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Privacy & Legal

The Agnew Group has made every effort to ensure the accuracy of the information contained in this site, and whilst every effort is made to produce up to date products and specifications, this site should not be regarded as an infallible guide to our vehicles products and services, nor does it constitute an offer for the sale of any particular vehicle.

1.1 This policy was last updated on the 1st July 2026.

1.2 This privacy policy ("policy") describes what types of personal data Isaac Agnew Holdings Limited and companies within the Agnew Group (referred to throughout this policy as "Agnew Group""we" , "us" or "our") collect from you, when, how and why it is collected, used and disclosed and how it is kept secure when you use our websites and when you purchase a vehicle and/or goods or services from us.

1.3 References to a ‘website’ means any website owned and operated by or on behalf of any Agnew Group entity including websites of our dealerships.

1.4 Full details of Isaac Agnew Holdings Limited and companies within the Agnew Group are listed in this policy under Section 18 (Which Agnew Group Companies are covered by this policy?)

1.5 It is important that you read this policy together with any other privacy policy 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. This policy supplements the other policies and is not intended to override them.

1.6 Our websites/services are not directed at individuals under the age of 16. We may verify age or obtain parental consent where appropriate.

1.7 It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us by contacting us using the details in Section 20 (How to contact us or make a complaint).

1.8 We process your personal data in accordance with the UK General Data Protection Regulation (‘UK GDPR’) and the Data Protection Act 2018 (‘DPA 2018’), including the principles of lawfulness, fairness, transparency, purpose limitation, data minimisation, accuracy, storage limitation, integrity and confidentiality, and accountability. We are accountable for demonstrating compliance with these principles and maintain appropriate records of processing activities.

The contents of this policy may change from time to time. We will post any updates to this policy on our website www.agnewcars.com/legal/. You may wish to check this page to ensure you are still happy to share your personal data with us. Where we make material changes to this policy, we will also contact you directly to notify you of these changes.

If you provide us with personal data on behalf of someone else for example you provide your spouse’s name on a loan car form to allow the vehicle to be insured for them to drive, you confirm to us that you have their permission to pass their personal data to us and that they are aware of the contents of this policy and do not have any objection to our processing their personal data in accordance with this policy.

4.1 A ‘controller’ is a person or organisation who decides why and how your personal information is collected, used and shared. They are responsible for ensuring that the processing complies with data protection legislation. This policy covers Isaac Agnew Holdings Limited and companies ‘controllers’ within the Agnew Group see Section 18 (Which Agnew Group Companies are covered by this policy?) for more information.

4.2 Depending on your interaction with us, different Agnew Group companies may act as independent controllers or joint controllers. Where two or more Agnew Group companies jointly determine the purposes and means of processing, they will act as joint controllers and allocate responsibilities in accordance with Article 26 UK GDPR. Further details of the specific controller responsible for your data will be provided at the point of data collection or within your contractual documentation.

5.1 Personal data means any information about a living individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data) or technical data about a vehicle. We collect and process personal data about you which we have grouped together into different types of data to make it easier for you to understand what we do with your personal data and what our legal basis is for processing the personal data. Details of how we process your personal data and why are set out in Section 10 (How we will use your personal data, and our basis for doing so) and details of the legal bases we rely on to process your personal data, are set out in Section 9 (What is the legal basis for processing your personal data):

5.1.1 Contact Data – details of your name(s), home address, previous home address, home phone number (including mobile), home email, work address, work phone numbers (including mobile) and social media username/identifier;

5.1.2 Identity Data – details of your passport, drivers’ licence, date of birth, utility bills, national insurance number and nationality. We will capture metadata (signer’s name, IP address, timestamps and view history, etc.) to validate an eSignature on remote signed documentation. Where biometric identifiers or document verification tools are used (e.g. ID validation), we will ensure that appropriate safeguards are in place and that processing is proportionate and necessary;

5.1.3 Financial Data – details of your bank account, bank statements, payment card details, vehicle purchase agreement, your employment history and salary where necessary. If you purchase an extended warranty or service plan your bank details for example, will be required to set up a payment plan by direct debit;

