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PRIVACY POLICY

TURNER GROUNDSCARE (hereinafter also referred to only as “TURNER GROUNDSCARE”) is strongly committed to your privacy and the protection of your personal data. As a result, this notice is designed to inform you about how we process your personal data as they are collected during your visits to our websites and as you use our applications or when you engage with our operators (hereinafter referred to collectively as the “Platforms”).

For example, we may collect information about you when you:

  • Request a cost estimate or a test-drive;
  • Use other services through our Platforms;
  • Have phone conversations with our operators;

More specifically, we need to process the data you provide when you register with our Platforms or when you request a service. Subject to your consent, moreover, we may use other information you provide freely at the time of registration or information related to how you engage with us (hereinafter referred to collectively as the “Data”). 

This Privacy Policy (together with our Terms and Conditions applicable to the relevant services, our Cookie Policy and other disclosures that may be provided in relation to the individual services) sets out the grounds based on which your Data will be processed.

1. What data do we collect?

We may collect and process the following data:

1.1 Data collected through our online enquiry or registration form.

If you submit a cost estimate or test-drive request and wish to receive additional services that require your prior registration, then we may ask you to provide some personal information, including your personal details (e.g. first name and last name), your address and contact details (e.g. postcode, telephone, email) and information about the car in respect of which you are requesting a certain service (e.g. vehicle registration plate, mileage).

While providing your Data through the appropriate form is optional, failure to provide the information marked with an asterisk will not enable us to complete the registration process and/or supply you the services you requested.

Subject to your consent, we may also use other information freely provided by you through our online form, such as: date of birth, driving licence number, driving licence expiry date, gender, taxpayer identification number, profession, education.

1.2 Data collected from social media

Our Platforms may allow you to complete enquiry and/or registration forms by logging in using your social media credentials (e.g. Facebook).

In this case, if you decide to rely on authentication methods using your social media credentials, we may have access to certain information (e.g. first name, last name, public profile picture, email) you have included in your own account, according to the terms of use of such social media platforms and depending on your privacy settings.

1.3 Data collected when using our Platforms

When you use our Platforms, we will process such Data as may be necessary to access these Platforms and the underlying services, including, but not limited to, login information and data relating to the pages you visit and your requests, preferences for a given car (as also shown through a special feature on our app), detailed data sheets of viewed cars, comparisons made between cars, other additional information that you may provide freely in order to make your online experience with our Platforms as thorough as possible (e.g. including personal profile pictures and pictures of each vehicle).

Unless you do give your specific consent to processing for other purposes, this information will be used solely to enable you to enjoy our Platforms and provide you with the information and services you may request from time to time.

1.4 Browsing data

Even if no login is required, the information systems we use to ensure the smooth running of our websites and applications will, during normal operations, acquire some personal data, the transmission of which is implicit in the use of electronic communication systems.

These data are not collected with a view to being associated with identified data subjects, but, given their nature, they may allow you to be identified if processed by and associated with data held by third parties. This category of data includes, for example, IP addresses or domain names of computers you use to access our websites and our applications, the type and version of your browser, the type and version of your browser plug-ins, your mobile device ID (IDFA and AndroidID) and other parameters relating to your operating system and IT environment, URIs (Uniform Resource Identifiers) of the resources requested, time of request, size of file received in response and numerical code specifying the status of the answer provided by the server.

Unless you give your specific consent to the processing for further purposes, these data will only be used to gather anonymous statistical data regarding the use of the websites and applications and to improve user experience and ensure the smooth running of such websites and applications, and will be deleted soon after processing is completed.

1.5 Additional Data

Subject to your consent, we may also use other information freely provided by you when submitting your enquiry and/or registration form or while you use our Platforms, as well as additional information about the way you interact with us and with our operators and sales advisors.

