketing our own similar products or services;

·         you were given a clear opportunity to opt out when your details were collected; and

·         you are given a clear opportunity to opt out in every marketing message.

For corporate business contacts, different rules may apply, but we will still respect objections and opt-outs.

You can opt out of marketing at any time.

We may still send service messages that are not marketing, such as appointment confirmations, safety notices, recall information, contractual updates, finance or insurance administration, complaint responses or important customer service communications.


10. Cookies and website tracking

Our websites may use cookies and similar technologies to operate the website, remember your preferences, analyse website performance, understand customer journeys and support marketing activity.

Some cookies are necessary for the website to work. Other cookies, such as analytics or advertising cookies, may require your consent.

Further information about the cookies we use, how long they last and how you can manage your preferences is available in our Cookie Policy or cookie settings tool.


11. Who we share your information with

We may share personal information where necessary and lawful with:

·         Pulman Group companies and trading businesses;

·         vehicle manufacturers and importers;

·         finance providers, funders, leasing companies and lenders;

·         insurance providers, warranty providers, roadside assistance providers and added-value product providers;

·         credit reference agencies and fraud prevention agencies;

·         Pinewood and other dealer management system providers;

·         Motor Complete and other website or CRM providers;

·         Zoom and other telephone, call recording or communications providers;

·         TekCor4 or other aftersales, predictive service, CRM or vehicle data providers where relevant;

·         website, hosting, IT, cyber security, cloud storage and system providers;

·         marketing, analytics, advertising, lead generation, email and customer survey providers;

·         payment processors and finance administration providers;

·         vehicle delivery, logistics, repair, bodyshop, valeting, accessory and parts suppliers;

·         professional advisers including accountants, auditors, insurers and legal advisers;

·         regulators, public authorities, law enforcement agencies, courts and ombudsman services;

·         DVLA, DVSA or other public bodies where required or lawful;

·         any third party where necessary to protect our rights, customers, employees, systems or business.

We do not sell your personal information.


12. Vehicle manufacturers and brand partners

Where you purchase, lease, service or repair a vehicle, or where we assist with a warranty, recall, technical, goodwill or customer care matter, we may share relevant personal information with the relevant vehicle manufacturer, importer or brand partner.

This may include Volkswagen, Volkswagen Commercial Vehicles, SEAT, CUPRA, Škoda and their associated group companies, systems, service providers and finance or customer care partners.

Manufacturers may use your information for their own purposes, including warranty administration, recalls, safety notices, technical support, customer care, brand surveys, market analysis and regulatory obligations. In many cases, manufacturers will act as independent controllers and will provide their own privacy information.


13. Finance, leasing and insurance providers

Where you ask us to assist with finance, leasing, contract hire, insurance or related products, we may share your information with finance providers, funders, lenders, brokers, insurers, product providers, credit reference agencies and fraud prevention agencies.

These organisations may use your information to assess applications, verify identity, carry out credit and affordability checks, prevent fraud, administer agreements, manage arrears, respond to complaints and meet legal or regulatory obligations.

These organisations usually act as independent controllers and will provide their own privacy information.


14. Processors and service providers

Some third parties process personal information on our behalf. These may include DMS, CRM, website, telephone, call recording, IT, hosting, marketing, reporting, document management, payment and customer service providers.

Where a provider acts as our processor, they must process personal information only in accordance with our instructions, our contract and applicable data protection law.

Some providers may also act as independent controllers for limited purposes, such as account administration, security, service improvement, legal compliance or where they determine their own purposes. Where this applies, their own privacy information will explain how they use personal information.


15. International transfers

Some of our suppliers, systems or service providers may process personal information outside the United Kingdom.

Where personal information is transferred outside the UK, we will take steps to ensure appropriate safeguards are in place. This may include adequacy regulations, standard contractual clauses, the UK International Data Transfer Agreement, the UK Addendum to EU standard contractual clauses, or other lawful transfer mechanisms.


16. How long we keep personal information

We keep personal information only for as long as necessary for the purpose for which it was collected, including to meet legal, regulatory, accounting, tax, warranty, safety, complaint handling and legal claim requirements.

The table below sets out our usual retention periods. In some cases, we may retain information for longer where necessary, for example where there is a complaint, legal claim, regulatory matter, safety issue, fraud concern, finance or insurance issue, or ongoing customer relationship.