5.1.4 Transaction Data – details about payments to and from you and other details of products and services you have purchased from us;

5.1.5 Website Data - our web servers store as standard details of your browser and operating system, the website from which you visit our websites, the pages that you visit on our websites, the date of your visit to the website, web browsing behaviour, demographics and statistics and the internet protocol (IP) address assigned to you by your internet service provider. For more details about how we collect your personal data through the use of cookies please see Section 16 (Cookies and how we use these to process your personal data);

5.1.6 Location Data – details of your travel history or home address will be collected if a loan car/demonstrator has a vehicle tracker fitted or you have used the satellite navigation system in the vehicle provided by the Agnew Group. Location data may also be captured if you check your vehicle in remotely for servicing via our self-service app to provide directions to the dealership. The vehicle manufacturer may also collect telematics data if the software is installed in your vehicle, this type of data is not under our control, and you should refer to the manufacturers privacy policy for further details regarding the use;

5.1.7 Image Data – photographic images and footage of you may be collected via the operation of CCTV when you come into our showrooms or visit our dealerships. We may take photographs or videos of you at dealership events for marketing purposes or when you collect your vehicle with your consent. We do not record customer calls made via video apps therefore no image data is retained in this format;

5.1.8 Vehicle Data – details of your number plate are collected using automatic number plate recognition technology (where ANPR is in operation) when you drive into our dealership for a pre-booked service. You will provide details of your vehicle to us to make a service booking although not personal data this will be the make, model and type of vehicle;

5.1.9 Audio Data – details of telephone voice calls may be recorded for monitoring, customer support, dispute resolution, and training purposes when you contact us, or we contact you from our dealership landlines and/or our contact centres. We transcribe land line calls using AI tools, to process vehicle sales enquiries, and to aid customer service and engagement. Outbound mobile telephone calls or calls made from video calling apps are not recorded;

5.1.10 Social Network Data – details of personal data that is part of your public profile on a third-party social network may be collected if you like, follow, message, share content, post opinion or comment on any of our Agnew Group social media pages;

5.1.11 Family Data – details of your direct family such as their name for example to purchase a vehicle for them and allow the vehicle to be registered to the correct keeper;

5.1.12 Chat Data – conversations you may have with our digital assistant via live chat windows on our websites, text messages, WhatsApp or apps. We may retain chat data on our systems for a short period of time after the conversation is terminated, but only where necessary;

5.1.13 Public Authority Data – details about you and your vehicle held with the driving and vehicle licencing agency (DVLA) including any penalties you may have on your driving licence. Should you incur a fixed penalty or fine when driving a loan vehicle, we will share your contact details with the respective third party, police or local authority. We may have a legal obligation to share your details with a public authority;

5.1.14 Analytics Data – this is personal data on how you interact with us, this may relate to your vehicle choice or current vehicle, how you use and engage with our services, apps or websites or to allow us to predict when your vehicle is due for maintenance, servicing or renewal.

5.2 Where we process special category data (e.g. health or vulnerability information), we will only do so where a specific condition under Article 9 UK GDPR applies, such as explicit consent or where necessary for compliance with a legal or regulatory obligation.

5.3 We do not collect the following special categories of personal data about you, details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and information about your health or genetic and biometric data. Nor do we collect any information about criminal convictions and offences unless these are held against your driving licence.

In limited circumstances for example if you lease a vehicle via the third-party Motability scheme, we may collect details about your disability and mobility allowance to administer your application and check your eligibility to join the scheme. For further details about this scheme please visit Motability’s website. There may be isolated circumstances where we process special categories of personal data for the purpose of a vehicle sale and/or service, specifically if we need to adapt a vehicle or make reasonable adjustments if you have identified as vulnerable.

We may also record details of potential or actual vulnerability that you provide to us or that we identify as required to fulfil our obligations to you and the Financial Conduct Authority and our lender partners, Any such information we record may be provided to any lenders who we refer you to consider finance for your vehicle. Some lenders will require us to confirm whether we consider you to be vulnerable from our dealings with you.