2. For what purposes and based on what legal grounds will we use your Data?

We will use your Data, including by relying on electronic tools, to:

  1. Enable you to use our Platforms. Your Data will be used to deliver you the services you are entitled to and, more generally, to discharge all related contractual and administrative formalities;
  2. Provide you with any cost estimates and/or details of test-drives you may have requested.
  3. Comply with law requirements and any orders issued by law enforcement authorities;
  4. Process data for statistical purposes using completely anonymized and aggregate information.

Subject to your consent, we may also use your Data to:

  1. Send you commercial and/or promotional information as well as advertising material or engage in direct selling of and interactive marketing communications about products, services and other TURNER GROUNDSCARE or third party’s activities or engage in market research endeavours. For example, we may send you emails or use instant messaging (e.g. SMS and WhatsApp) or contact you by phone through an operator to illustrate commercial offers, initiatives and promotions relating to our and/or third parties’ products and services (including products and services other than those you requested);
  2. Review your preferences and the ways you interact with us. In particular, with a view to gaining a better understanding of your tastes and interest in our services and communications, we may review the information you provided when you enrolled with our Platforms and other services available on our Platforms, your interest in the communications and newsletters we send you, the way you use our Platforms and your interest in our social channels (e.g. Facebook). For the purposes of such review, we may also rely on automated systems. Finally, we may enhance your profile with statistical data we may lawfully acquire from other sources, such as data related to the area in which you live (e.g. demographic data, georeferencing data, etc.) or to the electronic devices you use to interact with us;

In any event, you will not be subject to entirely automated decision-making processes with the effects as under Article 22 of the GDPR.

  1. to disclose your Data to our Business Partners for their own marketing purposes;

The use of Platforms and related services, including fulfilling estimate and test-drive requests, are in no way conditional on providing your consent as stated above.

3. How long will we store your Data?

Your Data will be processed for the time required to provide you with the services you requested. Unless you have given your consent to processing for additional purposes, your Data will be erased or anonymized after 12 months have elapsed since the date of receipt of your request.

On the other hand, the information associated with your account will be stored for as long as your account remains active. In case you decide to delete your account, your Data will be erased from your account within and not later than 30 days. In any event, for the purposes under 2 (e) and (f) above, the information relating to (i) the details of the services provided to you and (ii) your interactions with us will be processed for a period not exceeding 12 months as of the date of collection.

4. Who do we share your Data with?

Your Data may, for administrative purposes, be shared with parent companies, TURNER GROUNDSCARE’s subsidiaries and affiliates, as well as, for the purposes of Platform operation and delivery of the services requested, our partners who provide services that are incidental to the services delivered by TURNER GROUNDSCARE (e.g. IT services). These entities will act as data processors.

In the event of a cost estimate or test-drive being requested, TURNER GROUNDSCARE may also disclose your Data to its own Business Partners, whose support is deemed necessary in order to deliver the requested services, with special reference to financial or insurance companies, car manufacturers or companies entrusted by them with the management of the contacts involved from time to time (hereinafter referred to as the “Business Partners”), based on the cost estimate and/or test-drive requests you may submit.

Our Business Partners operate as independent data controller and in compliance with their own privacy policies, which they will send you together with the cost estimates or other information you may have requested.

If you wish to receive a full list of the entities to whom your Data may be disclosed, please send a written request to the contacts shown below.

5. Will your Data be transferred to non-EU countries?

Your Data will not be transferred outside the territory of the European Union.

6. What rights are you entitled to?

You have the right to request access to, rectification or erasure of your Data, restriction of processing and object to the processing of your Data by us, as well as the right to request the delivery of some of such Data.