Data category

Usual retention period

General website enquiry where no purchase, order or service relationship follows

Up to 12 months from last meaningful contact

Pulman Fleet or National Vehicle Solutions enquiry where no order follows

Up to 24 months from last meaningful contact

Test drive, vehicle appraisal or valuation enquiry where no purchase follows

Up to 12 months from last meaningful contact

Customer sales, order and contract records

Usually 6 years after our relationship with you ends

Vehicle service, repair, MOT, parts and warranty records

Usually 6 years after our relationship with you ends, or longer where needed for warranty, recall, safety or manufacturer requirements

Finance, leasing and insurance records

Usually 6 years after final interaction or the end of the relevant agreement, or longer where required

Complaint records

Usually 6 years after the complaint is closed

Standard Zoom call recordings

Usually up to 365 days

Call recordings, transcripts or notes linked to complaints, finance, insurance, regulatory matters, legal claims or disputes

Up to 6 years where necessary

Zoom call logs and call metadata

Usually up to 24 months

Voicemail and similar telephone messages

Usually 30 to 90 days unless required for a complaint, dispute or regulatory matter

SMS/MMS or telephone messages used for customer communication

Usually up to 24 months unless required for a longer lawful purpose

CCTV

Normally up to 30 days, unless required for an incident, investigation, claim or legal matter

Marketing consent records

While active and for a reasonable period afterwards to evidence consent or withdrawal

Marketing suppression records

As long as necessary to ensure we respect your opt-out

Vulnerable customer or additional support notes

Only for as long as relevant and necessary, and subject to review

Website cookies and analytics data

As set out in our Cookie Policy or cookie settings tool

Legal claim, fraud, safety or regulatory investigation records

As long as necessary for the relevant matter

At the end of the relevant retention period, we will delete, anonymise or securely archive the information unless we have a lawful reason to keep it for longer.


17. Security

We take appropriate technical and organisational measures to protect personal information against unauthorised access, loss, misuse, alteration or disclosure.

These measures may include access controls, password protection, staff training, supplier due diligence, system permissions, secure storage, encryption where appropriate, audit controls, cyber security measures, backup processes and secure disposal procedures.

Access to personal information is limited to people who need it for their role.


18. Your data protection rights

You have rights under data protection law. These include:

Right of access

You can ask us for a copy of the personal information we hold about you.

Right to rectification

You can ask us to correct inaccurate or incomplete personal information.

Right to erasure

You can ask us to delete personal information in certain circumstances.

Right to restriction

You can ask us to restrict how we use your personal information in certain circumstances.

Right to object

You can object to processing based on legitimate interests in certain circumstances.

You have an absolute right to object to direct marketing at any time.

Right to withdraw consent

Where we rely on consent, you can withdraw that consent at any time.

Right to data portability

In certain circumstances, you can ask us to provide your information in a structured, commonly used and machine-readable format.

Rights relating to automated decision-making

You have rights relating to decisions based solely on automated processing where those decisions have legal or similarly significant effects.

We do not usually make decisions about customers based solely on automated processing that have legal or similarly significant effects. If this changes, we will provide appropriate information.

These rights do not apply in every situation. For example, we may need to keep certain information to comply with legal, regulatory, contractual, tax, accounting, complaint handling, safety or legal claim obligations.

To exercise your rights, please contact us using the details in section 3.


19. Complaints

If you are unhappy with how we use your personal information, please contact us first so that we can try to resolve your concern.

You also have the right to complain to the Information Commissioner’s Office.

Information Commissioner’s Office
Website: www.ico.org.uk
Telephone: 0303 123 1113


20. Changes to this policy

We may update this Privacy Policy from time to time to reflect changes in our business, systems, legal obligations or how we use personal information.

The latest version will be published on our website. Where appropriate, we may also notify you of significant changes by other means.



 service, complaint handling and regulatory purposes. Please see our Privacy Policy for more information.”

Pulman Volkswagen, Pulman Group, Pulman SEAT, Pulman Škoda, Pulman CUPRA, Pulman Volkswagen Commercial Vehicles, Pulman Used Cars and Pulman Fleet are all trading divisions of Mike Pulman Holdings Ltd, we are committed to protecting and respecting any personal information you share with us.

This statement describes:

  • What types of information we collect from you
  • How it is used by us
  • How we share it with others
  • How you can manage the information
  • How you can contact us

We will always give you the option not to receive marketing communications from us. We will never send you unsolicited ‘junk’ email or communications, or share your data with anyone else who might. We do not sell your information to third parties, but we do work closely with selected partners who help us to provide you with the information, products and services that you request from us. For example, Volkswagen UK, Autoglym.

The contents of this statement may change from time to time so you may wish to check this page occasionally to ensure you are still happy to share your information with us. Where possible, we will also contact you directly to notify you of these changes.

What information do we collect?

We collect information about you and your vehicle when you engage with our website, applications or authorised repairer network. We only collect information which is necessary, relevant and adequate for the purpose you are providing it for.