5.4 We may collect and process information we receive about you from third parties. This information may include your personal and financial information, your employer, companies that you are connected with (such as a Director) or other person connected with your finance application; information about the vehicle you are purchasing; credit information, such as previous applications, any business accounts you have and public information such as county court judgments, bankruptcies and the electoral register.

5.5 The Agnew Group ensures your personal data is responsibly handled and your privacy is of great importance to us. We also carefully consider your privacy rights when designing new state of the art systems across our business. In some cases, we use Artificial Intelligence (“AI”) to analyse and improve our processes. The use of AI and other new technologies benefits the services we provide. We have taken steps to ensure the responsible use of new technology, which is closely monitored. We may gain insights and analysis of our customers’ behaviour using such tools. 

5.6 We also use AI and automated tools to support customer service, sales processes, analytics, and communications. These tools can analyse personal data such as communication content, browsing behaviour, and engagement patterns.

AI tools assist decision-making but do not make solely automated decisions that produce legal or similarly significant effects on individuals. Human oversight is applied to all decisions.

We assess AI systems for fairness, accuracy, and data protection risks and apply appropriate safeguards.

5.7 We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated or anonymous 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 and is not covered by this policy. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with a vehicle, goods or services). In this case, we may have to cancel your vehicle order, or product or service you have with us but we will notify you if this is the case at the time.

7.1 Personal data you have given to us. We collect personal data when you provide this to us directly in the scenarios listed below:

7.1.1 by entering personal data via our websites, live chat boxes, social media platforms, apps or other digital platforms;

7.1.2 through testimonials and opinions, you may have posted publicly on our websites, social media platforms or on third party platforms such as Google or Trustpilot;

7.1.3 when you contact our customer service teams, dealerships or our call centres;

7.1.4 on an enquiry form during a showroom, manufacturer or third-party event that you have attended;

7.1.5 when you reserve a vehicle or use our buy online service through our websites;

7.1.6 when you register interest in a vehicle in one of our dealerships either face to face, through social media or by phone or by digital assistant, or filling in forms in our websites;

7.1.7 when you complete customer surveys, provide feedback or participate in competitions we run online on social media and in our dealerships;

7.1.8 when you place any order for our goods, products or services for example when you purchase a vehicle or book an appointment for your vehicle to be serviced in our dealership. We require your personal data for these specific purposes to fulfil a contract with you;

7.1.9 when you apply for a loan, personal contract purchase, hire purchase or lease agreement from one of our accredited finance providers to fund the purchase your vehicle;

7.1.10 when you part exchange or sell your vehicle to us;

7.1.11 when you provide documents to evidence your vehicle is covered by a valid insurance policy prior to collection;

7.1.12 if you would like a courtesy vehicle or wish to test drive a vehicle, we ask for you to provide a copy of your current driving licence;

7.1.13 if you provide another family members personal details for example in relation to a vehicle purchase or for vehicle collection after servicing;

7.1.14 when you respond to an advertisement or any other promotional communication we may have sent to you, communicated via social media or other digital platform;

7.1.15 to gain an estimate from our body shop for repairs to your vehicle;

7.1.16 if you create an online customer account on one of our websites, save vehicle searches or check out as a guest;

7.1.17 if you make a complaint about our dealership or exercise or rights;

7.1.18 if you join our loyalty or VIP programmes, we will capture and process your information;

7.1.19 by corresponding with us by phone, email, in person, What’s App, chat bot or otherwise (for example via social media) for any other purpose.

7.2 Personal data we may receive from within the Agnew Group. We collect the personal data from the Agnew Group of companies in the scenarios listed below:

7.2.1 for accounting, financial or intragroup reporting purposes;

7.2.2 to handle complaints, aid, or to provide information you have requested;

7.2.3 when we acquire or dispose of a business, we may share your personal data with another dealership in our group who trade under the same brand;

7.2.4 for marketing analysis or to improve our customer facing services or digital platforms;

7.2.5 for customer feedback and support;

7.2.6 for IT to support, maintain and secure our internal systems;

7.2.7 for fraud prevention, tax, audit, regulated or legal purposes.

