Part Exchange Centre
1 ABOUT THIS POLICY
1.1 We appreciate your interest in our products and services and your visit to this website. Your privacy is important to us and we want you to feel comfortable with how we use and share your personal information.
1.2 This policy sets out how Part Exchange Centre (a Trading Name of City West Country Ltd) handle your personal information, including when and why it is collected, used and disclosed and how it is kept secure.
1.3 You will find our contact details at the end of this policy which you can use if you have any questions, including how to update or access your personal information or to make a complaint.
1.4 This policy may change, so please check this page from time to time to ensure that you’re happy with any changes. Please see further Changes to this policy in Section 11.
1.5 This policy was last updated on 11th April 2018.
2 WHO WE ARE
2.1 Part Exchange Centre is a Trading Name of City West Country Ltd and whenever you share your personal data with us we are the ‘controller’ of your information within the group. A ‘controller’ is a company that decides why and how your personal information is processed.
2.2 Where this policy refers to “we”, “our” or “us” below, unless it mentions otherwise, it’s referring to the particular company that is the controller of your personal information.
3 HOW AND WHAT PERSONAL INFORMATION WE COLLECT
3.1 We may collect and process the following personal information about you
Personal information you give to us: This is information about you that you give to us by entering information via our websites or our social media pages or by corresponding with us by phone, email or otherwise and is provided entirely voluntarily. The information you give to us includes your name, contact details (such as phone number, email address and address), enquiry details and your opinion of our products and service.
Personal information we collect about you: We may automatically collect the following personal information: our web servers store as standard details of your browser and operating system, the website from which you visit our website, the pages that you visit on our website, the date of your visit, and, for security reasons, e.g. to identify attacks on our website, the Internet protocol (IP) address assigned to you by your internet service. We collect some of this information using cookies – please see Cookies in Section 9.2 for further information. We may also collect any personal information which you allow to be shared that is part of your public profile on a third party social network.
Personal information we may receive from other sources: We obtain certain personal information about you from sources outside our business which may include other Trading Names of City West Country Limited (Section 13) or other third party companies; the personal information received is as described in the two paragraphs above.
3.2 Please see further how we use your personal information in Section 4 for details of the purposes for which we use the personal information we obtain from these sources and the legal basis on which we rely to process that information. The remaining provisions of this policy also apply to any personal information we obtain from these sources.
4 HOW WE USE YOUR PERSONAL INFORMATION
4.1 Where you have provided CONSENT
We may use and process your personal information where you have consented for us to do so for the following purposes:
- to contact you via email, text message, post or telephone with marketing information about other products and services we believe are relevant based on your preferences (see Marketing section below for further details);
4.2 You may withdraw your consent for us to use your information in any of these ways at any time. Please see Withdrawing your consent in Section 8.4 for further details.
4.3 Where required to perform a CONTRACT with you
We may use and process your personal information where it is necessary for the performance of a contract with you or in order to take steps at your request before entering into a contract with you including for the following purposes:
- To quote correct pricing options based on your requirements
- To process finance agreements
- To order and arrange delivery of your vehicle.
4.4 Where required to comply with our LEGAL OBLIGATIONS
We will use your personal information to comply with our legal obligations including: (i) to assist HMRC, the Police, the Driver and Vehicle Licensing Agency (DVLA) or any other public authority or criminal investigation body; (ii) to identify you when you contact us; and (iii) to verify the accuracy of data that we hold about you.
4.5 Where there is a LEGITIMATE INTEREST
We may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business for the following purposes:
- for analysis, and profiling to inform our marketing strategy, and to enhance and personalise your customer or visitor experience;
- for market research in order to continually improve the products and services that we and our authorised dealers deliver to you;
- to administer our websites and for internal operations, including troubleshooting, testing, statistical purposes;
- for marketing activities (other than where we rely on your consent) e.g. to tailor marketing communications or send targeted marketing messages via social media and other third party platforms;
- for the prevention of fraud and other criminal activities;
- to undertake credit checks for finance;
- to correspond and communicate with you;
- to create a better understanding of you as a customer or visitor;
- for network and information security in order for us to take steps to protect your information against loss or damage, theft 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);
- for the purposes of corporate restructure or reorganisation or sale of our business or assets;
- for efficiency, accuracy or other improvements of our databases and systems e.g. by combining systems or consolidating records we or our group companies hold about you;
- to enforce or protect our contractual or other legal rights or to bring or defend legal proceedings; and
- for general administration including managing your queries, complaints, or claims, and to send service messages to you.