Data subject’s rights:

Right of access

The data subject has the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:

(a) The purpose of processing;

(b) The categories of personal data concerned;

(c) The recipients or categories of recipients to whom the Personal Data have been or will be disclosed, in particular recipients of third-party countries or international organisations, with confirmation as to whether adequate safeguards are in place;

(d) Where possible, the envisaged period for which the personal data will be stored or, if not possible, the criteria used to determine that period;

(e) The existence of the right to request from the controller rectification or erasure of personal data or restriction of processing concerning the data subject or to object to such processing;

(f) The right to lodge a complaint with a Supervisory Authority;

(g) Where the personal data have not been collected from the data subject, any available information on their source;

(h) The existence of an automated decision-making process, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her and, at least in those cases, meaningful information about the rationale, the significance and the envisaged consequences of such processing for the data subject.

Right to rectification

The data subject has the right to obtain from the data controller without undue delay the rectification of inaccurate personal data concerning him or her.

Right to erasure (‘right to be forgotten’)

The data subject has the right to obtain from the data controller the erasure of personal data concerning him or her without undue delay and the data controller has the obligation to erase personal data without undue delay where one of the following grounds applies:

(a) The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

(b) The data subject withdraws consent on which the processing is based and where there is no other legal ground for the processing;

(c) The data subject objects to the processing and there are no overriding legitimate grounds for the processing;

(d) The personal data have been unlawfully processed;

(e) The personal data have to be erased for compliance with a legal obligation under the European Union or Member State law to which the data controller is subject.

Right to restriction of processing

The data subject has the right to obtain from the data controller restriction of processing where one of the following applies:

(a) The accuracy of the personal data is contested by the data subject. Data processing will be restricted for a period enabling the data controller to verify the accuracy of such personal data;

(b) The processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use;

(c) The data controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;

(d) The data subject has objected to processing pending the verification whether the legitimate grounds of the data controller override those of the data subject.

Right to object

The data subject has the right to object at any time to the processing of personal data concerning him or her which is based on the data controller’s legitimate interest, including profiling. The data subject has the right to object at any time to the processing of personal data concerning him or her for direct marketing purposes, including profiling to the extent that it is related to such direct marketing.

Right to data portability

The data subject has the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format, and has the right to transmit those data to another data controller without hindrance from the data controller to which the personal data have been provided, where the:

(a) Processing is based on consent or on a contract; and

(b) Processing is carried out by automated means.

In exercising his or her right to data portability, the data subject has the right to have the personal data transmitted directly from one data controller to another, where technically feasible.

7. How can you change your preferences or withdraw your consents?

You may at any time control, change or withdraw your consents in relation to the purposes under 2 (e), (f) and (g) above (and you may also represent that you do not wish to receive commercial information by email and/or instant messaging) All you need to do contact TURNER GROUNDSCARE.

8. How to contact TURNER GROUNDSCARE and the Data Protection Officer in order to exercise your rights?

You may exercise your rights by writing to the data controller and TURNER GROUNDSCARE/span> to the following addresses:

TURNER GROUNDSCARE

Lansdown Road – Stamford Bridge CH3 8EL

email gareth.baker@turnergroundscare.co.uk

Telephone: 44 01829 742135

9. How to contact the relevant Supervisory Authority to lodge a complaint?

Any complaint may be lodged with the relevant Supervisory Authorities:

The Information Commissioner’s Office

Water Lane, Wycliffe House

Wilmslow – Cheshire SK9 5AF

Tel. +44 1625 545 745

e-mail: international.team@ico.org.uk

Website: https://ico.org.uk

10. How can you be notified of any changes to this Privacy Policy?

This Privacy Policy may be subject to changes and updates in the event that changes are made to the way we process your Data or to other information provided hereunder. Any such changes will ensure that your rights are fully safeguarded. If changes are made to the effect that the safeguards protecting your Data and your rights may be hindered as compared to the current version, before the processing of your data according to the new method begins you will be promptly informed through the contact details you provided and you will be entitled to exercise your right to delete your account or, at any rate, to change your consents and preferences.

In any event, we encourage you to check from time to time the updated Privacy Policy published on this website: turnergroundscare.co.uk/privacy/

Last Updated: [INSERT DATE]

turner-groundscare COOKIE POLICY

This Cookie Policy sets out to provide the user/visitor (hereafter the “User” or “you”) of our turnergroundscare.co.uk Website (hereafter the “Site”) with a description of how cookies are managed.