7.3 Personal data we may receive from vehicle manufacturers. We collect the personal data from vehicle manufactures in the scenarios listed below:

7.3.1 if you have requested a brochure, test drive, specific detail about a vehicle or registered an interest in a vehicle the manufacturer will share your personal information with our dealership;

7.3.2 if you have clicked on vehicle adverts or offer on the vehicle manufacturers or other third-party websites controlled by the vehicle manufacturer and then completed an enquiry form your personal details will be shared with Agnew Group to follow up your enquiry;

7.3.3 if you have ordered a vehicle online with the vehicle manufacturer via their website, your vehicle order details will be shared with our respective dealership to fulfil the order;

7.3.4 to provide vehicle support services for repairs, servicing, warranty, cosmetic or in the event of safety recall;

7.3.5 in the event of vehicle break down, the manufacturer may provide your personal details to us to recover and/or repair the vehicle;

7.3.6 if you book your vehicle in for servicing online via the vehicle manufacturer’s website, your personal details will be automatically shared with us to complete the required works at our dealership;

7.3.7 if you exercise your rights to access, to erasure, etc. as detailed in section 11 (What rights do you have under data protection legislation), you provide feedback about our dealership or you make a complaint about our dealership we will receive notification from the vehicle manufacturer;

7.3.8 for dispute resolution, complaint, feedback or legal matters.

7.4 Personal data we may receive from finance providers and brokers. We collect the personal data from finance providers in the scenarios listed below:

7.4.1 if you have engaged a third-party broker to act on your behalf to administer the purchase of a vehicle;

7.4.2 if your vehicle finance application has been declined, the lender will advise us of their decision but not provide the reason;

7.4.3 vehicle finance settlement details with your consent, unless we have a lawful basis to source the information from the lender, such as, a vehicle rejection request, direct sale of your vehicle, or purchase of a new vehicle. We need to know how much finance is outstanding to make an offer to buy the vehicle;

7.4.4 our approved finance providers have a legitimate interest to provide your details to Agnew Group to allow us to contact you to discuss your options during the term of the loan contract. For example, if you have a Personal Contract Purchase (PCP) contract which is about to end in 6 months we will discuss all your options with you such as how to pay the balloon payment, changing your vehicle or returning your vehicle to allow you to make an informed decision before the contract ends;

7.4.5 if you have leased a vehicle through a finance partner, or you purchased your new vehicle directly via the vehicle manufacturer we may handle your vehicle collection or delivery and servicing needs;

7.4.6 to defend, respond to or prosecute legal claims, directed to us or the lender;

7.4.7 if you have financed vehicle repair or service works through a third-party, Bumper International Limited (“Bumper”), we require evidence of cleared funds from Bumper to release the vehicle;

7.4.8 for compliance, audit, tax, fraud, money laundering, complaint resolution and other legal purposes where required.

7.5 Personal data we may receive from insurance providers. We collect the personal data from insurance providers in the scenarios listed below:

7.5.1 if you have been involved in an accident, we may receive details from your insurer about the vehicle to arrange recovery;

7.5.2 when we are required to carry out authorised repairs on your vehicle as part of a claim you have made through your insurance company for the purposes of carrying out those repairs and providing you with a loan car;

7.5.3 they may ask us to provide further information to support a dispute, claim or to fulfil a legal obligation.

7.6 Personal data we may receive from regulatory bodies. We collect personal data from regulatory bodies in the scenarios listed below:

7.6.1 from the Driver and Vehicle Licencing Agency (DVLA) to confirm if you hold a valid driving licence to allow the provision of a loan car or a test drive;

7.6.2 Ombudsman or other UK regulators if you have made a complaint about our dealership, vehicle finance or the handling of your personal data.

7.7 Personal data we may receive from other public sources. We collect personal data from the following public sources in the scenarios listed below:

7.7.1 to assist the police or other public authorities with their enquiries and/or investigations.

8.1 Third parties we share data with may act as either independent controllers or processors depending on the service provided. Where they act as processors, they are contractually bound to process personal data only on our documented instructions.

8.2 Where third parties act as independent controllers (e.g. finance providers, vehicle manufacturers), their use of your personal data will be governed by their own privacy notices.