5 OTHERS WHO MAY RECEIVE OR HAVE ACCESS TO YOUR PERSONAL INFORMATION
5.1 Group companies
We may share your information with other companies within City West Country Ltd. They may use your personal information in the ways set out in How we use your personal information in Section 4, in connection with products and services that complement our own offer on products or services.
Please visit About City West Country Ltd in Section 13 for the details of our group companies with whom we may share your personal information.
5.2 Our suppliers and service providers
We may disclose your information to our third party service providers, agents, subcontractors and other organisations for the purposes of providing services to us or directly to you on our behalf. Such third parties may include cloud services providers (such as hosting and email management) or advertising agencies, administrative services or other third parties who provide services to us.
When we use third party service providers, we only disclose to them any personal information that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.
5.4 Third parties who provide products and services
We work closely with various third parties to bring you a range of products and services which are complimentary to ours.
When you enquire about or purchase one or more of these products or services through us (e.g. via our websites), the relevant third party may use your details to provide you with information and carry out their obligations arising from any contracts you have entered into with them.
5.5 Other ways we may share your personal information
We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation. We may also transfer your personal information if we’re under a duty to disclose or share it in order to comply with any legal obligation (e.g. by sharing your personal information with the DVLA), to detect or report a crime, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our visitors and customers.
However, we will always take steps with the aim of ensuring that your privacy rights continue to be protected.
6 WHERE WE STORE YOUR PERSONAL INFORMATION OUTSIDE THE EEA
6.1 All information you provide to us may be transferred to countries outside the European Economic Area (EEA). By way of example, this may happen where any servers of our third party service providers are from time to time located in a country outside of the EEA. These countries may not have similar data protection laws to the UK.
6.2 If we transfer your information outside of the EEA in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this policy. These steps include imposing contractual obligations on the recipient of your personal information or ensuring that the recipients are subscribed to ‘international frameworks’ that aim to ensure adequate protection. Please contact us using the details at the end of this policy for more information about the protections that we put in place and to obtain a copy of the relevant documents.
6.3 If you use our services whilst you are outside the EEA, your information may be transferred outside the EEA in order to provide you with those services.
7 HOW LONG WE KEEP YOUR PERSONAL INFORMATION FOR
7.1 If we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws.
7.2 We do not retain personal information in an identifiable format for longer than is necessary.
7.3 We may need your personal information to establish, bring or defend legal claims, in which case we will retain your personal information for 7 years after the last occasion on which we have used your personal information in one of the ways specified in How we use your personal information in Section 4.
7.4 The only exceptions to this are where:
- the law requires us to hold your personal information for a longer period, or delete it sooner;
- you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted in this section 7, or becausewe are required under the law (see further Erasing your personal information or restricting its processing in Section 8.6); and
- in limited cases, the law permits us to keep your personal information indefinitely provided we put certain protections in place.
8 YOUR RIGHTS
8.1 Your ‘data subject’ rights:
You have a number of rights in relation to your personal information under data protection law. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within 30 days after we have received this information or, where no such information is required, after we have received your request.
8.2 Accessing your personal information
You have the right to ask for a copy of the information that we hold about you by emailing or writing to us at the address at the end of this policy. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.
8.3 Correcting and updating your personal information
The accuracy of your information is important to us and we are working on ways to make it easier for you to review and correct the information that we hold about you.
In the meantime, if you change your name or address/email address, or you discover that any of the other information we hold is inaccurate or out of date, please let us know by contacting us in any of the details described at the end of this policy.
8.4 Withdrawing your consent
Where we rely on your consent as the legal basis for processing your personal information, as set out under How we use your personal information in Section 4, you may withdraw your consent at any time by contacting us using the details at the end of this policy. If you withdraw your consent, our use of your personal information before you withdraw is still lawful.
8.5 Objecting to our use of your personal information and automated decisions made about you.
Where we rely on our legitimate business interests as the legal basis for processing your personal information for any purpose(s), as out under How we use your personal information in Section 4, you may object to us using your personal information for these purposes by emailing or writing to us at the address at the end of this policy. Except for the purposes for which we are sure we can continue to process your personal information, we will temporarily stop processing your personal information in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise we will provide you with our justification as to why we need to continue using your data.
You may object to us using your personal information for direct marketing purposes and we will automatically comply with your request. If you would like to do so, please use our unsubscribe tool.