You are encouraged to read this Cookie Policy carefully before carrying on navigating through the Site.

What is a cookie?

Cookies are small text files that are stored on the user’s device when he/she visits a website. When the same user returns, cookies are re-sent to the site that first created them (first party cookies) or to another site that recognises them (third party cookies). They have a number of purposes, such as increasing browsing efficiency, remembering favourite sites and, in general, giving a better online experience. Cookies also help deliver advertising contents more in line with the User’s interests. Depending on their function and the party that created them, cookies can include technical cookies, analytical and profiling cookies, first party cookies and third party cookies.

Technical cookies

This category of cookies includes so-called essential cookies, i.e. those needed to enable Site functions, without which the Site may not be used to its fullest potential.

Essential technical cookies are used solely by TURNER GROUNDSCARE and, as such, they qualify as first party cookies. They are stored on your computer (or another device) only during single browser sessions. Essential technical cookies are used, for instance, to allow you to log into your own account, add vehicles for comparison purposes, access the garage section, choose vehicle features and finally provide your with additional information, such as the most recent vehicles viewed.

This type of technical cookie is also used to save the User’s consent decision regarding the use of the Site cookies.

Essential technical cookies cannot be disabled using the Site’s functions.

Name

Characteristics and functions

Duration

Source

Name

Characteristics and functions

Duration

DealerK

cc_cookie_accept

Recognises the user and prevents popups from appearing if already accepted

1 Year

DealerK

cc_cookie_decline

Recognises the user and prevents popups from appearing if already accepted

Permanent

New Relic

__NREUM,

__NRAGENT,

__JSESSIONID

Monitoring of site performance

Session

Cloudflare

__cfduid

Identifies visitors coming from shared IPs and applies specific safety measures

1 Year

Google

__NID

6 Months

Profiling cookies

The Site also uses profiling cookies, which are used to analyse user behaviour in order to improve the Site’s browsing experience, and for marketing purposes. The use of profiling cookies requires the User’s prior voluntary and informed consent.

To this end, the Site acquires the User’s consent as set forth in the Decision through the banner that appears when the Site is first visited. Consent may be withdrawn at any time by disabling the respective cookie. Refusal to give your consent to the use of profiling cookies will not affect your ability to access the Site, however some functions or contents that use these cookies will not be available.

You may change the settings and your consent regarding the use of profiling cookies at any time.

Name

Characteristics and functions

Duration

Consent

Source

Cookie

Characteristics and functions

Duration

DealerK

_gat_allDeKTracker

Tracking of analytics data by means of DealerK account

1 Year

DealerK

_gat_customerTracker

Tracking of analytics data for the dealer’s account

1 Year

DealerK

_dk_consent_given

Tracking of consent for the processing of personal data

1 Year

Google Adwords

__ga,

__gat

To review and improve advertising so that the User receives messages in keeping with his/her interests

2 Years,

1 Minute

Icegram

icegram_campaign_shown_[Campaign Code]

Tracking of User’s behaviour regarding the viewing of graphics such as banners, pop-ups, toasts and messengers

1 Year

Third party cookies

While browsing the Site, cookies from third party sites or web servers (i.e., “third party” cookies) may also be stored on device. This happens because the Site may contain items such as images, maps, sounds, specific links to the web pages of other domains residing on servers other than that on which the requested page is located. Basically, these cookies are set directly by operators of websites or servers other than the Site. Theoretically, these third parties may set cookies while you visit the Site, thereby becoming aware of you visiting the Site. You will find more information on the use of cookies by clicking on the link. If you decide not to give your consent to the storing of third party cookies, then you may only use those functions of the Site that do not require such cookies.