8.3 We share your personal data with the Agnew Group of companies as set out in Section 18 (Which Agnew Group companies are covered by this notice?) for the following purposes:

8.3.1 for sending communications or direct marketing to customers by brand;

8.3.2 for accounting purposes your personal data is included on invoices;

8.3.3 to allow us to verify your identity to handle complaints, provide customer support, to fulfil your rights or to access information you have requested;

8.3.4 for intragroup sales, operations and/or reporting, financial, tax or auditing our business operations;

8.3.5 when we restructure or sell our business or its assets or have a merger or re-organisation;

8.3.6 to monitor emails, calls or other communications for compliance and training purposes;

8.3.7 for establishment and defence of legal claims;

8.3.8 for marketing analysis and to improve our websites and digital platforms;

8.3.9 for feedback and market research purposes;

8.3.10 to combat fraud and protect our business, we will use your personal data to implement security measures such as multi-factor-authentication, and to investigate and prevent any suspected fraudulent activity across Agnew Group.

8.4 We share your personal data with the respective vehicle manufacturer listed in Section 19 (List of manufacturers with whom we share your personal data) because the Agnew Group is an authorised retailer for these manufacturers. A link to each manufacturer’s privacy notice can be found next to their name in this policy. The personal data is shared for the following purposes:

8.4.1 to fulfil your order for a vehicle;

8.4.2 for warranty purposes relating to your vehicle and to set up in car systems or linked vehicle apps;

8.4.3 to help with complaint resolution and for product feedback;

8.4.4 to diagnose and fix problems with your vehicle;

8.4.5 where you have provided your consent, for marketing communications. Please see Section 13 (Using your personal data for marketing and how to opt-out) for details about how you withdraw your consent to marketing.

8.5 We share your personal data with our accredited finance providers for the following purposes:

8.5.1 to allow our finance lenders to conduct credit history checks with your consent;

8.5.2 to administer your vehicle finance application on your behalf with our accredited finance providers. Agnew Group is a credit broker and not a finance lender;

8.5.3 for the finance lender to decide if they wish to offer you a credit facility in order to purchase a vehicle and/or vehicle related services from us;

8.5.4 if you make a vehicle finance application directly via our websites, your personal data will be automatically shared with the respective finance lenders when you submit your application online for consideration;

8.5.5 where you have identified as vulnerable, we have a legal obligation to share this information with the prospective lender;

8.5.6 for fraud prevention, verification of your identity, detection and investigation of financial crime, including fraud, money laundering, complaint resolution and to establish or defend legal claims.

We process information relating to your finance application on behalf of Agnew Group’s approved finance providers who are acting as independent data controller’s.

8.6 We share your personal data with our insurance providers for the following purposes:

8.6.1 if you decide to purchase additional regulated or non-regulated products or services during the sale or after the sale of your vehicle, we may pass your personal data to the relevant provider to fulfil your request. For example, if you purchase an extended vehicle warranty for your vehicle we will pass your personal data to the respective provider;

8.6.2 if you have been offered a complimentary drive away insurance policy with your vehicle purchase, the respective insurance provider will require your personal data to set up the temporary policy prior to vehicle collection;

8.6.3 to insure a courtesy or loan vehicle for the duration of the signed agreement;

8.6.4 for your insurance provider to accept the costs to repair your vehicle in our body shop;

8.6.5 for health and safety, crime or fraud prevention, customer disputes or legal matters.

8.7 We do not sell your personal data to third parties. However, we may from time to time disclose your personal data to the following categories of companies or organisations to which we pass the responsibility to handle services on our behalf:

8.7.1 roadside assistance service providers;

8.7.2 vehicle collection, delivery or logistics companies to transport a vehicle;

8.7.3 external third-party body shops or body shop system providers;

8.7.4 marketing companies who run and manage marketing campaigns;

8.7.5 events companies who run and manage sponsored or dealership events;

8.7.6 cloud service providers who facilitate IT platforms;

8.7.7 card payment providers who operate secure payment platforms;

8.7.8 market research and market analytics service providers;

8.7.9 and consultants with whom we have an agreement, external auditors, law firms and other professional advisors.