You may also contest a decision made about you based on automated processing by contacting the data protection department.
8.6 Erasing your personal information or restricting its processing
In certain circumstances, you may ask for your personal information to be removed from our systems by emailing or writing to us at the address at the end of this policy. Unless there is a reason that the law allows us to use your personal information for longer, we will make reasonable efforts to comply with your request.
You may also ask us to restrict processing your personal information in the following situations:
- where you believe it is unlawful for us to do so,
- you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings.
In these situations, we may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings.
8.7 Transferring your personal information in a structured data file
Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with your contract, as set out under Section 4 How we use your personal information, you may ask us to provide you with a copy of that information in a structured data file. We will provide this to you electronically in a structured, commonly used and machine readable form, such as a CSV file.
You can ask us to send your personal information directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.
8.8 Complaining to the UK data protection regulator
You have the right to complain to the Information Commissioners Office (ICO) if you are concerned about the way we have processed your personal information. Please visit the ICO’s website for further details.
9 SECURITY / COOKIES / LINKS / SOCIAL PLUGINS
9.1 Security measures we put in place to protect your personal information
All companies within the City West Country Ltd use technical and organisational security measures to protect the personal information supplied by you and managed by us against manipulation, loss, destruction, and access by third parties. Our security measures are continually improved in line with technological developments.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information whilst in transit to our website and any transmission is at your own risk.
9.2 Use of ‘cookies’
‘Cookies’ are small pieces of information sent to your device and stored on its hard drive to allow our websites to recognise you when you visit.
9.3 Links to other websites
In addition, if you linked to our website from a third party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party website and recommend that you check the policy of that third party website.
9.4 Social plugins
We use so-called social plugins (buttons) of social networks such as Facebook, Google+ and Twitter.
After their activation, a direct link to the server of the respective social network is established. The contents of the button are then transmitted from the social network directly to your browser and incorporated in the website.
After activation of a button, the social network can retrieve data, independently of whether you interact with the button or not. If you are logged on to a social network, the network can assign your visit to the website to your user account. A social network cannot assign a visit to websites operated by our other group companies unless and until you activate the respective button there as well.
If you are a member of a social network and do not wish it to combine data retrieved from your visit to our websites with your membership data, you must log out from the social network concerned before activating the buttons.
We have no influence on the scope of data that is collected by the social networks through their buttons. The data use policies of the social networks provide information on the purpose and extent of the data that they collect, how this data is processed and used, the rights available to you and the settings that you can use to protect your privacy.
10.1 We may collect your preferences to send you marketing information directly from us by email/SMS (where applicable) including:
- if you sign-up for news from us
- if you book a submit an application or request a call back.
We will only do so if you have consented to receiving such marketing information directly from us.
10.2 We may contact you with targeted advertising delivered online through social media and platforms (operated by other companies) by using your personal information, or use your personal information to tailor marketing to improve its relevance to you, unless you object.
10.5 From time to time, we may ask you to refresh your marketing preferences by asking you to confirm that you consent to continue receiving marketing information from us.
10.6 You have the right to opt-out of our use of your personal information to provide marketing to you in any of the ways mentioned above. Please see Withdrawing your Consent in Section 8.4 and Objecting to our use of your personal information and automated decisions made about you in Section 8.5 above for further details on how you can do this.
11 CHANGES TO THIS POLICY
We may review this policy from time to time and any changes will be notified to you by posting an updated version on our website and/or by contacting you by email. Any changes will take effect 7 days after the date of our email or the date on which we post the modified terms on our website, whichever is the earlier. We recommend you regularly check for changes and review this policy when you visit our website. If you do not agree with any aspect of the updated policy, you must promptly notify us and cease using our services.