 

Source

Cookie

Characteristics and functions

Duration

Link to the site to read the third party’s privacy statement

HotJar

__hjClosedSurveyInvites,

__hjDonePolls,

__hjMinimizedPolls,

__hjDoneTestersWidgets,

__hjMinimizedTestersWidgets,

__hjDoneSurveys

Anonymised service to generate heatmaps, monitor User’s movements and clicks on pages, analyse performance and record user sessions

1 Year

1 Year

1 Year

1 Year

1 Year

1 Year

https://www.hotjar.com/legal/policies/privacy

Google Analytics

__utma __utmb __utmz __utmc __utmt

Service to analyse site traffic anonymously, with data aggregation in Google Analytics

2 Years,

30 Minutes,

6 Months,

Session,

10 Minutes

https://policies.google.com/privacy

Google Adwords

__ga,

__gat,

__gid

To review and improve advertising so that the User receives messages in keeping with his/her interests

2 Years,

1 Minute,

24 Hours

https://policies.google.com/privacy

DoubleClick

__ID,

__DSID,

__IDE

To review and improve advertising so that the User receives messages in keeping with his/her interests

1.5 Years,

1.5 Years,

1.5 Years

https://support.google.com/dcm/partner/answer/2839090?hl=it

Facebook

_fr

To review and improve advertising so that the User receives messages in keeping with his/her interests

3 Months

https://www.facebook.com/policies/cookies/

Piwik (Matomo)

__pk_ref,

__pk_cvar,

__pk_id,

__pk_ses,

__pk_hsr,

__pk_uid

Service to analyse site traffic in anonymously, with data aggregation in Matomo

Session,

1 Year

1 Year,

Session,

1 Year,

Session

https://matomo.org/privacy-policy/

Criteo

__eid,

__uid,

__optout

To review and improve advertising so that the User receives messages in keeping with his/her interests

6 Months,

1 Year,

5 Years

https://www.criteo.com/it/privacy/

Linkedin

__lidc,

__bcookie,

__bscookie,

__L1c,

__BizoData,

__BizoID,

__BizoUserMatchHistor,

__BizoCustomSegments

To review and improve advertising so that the User receives messages in keeping with his/her interests

1 Day,

1 Year,

Session,

6 Months,

6 Months,

6 Months,

6 Months

https://www.linkedin.com/legal/cookie-policy?_l=it_IT

Smartupp Chat

__ssupp.vid,
__ssupp.opened,

__ssupp.geoloc,

__ssupp.barclicked,

__ssupp.chatid,

__ssupp.message,

To improve the service provided to its visitors through use of a dedicated chat function for direct company-visitor engagement

6 Months,

Session,

Session,

Session,

1 Year

https://www.smartsupp.com/help/privacy/

Smartlook

__SL_C_23361dd035530_KEY

Anonymised service to generate heatmaps, monitor the User’s movements and clicks on pages, analyse performance and record user sessions

2 Years

https://www.smartlook.com/help/privacy-statement/

Bing

__uetsid,
__MR,

__MUID

To review and improve advertising so that the User receives messages in keeping with his/her interests

30 Minutes,

6 Months,

1 Year and 1 Month

https://privacy.microsoft.com/it-it/privacystatement#maincookiessimilartechnologiesmodule

https://account.microsoft.com/privacy/ad-settings/signedout?ru=https:%2F%2Faccount.microsoft.com%2Fprivacy%2Fad-settings

Oracle Bluekai bkdc, bkdu To improve advertising that the user receives and personalize website 18 months, 18 months Privacy Policy (https://www.oracle.com/legal/privacy/marketing-cloud-data-cloud-privacy-policy.html)
Opt Out (https://datacloudoptout.oracle.com/#optout)

How to disable cookies

Most browsers are initially configured to automatically accept cookies. You may change this setting to block cookies or prevent some cookies from being stored on his/her device. There are a number of ways of managing cookies. To manage or change your browser settings, please review your browser technical guide and/or help screen. If you use more than one device (e.g. computer, smartphone, tablet, etc.), you will be responsible for ensuring that the browser settings of each device are configured in such a way as to reflect your cookie-related preferences.