We collect information about you or your vehicle when you use a Pulman website, visit a Pulman showroom and / or call our aftersales contact centres or switchboard. We also may obtain information about you or your vehicle from our Manufacturer partners, finance providers, credit reference agencies and other third partners. Some of this information does not identify you personally, but provides us with information about how you use our services and engage with us (we use this information to improve our service and make them more useful to you). The information we collect includes some or all of the following:

  • Name (including title)
  • Address
  • Phone number
  • Date of birth
  • Email address
  • Vehicle information (including registration number, VIN, service reminders, mileage and warranty repair information)
  • The date and time you used our services
  • The pages you visited on our website and how long you visit us for
  • Your IP address
  • The internet browser and devices you are using
  • Cookie, Pixels or Beacon information (for more information please see our Cookie Policy
  • The website address from which you accessed our website
  • Details of any transaction between yourself and Mike Pulman Holdings Ltd
  • Where you engage with us in a business context, we may collect your job title, company contact details (including email addresses), fleet size and company details
  • The website address from which you accessed our website
  • Voice recordings of calls you make with Mike Pulman Holdings Ltd
  • Live chat records
  • Any information within correspondence you send us
  • PayPal transactional ID’s and amount created for reservations

How do we use this information?

Mike Pulman Holdings Ltd will only process information that is necessary for the purpose for which it has been collected. You will always have the option not to receive marketing communication from us (and you can withdraw your consent or object at any time). We will never send you unsolicited ‘junk’ email or communications, or share your personal information with anyone else who might.

There are various ways in which we may use or process your personal information. We list these below:

Consent:

Where you have provided your consent, we may use and process your information to:

  • Contact you from time to time about promotions, events, products, services or information which we think may be of interest to you.
  • Contact you reference your specific Pulman account preferences, notifying of any watched cars or new cars which match your preference and any other account feature that you have opted in for.
  • If consented, to share your personal information with Manufacturer partners, so that they can contact you with marketing information about their products and services.

You can withdraw your consent at any time by contacting us on the details here or, in relation to any marketing messages you receive, by using the unsubscribe option included in those messages.

Contractual performance:

We may use and process your personal information where this is necessary to perform a contract with you and to fulfil and complete your orders, purchases and other transactions entered with us (or one of our selected partners).

Legitimate interests:

We may use and process your personal information as set out below where it is necessary for us to carry out activities for which it is in our legitimate interests as a business to do so.

Processing necessary for us to support customers with sales and other enquiries

  • To respond to correspondence, you send to us and fulfil the requests you make to us (for example: test drives, service requests, brochure requests or information about specific vehicles).
  • To provide vehicle support and services (for example warranty services).

Processing necessary for us to operate the administrative and technical aspects of our business efficiency and effectively

  • To verify the accuracy of information that we hold about you and create a better understanding of you as a customer.
  • For network and information security purposes i.e. in order for us to take steps to protect your information against loss, damage, theft or 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).
  • To inform you of updates to our terms and conditions and policies.

Processing necessary for us to promote our business, brands and products and measure the reach and effectiveness of our campaigns

  • To send you marketing information from time to time after you have purchased a product or service from us. We will only contact you with information about our own products and services (and in ways the law allows), which we hope you will like. You have the right to object to us sending you this information at any time.
  • To contact you from time to time with marketing information (unless you object) if you have expressly indicated to us that you are acting on behalf of a business or where we have obtained business contact details from an online or public business directory. In relation to any such information we send by email or SMS, we will include an option allowing you to object to receiving future messages by unsubscribing.
  • To contact you with targeted advertising delivered online through social media and other platforms operated by other companies, unless you object. You may receive advertising based on information about you that we have provided to the platform or because, at our request, the platform has identified you as having similar attributes to the individuals whose details it has received from us. To find out more, please refer to the information provided in the help pages of the platforms on which you receive advertising from us.
  • To identify and record when you have received, opened or engaged with our website or electronic communications (please see our Cookie Policy for more information)
  • To administer competitions and promotions that you enter with us from time to time and to distribute prizes.

Processing necessary for us to respond to understanding customers’ and drivers’ needs

  • To analyse, evaluate and improve our products and services so that your visit and use of our website and aftersales contact centre are more useful and enjoyable (we will generally use data amalgamated from many people so that it doesn’t identify you personally).
  • To undertake customer surveys so that we can better understand your customer experience with Mike Pulman Holdings Ltd. We will only send marketing communications to you if you have provided your consent for us to do so or which we have obtained in the ways mentioned in the paragraph above.
  • In some cases, we may use automated methods to analyse, combine and evaluate information that you have provided to us to deliver the most appropriate customer experience to you. By tailoring and making relevant all our service and communication. For example, when your mileage suggests your vehicle is due a service.