12 CONTACT US
If you have any questions, suggestions or complaints about the processing of your personal information or wish to contact us to amend/update your marketing preferences with a UK company within the City West Country Group, please contact
|Data Protection Officer
Matford Park Road
13. About City West Country Ltd
City West Country Ltd is the parent company comprising Legal Entities
Mercedes-Benz South West
Mercedes-Benz of Exeter
Mercedes-Benz of Plymouth
Mercedes-Benz of Taunton
Mercedes-Benz of Truro
Part Exchange Centre
City West Country Ltd Slavery and Human Trafficking Statement
The Modern Slavery Act 2015 (MSA 2015) focuses specifically on the issue of modern slavery to ensure offenders are suitably reprimanded with severe sentences. Modern slavery encompasses the offences of: ‘slavery’ where ownership is exercised over a person; ‘servitude’ which involves the obligation to provide service imposed by coercion; ‘forced or compulsory labour’ involves work or service exacted from any person under the menace of a penalty and for which the person has not offered themselves voluntarily; and ‘human trafficking’ concerns arranging or facilitating the travel of another with a view to exploiting them.The MSA 2015 requires large businesses, with sales of over 36 million, to be transparent about their efforts to eradicate Slavery and Human Trafficking. This statement therefore explains the steps we have taken during the financial year to ensure that slavery and human trafficking is not taking place in any of our supply chains or any part of our business.
The organisation – City West Country trading as Mercedes-Benz South West –is the collective of five franchised retail sites, national leasing business and Used car retail centre. The supply chain being weighted towards Mercedes-Benz as the franchise manufacturer. Additional suppliers support maintenance, specialised service and marketing of the business
We have policies in place internally, which are available to all staff and these can be accessed by third parties on request, simply contact firstname.lastname@example.org for a copy. Our policies are reviewed annually by the Director team and Legal advisers to ensure we remain compliant.
As part of the organisation’s induction process and throughout workers’ employment with us, we train all staff to treat others with respect and courtesy as well as ensuring they adhere to all relevant laws, regulations and standards. This is an ongoing due diligence process. We offer a training and development program for all staff from the ground floor through to management. We focus on ensuring our management team is not only aware of the requirements to be alert to modern slavery but can also address concerns raised by their team or any suppliers. If any worker is found in breach of our policies, we ensure suitable disciplinary action is taken which can include termination.
In relation to our supply chains, we use our reasonable endeavours to conduct risk assessments of the third parties we work with and investigate, where feasible, the working conditions of their workers.
As part of our risk assessments, we have procedures in place to identify whether there is a possible threat of slavery and human trafficking either in the business or our supply chain which includes conducting regular audits of businesses that demonstrate risk. We aim to work with our colleagues and suppliers to ensure collaboration to remedy or mitigate such risks.
We allow all individuals who work or provide services to us the right to freely choose employment and, the right to associate freely with other individuals. Workers are free to choose whether to join a trade union or not and as a result of our training, we offer an environment which is free from harassment and unlawful discrimination. We ensure our working practices are in accordance with the Equality Act 2010 and all employment legislation. We do not engage in forced or involuntary labour and have a zero tolerance approach to the same, meaning we do not tolerate any of our suppliers engaging in such conduct. We require suppliers to certify that they do not participate in any forced or involuntary labour with their workers, subcontractors, agents or associates.
Gender Pay Gap Report 2018
At Mercedes-Benz South West we are passionate about creating a diverse and inclusive place to work, with a commitment to equality and fairness at the heart of our values and everyday practices and policies. We aim to recruit, nurture and retain a diverse workforce that reflect the diversity of our customer base.
As part of this, we are committed to creating a gender balanced work force, ensuring that women have the same opportunity within the business to achieve strong career progression as men, which includes pay.
Group Tax Strategy
Mercedes Benz South West is the trading name of City West Country Limited which is the trading subsidiary of CWC (UK Holdings) Limited.
CWC (UK Holdings) Limited is a UK based business involved in the premium motor retail sector. All profits are reported and taxed in the United Kingdom.
This document has been approved by the Board for publication in accordance with Schedule 19 of the Finance Act 2016. It is effective for the year ended 31 December 2017.
Tax Risks and tax planning
The Board of Directors bears ultimate responsibility for all corporate governance and delegates it’s tax strategy to the Group Finance Director who is also the Senior Accounting Officer.
The group has internal systems, policies and processes covering all areas of its operations to ensure it conducts its business in a fair and honest manner, supporting a culture of compliance with all relevant tax legislation.
The board adopts a low risk approach to tax planning. The commercial ethos of the creation of value for all stakeholders in the business including the equity ownership is completely aligned to this low risk approach. We will seek to manage our tax affairs in line with HMRC guidelines and principles. The business employ’s suitably qualified financial staff and engages industry qualified external advisors.
Working with HMRC
We are committed to an open, honest and transparent relationship with HMRC as we seek to have with all stakeholders of the business. We aim to work collaboratively with HMRC whether seeking clarification on a meter or dealing with enquiries.
Approved by the Board of Directors on 8 December 2017.