Below are some links to the online documentation of major browsers:

Internet Explorertm: http://windows.microsoft.com/it-IT/windows-vista/Block-or-allow-cookies

Safaritm: http://www.apple.com/it/support/

Chrometm: https://support.google.com/chrome/answer/95647?hl=it&hlrm=en

Firefoxtm: http://support.mozilla.org/it/kb/Attivare%20e%20disattivare%20i%20cookie

Operatm: http://help.opera.com/Windows/10.20/it/cookies.html

User’s rights:

With respect to the personal data we collect, you may, including by proxy, exercise the rights as under Articles 7 and 15-22 of the GDPR at any time. In particular, you have the right to (i) request access to and rectification or erasure of your data and restriction of processing, (ii) object to their use by us and (iii) obtain a copy of some of such data.

Data subject’s rights:

Right of access

The data subject has the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:

(a) The purpose of processing;

(b) The categories of personal data concerned;

(c) The recipients or categories of recipients to whom the Personal Data have been or will be disclosed, in particular recipients of third-party countries or international organisations, with  confirmation as to whether adequate safeguards are in place;

(d) Where possible, the envisaged period for which the personal data will be stored or, if not possible, the criteria used to determine that period;

(e) The existence of the right to request from the controller rectification or erasure of personal data or restriction of processing concerning the data subject or to object to such processing;

(f) The right to lodge a complaint with a Supervisory Authority;

(g) Where the personal data have not been collected from the data subject, any available information on their source;

(h) The existence of an automated decision-making process, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her and, at least in those cases, meaningful information about the rationale, the significance and the envisaged consequences of such processing for the data subject.

Right to rectification

The data subject has the right to obtain from the data controller without undue delay the rectification of inaccurate personal data concerning him or her.

Right to erasure (‘right to be forgotten’)

The data subject has the right to obtain from the data controller the erasure of personal data concerning him or her without undue delay and the data controller has the obligation to erase personal data without undue delay where one of the following grounds applies:

(a) The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

(b) The data subject withdraws consent on which the processing is based and where there is no other legal ground for the processing;

(c) The data subject objects to the processing and there are no overriding legitimate grounds for the processing;

(d) The personal data have been unlawfully processed;

(e) The personal data have to be erased for compliance with a legal obligation under the European Union or Member State law to which the data controller is subject.

Right to restriction of processing

The data subject has the right to obtain from the data controller restriction of processing where one of the following applies:

(a) The accuracy of the personal data is contested by the data subject. Data processing will be restricted for a period enabling the data controller to verify the accuracy of such personal data;

(b) The processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use;

(c) The data controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;

(d) The data subject has objected to processing pending the verification whether the legitimate grounds of the data controller override those of the data subject.

Right to object

The data subject has the right to object at any time to the processing of personal data concerning him or her which is based on the data controller’s legitimate interest, including profiling. The data subject has the right to object at any time to the processing of personal data concerning him or her for direct marketing purposes, including profiling to the extent that it is related to such direct marketing.

Right to data portability

The data subject has the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format, and has the right to transmit those data to another data controller without hindrance from the data controller to which the personal data have been provided, where the:

(a) Processing is based on consent or on a contract; and

(b) Processing is carried out by automated means.

In exercising his or her right to data portability, the data subject has the right to have the personal data transmitted directly from one data controller to another, where technically feasible.

You may exercise your rights by writing to the data controller to the following address:

TURNER GROUNDSCARE

Lansdown Road – Stamford Bridge CH3 8EL

email gareth.baker@turnergroundscare.co.uk

Telephone: 44 01829 742135

For more information about the processing of your personal data on the Site, please review our Privacy Policy at turnergroundscare.co.uk/privacy/.

Cookie Policy