Legal Obligation:

We may process your personal information to comply with our legal requirements (for example to register your car with the DVLA).

Vital Interest:

Sometimes we will need to process your personal information to contact you if there is an urgent safety or product recall notice and we need to tell you about it.

How do we share this information?:

We do not sell your information to third parties, but we do work closely with our manufacturer partners and with third party suppliers who fulfil business activities for us (like finance applications, marketing, roadside assistance, warranty etc.)

We do not sell your information to third parties. However, we may from time to time disclose your information to companies or organisations to which we pass the responsibility to handles services on our behalf: roadside assistance providers for example.

In order to process vehicle sales, servicing, warranty claims and record vehicle service history we will share your information with the relevant manufacturer of your vehicle. For more detail of the ways in which your information is used by these manufacturers, please see links below.

  • For more information of how Volkswagen uses your information, see the full Privacy Statement here.
  • For more information of how SEAT uses your information, see the full Privacy Statement here.
  • For more information of how Škoda uses your information, see the full Privacy Statement here.

We may also share information with financial partners such as Volkswagen Financial Services UK Limited and Black Horse Limited where you enquire about their services through us or where you make a compliant to us and later make the same or similar complaint to them. The finance partners may use your information to provide you with information and carry out their obligations arising from contracts you enter into with them. For more information, please see: Volkswagen Financial Services UK Limited Privacy Statement and Black Horse Limited Privacy Statement.

We take steps to ensure that any third-party partners who handle your information comply with data protection legislation and protect your information just as we do. We only disclose personal information that is necessary for them to provide the service that they are undertaking on our behalf. We will aim to anonymise your information or use aggregated none specific data sets wherever possible.

We will use technical and organisational measures to safeguard your personal data.

How long do we keep your information for?

We will not hold your personal information in an identifiable format for any longer than is necessary. If you are a customer or otherwise have a relationship with us we will hold personal information about you for a longer period than if we have obtained your details in connection with a prospective relationship.

We do not retain personal information in an identifiable format for longer than is necessary.

If we have a relationship with you (e.g. you are a customer or the registered driver of a leased or other vehicle purchased from us), we hold your personal information for 6 years from the date our relationship ends. We hold your personal information for this period to establish, bring or defend legal claims. Our relationship may end for a number of reasons including where the vehicle warranty or lease expires, or we have been made aware that you no longer own or drive that vehicle.

Where we have obtained your personal information following a request for information, test drive, brochure, quotations or any other information requested on any other of our products or services. We will hold your information for 1 year from the date we collect that information, unless during that period we form a relationship with you e.g. you purchase or lease a vehicle. We hold your personal information for this period to give us an opportunity to form a relationship with you.

The only exceptions to the periods mentioned above are where:

  • The law requires us to hold your personal information for a longer period, or delete it sooner.
  • Where you have raised a compliant or concern regarding a product or service offered by us, in which case we will retain your information for a period of 6 years following the date of that compliant or query.
  • You exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law.

How can I manage the information we hold about you?

You have the right as an individual to access your personal information we hold about you and make corrections if necessary. You also have the right to withdraw any consent you have previously given us to ask us to erase information we hold about you. You can also object to us using your personal information (where we rely on our business interests to process and use your personal information).

You have a number of rights in relation to your personal information under data protection law. In relation to most rights, we will ask you for information to confirm your identity and, where applicable, to help us search for your personal information. Except in rare cases, we will respond to you within 30 days after we have received any request.

You have a right to:

  • Ask for a copy of the information that we hold about you.
  • Correct and update your information.
  • Object to our use of your information (where we rely on our legitimate interests to use your personal information) provided we do not have any continuing lawful reason to continue to use and process the information. When we do rely on our legitimate interests to use your personal information for direct marketing, we will always comply with you right to object.
  • Erase your information, provided we do not have any continuing lawful reason to continue to use process that information
  • Transfer your information in a structured data file, where we rely on your consent to use and process your personal information or need to process it in connection with your contract.

You can exercise the above rights and/or manage your information by contacting us using the details below:

  • Post: Newcastle Road, Sunderland, Tyne & Wear, SR5 1QE
  • Email: [email protected]
  • Phone: 0800 0720 228
  • Post: Abbey Road, Durham, County Durham, DH1 5HA
  • Email: [email protected]
  • Phone: 0800 0720 228
  • Post: Belmont Industrial Estate, Durham, County Durham, DH1 1HP
  • Email: [email protected]
  • Phone: 0800 0720 228

If you have any specific data protection concerns or a compliant, you can address it to our Data Protection Team.

This policy was last modified on 18/10/2019