OEConnection (“OEC”) respects your privacy and is committed to protecting the security of your personal data. This Privacy Notice describes how OEC and its subsidiaries, affiliates, and related entities (collectively, "we," or "us") collect and process personal data about you.
This Privacy Notice is issued on behalf of the OEConnection group of companies so when we mention OEConnection, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the OEConnection group of companies responsible for processing your data. This Privacy Notice describes the categories of personal data that we collect, how we use your personal data, how we secure your personal data, when we may disclose your personal data to third parties, and when we may transfer your personal data outside of your home jurisdiction. This Privacy Notice also describes your rights regarding the personal data that we hold about you including how you can access, correct, restrict processing, request erasure, and transmission of your personal data.
We will process your personal data in accordance with this Privacy Notice unless you consent, or as otherwise required by applicable law. OEC takes all reasonable steps to ensure that the personal data that we collect about you is adequate, relevant, not excessive, and processed for limited purposes.
It is important that you read this privacy notice, together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data.
PLEASE NOTE: This website is not intended for children and we do not knowingly collect data relating to children.
THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store, and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Datawhich includes first name, , last name, Vehicle Identification Number (VIN) or similar identifier, marital status, title, date of birth and gender.
• Contact Datawhich includes billing address, delivery address, email address, and telephone numbers.
• Financial Datawhich includes bank account and payment card details.
• Transaction Datawhich includes details about payments to and from you and other details of products and services that you have purchased from us.
• Technical Datawhich includes internet protocol (IP) address, your login data, browser type and version, browser use, time zone setting and location, the length of time of your visit, the pages you looked at on our site, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Datawhich includes your username and password, purchases or orders made by you, your interests including motor vehicle make and model and specific parts order details as well as other preferences, feedback and survey responses.
• Usage Datawhich includes information about how you use our website, products and services.
• Marketing and Communications Datawhich includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you, including details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. Nor do we collect any information about criminal convictions and offences.
HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you, including through:
• Direct interactions.You may give us your Identity, Contact and Financial Data by filling in forms, electronically or otherwise, or by corresponding with us in person or by post, phone, email or any other method. This includes personal data you provide when, for example, you:
• create an account on our website
• fill out a “Contact Us” or “Request More Information” form on our website
• order our products or services
• subscribe to our service or publications
• request marketing to be sent to you
• enter a competition, promotion or survey
• give us feedback
• Automated technologies or interactions.As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy [LINK] for further details.
• Third parties or publicly available sources.We may receive personal data about you from various third parties and public sources as set out below:
• Technical Data from the following parties:
(a) analytics providers, such as Google, which may be based outside the EU;
(b) marketing tools, such as Hubspot, which may be based outside the EU; and
(c) search information providers such as Wistia, which may be based outside the EU.
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services;
• Identity and Contact Data from data brokers or aggregators; or
• Identity and Contact Data from publicly availably sources.
PURPOSES FOR WHICH WE PROCESS YOUR PERSONAL DATA
We will only use your personal data when the law allows us. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests or those of a third party (including, but not limited to, keeping our records updated, managing and growing our business, reorganizing or restructuring our business, and recovering debts due to us, or to keep our website updated and relevant, develop our products and services, study how customers use our products and services, and inform our marketing strategy) and your interests and fundamental rights do not override these interests.
• Where we need to comply with a legal or regulatory obligation.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at privacy@oeconnection.comif you need details about the specific legal ground we are relying on to process your personal data.
We may also process your personal data:
· To prevent fraud.
· To administer IT services, ensure network and information security, including preventing unauthorized access to our computer and electronic communications systems and preventing malicious software distribution.
HOW WE WILL USE YOUR PERSONAL DATA
We may process your personal data for the following legitimate business purposes and for the purposes of performing any service contracts we may have with you:
· To register you as a new customer
· To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
- To manage our relationship with you and provide you with effective customer support which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Training and consulting
(c) New feature announcements
(d) Asking you to leave a review or take a survey
· To verify your eligibility and deliver prizes in connection with promotions, contests and sweepstakes;
· To enforce our terms and conditions;
· To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
· To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
· To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
· To make suggestions and recommendations to you about goods or services that may be of interest to you
· To comply with applicable law
· To perform other functions as described to you at the time of collection;
We will only process your personal data for the purposes we collected it for or for compatible purposes. If we need to process your personal data for an incompatible purpose, we will provide notice to you and, if required by law, seek your consent. We will only process your personal data without your knowledge or consent where required by applicable law or regulation.