8.8 We may transfer your personal information to a third party as part of a sale of some or all 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 employees, visitors and customers. However, we will always take steps with the aim of ensuring that your privacy rights continue to be protected.

8.9 We take steps to ensure that any third-party partners who handle your personal data comply with data protection legislation and protect your personal data 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 personal data or use aggregated nonspecific data sets wherever possible.

9.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

9.1.1 Contractual performance – where we need to process your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering such a contract.

9.1.2 Legal or regulatory obligation – when we must process your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

9.1.3 Legitimate interest – where we rely on legitimate interests, we carry out a legitimate interest assessment to ensure that our interests are balanced against your rights and freedoms. For example, we may rely on legitimate interests to improve our services, prevent fraud, for direct marketing and to maintain customer relationships.

9.1.4 Vital interests – where it is necessary to process your personal data to protect your vital interests or another person.

9.1.5 Consent – generally we do not 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 us using the contact details set out in Section 20 (How to contact us or make a complaint).

10.1 Each processing activity is subject to defined retention periods and safeguards, and you may exercise your rights in respect of any activity listed below.

10.2 We have set out in a table format, a description of all the ways we use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

10.3 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 using the contact details set out in Section 20 (How to contact us or make a complaint) if you need details about the specific legal grounds, we are relying on to process your personal data where more than one ground has been set out in the table below.

10.4 We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please us using the contact details set out in Section 20 (How to contact us or make a complaint). If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

10.5 Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

When you are making an enquiry or negotiating to buy a vehicle
Processing activity Type of data Legal Basis

To respond to enquiries, you send to us and fulfil the requests you make to us for example to provide detail of the vehicle specification you have enquired about.

 

Contact data / Audio data / Social Network data / Website data / Chat data / Vehicle data Contractual performance / legitimate interest

If you enquire about a used vehicle, we may send via our provider citNOW a video presentation by email which shows the vehicle in detail in the footage.

 

Contact data /Vehicle data Contractual performance / legitimate interest

When you provided your personal information either to the vehicle manufacturer or to a third-party website to enquire about a vehicle advertised for example Auto trader or Car Wow. Your personal data will be forwarded to a Agnew Group dealership to follow up your request.

 

Contact data / Website data / Vehicle data Legitimate interest / Consent

If you reserve a vehicle online through our website.

 

Contact data / Transactional data / Website data / Analytics data / Financial data Contractual performance / Legitimate interest

To arrange a test drive we have a legal obligation to check you hold a valid driving licence as required by law and for insurance purposes.

 

Contact data / Identity data / Public Authority data / Family data (e.g. if a family member wishes to test drive the vehicle) Contractual performance / Legal or regulatory obligation

Photographic images and footage of you is collected via the operation of CCTV when you come into our showrooms or visit our dealerships. This is for security, crime prevention and required for insurance purposes.

 

Image data Legitimate interest·      Public interest

If you contact us directly for a vehicle valuation and proceed with the direct purchase of your vehicle.

 

Contact data / Vehicle data / Website data / Identity data / Location data Legitimate interest / Contractual performance
Purchasing a vehicle
Processing activity Type of data Legal Basis

Completion of all mandatory sales documentation to purchase a vehicle and make payment non-finance

 

Contact data / Identity data / Vehicle data / Transaction data / Identity data / Financial data / Family data if applicable Contractual performance

To share your personal data with manufacturer systems to allow vehicle ordering, in car systems setup, and activation of services and products for the vehicle including warranty

 

Contact data / Vehicle data / Family data if applicable Contractual performance

To administer the manufacturer’s complimentary insurance on your behalf (if applicable to that manufacturer)

 

Contact data / Identity data / Family data if applicable Contractual performance / Legal or regulatory obligation

Registering and taxing the vehicle with the DVLA

 

Contact data / Vehicle data / Identity data Contractual performance / Legal or regulatory obligation

To provide or manage any information, products or services you have asked for specifically related to the purchase of your vehicle for example the purchase of a GAP policy or paint protection product.

 

Contact data / Vehicle data / Identity data (if applicable) / Transaction data Contractual performance / Consent

If you are part exchanging / selling your vehicle to our dealership or buyers we will check your vehicle details via third-party provider CAP-HPI this includes vehicle mileage, condition, outstanding finance and history before making an offer to buy the vehicle.