We do not generally rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at Marketing@OEConnection.com.You will not be subject to decisions based on automated data processing without your prior consent.
We will get your express opt-in consent before we share your personal data with any company outside the OEC Group of companies for marketing purposes.
Opting Out
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at Marketing@OEConnection.com.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.
THIRD PARTY SOURCES
Our website or other materials may contain links to websites owned and operated by third parties. Those third parties may collect personal information about you. Once you navigate away from Clifford Thames' webpage(s), this Privacy Policy no longer applies, and Clifford Thames disclaims any responsibility for the privacy practices of such third parties, or the content they provide. Further, Clifford Thames disclaims responsibility for information which is collected by a third party, not affiliated with Clifford Thames, and subsequently provided to Clifford Thames with or without your consent. You should always protect your privacy by reviewing the privacy policies of each third party with whom you interact.
HOW WE MAY SHARE YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out above:
• Internal/External Third Parties such as
• Vendors and service providers acting as processors who provide IT and system administration services.
• Professional advisers and other agents and representatives acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• Regulators and other authorities acting as processors or joint controllers based in the European Unionwho require reporting of processing activities in certain circumstances.
• With other customers, including but not limited to, automotive dealerships, automotive manufacturers, repair facilities, parts suppliers, and insurance companies in order to facilitate transactions; orThird-parties that conduct customer satisfaction surveys on behalf of OEC. Third-parties are used to ensure anonymity of survey respondents.
We may also disclose your personal data for the following additional purposes where permitted or required by applicable law:
· To other members of our group of companies (including outside of your home jurisdiction) for the purposes set out in this Privacy Notice and as necessary to perform our employment contract with you.
· As part of our regular reporting activities to other members of our group of companies.
· To comply with legal obligations or valid legal processes such as search warrants, subpoenas, or court orders. When we disclose your personal data to comply with a legal obligation or legal process, we will take reasonable steps to ensure that we only disclose the minimum personal data necessary for the specific purpose and circumstances.
· To protect the rights and property of OEC.
· During emergency situations.
· Where the personal data is publicly available.
· If a business transfer or change in ownership occurs and the disclosure is necessary to complete the transaction. In these circumstances, we will limit data sharing to what is absolutely necessary and we will anonymize the data where possible.
· For additional purposes with your consent where such consent is required by law.
INTERNATIONAL TRANSFERS
Where permitted by applicable law, we may transfer the personal data we collect about you to the United States and other jurisdictions that may not be deemed to provide the same level of data protection as your home country, as necessary to perform our employment contract with you and for the purposes set out in this Privacy Notice.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
• We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe;
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US; or
• Where we transfer your personal data between the OEC Group of companies, we have implemented adequate safeguards in the form of an Intra Group International Transfer Agreement, including the Standard Contractual Clauses for processors approved by European Commission Decision C(2010)593, among all of the OEC Group of companies to secure the transfer of your personal data to the United States and other jurisdictions.
Please contact us at privacy@oeconnection.comif you want further information on the specific mechanism used by OEC when transferring your personal data out of the EEA.
HOW DO WE ENSURE THE SECURITY OF YOUR DATA?
OEC has put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We further require all our third-party service providers to implement appropriate security measures to protect your personal data consistent with our policies and any data security obligations applicable to us. We take all reasonable measures to ensure that our third-party service providers do not use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We have also put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
HOW LONG WE WILL USE YOUR PERSONAL DATA?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirementsor as necessary to resolve disputes.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us at privacy@oeconnection.com.
In some circumstances you can ask us to delete your data: see the Request erasuresection below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correctionof the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing of your personal data based on your consent before it was withdrawn. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us at privacy@oeconnection.com.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.Reasonable access to your personal information will normally be provided at no cost.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
If for some reason access is denied, we will provide an explanation as to why access has been denied.
CHANGES TO THIS PRIVACY NOTICE
We reserve the right to update this Privacy Notice at any time. If we would like to use your previously collected personal data for different purposes than those we notified you about at the time of collection, we will provide you with notice and, where required by law, seek your consent, before using your personal data for a new or unrelated purpose.
CONTACT US
If you have any questions about our processing of your personal data or would like to make an access or other request, please contact us at:
OR VIA MAIL AT:
Clifford Thames (Holdings) Ltd
Springfield Lyons House
Springfield Lyons Approach
Chelmsford
Essex
United Kingdom
You have the right to make a complaint at any time to with the data protection authority in your jurisdiction We would, however, appreciate the chance to deal with your concerns before you approach the data protection authority, so we hope that you will please contact us in the first instance.
Effective Date: May 25, 2018