 

Vehicle data / Contact data / Website data (if applicable) Contractual performance / Legal or regulatory obligation

If you are purchasing an electric vehicle, we may share your contact details to install a charging point at your home address.

 

Contact data / Vehicle data Consent / Performance of a contract

We will send a customer survey to you following your vehicle purchase to gain your feedback about our products and services provided.

 

Contact data / Analytics data Legitimate Interest

Purchasing a vehicle with finance

The processing activity detailed in the table below is in addition to ‘purchasing a vehicle’ if you would like Agnew Group to arrange finance for you.

Processing activity Type of data Legal Basis

To administer and arrange finance for you to purchase or lease a vehicle remotely or in the dealership.

 

Contact data / Vehicle data / Identity data / Financial data / Audio data / Transactional data Legal or regulatory obligation / Performance of a contract / Legitimate interest

When you apply online for vehicle finance via our websites.

 

Contact data / Vehicle data / Identity data / Financial data / Website data / Transactional data / Analytics data Legal or regulatory obligation / Performance of a contract / Consent

Completion of all documents to comply with the financial conduct authority guidelines when administering finance on your behalf.

 

Contact data / Vehicle data / Identity data / Financial data / Transactional data Legal or regulatory obligation

Agnew Group will enter your personal details directly into the finance lenders system which allows the respective finance provider to then conduct a credit check and affordability assessment on you before making a decision whether to offer you a credit facility to fund your vehicle.

 

Contact data / Vehicle data / Identity data / Financial data / Transactional data Contractual performance / Consent / Legitimate interest
Vehicle maintenance, repairs and servicing
Processing activity Type of data Legal Basis

Inbound vehicle service or maintenance bookings by any medium.

 

Contact data / Vehicle data / Audio data / Website data / Analytics data Contractual performance

To contact you to book an appointment to bring your vehicle into the dealership which may fall under your service contract or service plan for your vehicle.

 

Contact data / Vehicle data / Transactional data /Audio data Contractual performance

Automated check-in by SMS for vehicle servicing, repairs or MOT bookings.

 

Contact data / Vehicle data / Location data Contractual performance

To collect or deliver your vehicle outside our dealership for example to collect your vehicle from your home or work address to undertake service works on the vehicle. This service maybe outsourced to an approved third-party vehicle delivery company.

 

Contact data / Vehicle data Contractual performance

Creation of service documentation and billing for the works conducted to your vehicle.

 

Contact data / Vehicle data / Transactional data Contractual performance

Arranging a courtesy car subject to availability. If we agree to provide a courtesy vehicle to you for the duration of the works on your vehicle you will be asked to provide a copy of your driving licence. This is for insurance purposes and to ensure you hold a valid driving licence. If you incur any speeding, parking or other motoring offences when using the vehicle, you will be liable for all costs, and we will forward your contact data to the third party enforcing the penalties.

 

Contact data / Vehicle data / Identity data / Location data (if a Tracker is fitted to the vehicle) / Public Authority data Contractual performance / Legal or regulatory obligation

Aftersales, we will contact you in relation to all on-going servicing, repairs and maintenance of your vehicle, including manufacturer warranty claim.

 

Contact data / Vehicle data / Audio data / Website data / Analytics data Contractual performance / Legitimate interest

Rectification works to your vehicle as part of an insurance claim. Your insurance provider may request your vehicle is repaired by one of our approved body shops and they will share your personal information with Agnew Group for this purpose.

 

Contact data / Vehicle data Contractual performance / Legitimate interest

We may capture your vehicle registration number when you drive onto our dealership premises using ANPR to recognise you in relation to your service booking.

 

Contact data / Vehicle data/ Image data Contractual performance / Legitimate interest

Breakdown assistance, your personal details are provided by the breakdown provider to Agnew Group to complete the repairs for example the AA towed your vehicle to our dealership for repair.

 

Contact data / Vehicle data Contractual performance / Legitimate interest

We will notify you when your vehicle is due for servicing or MOT as a duty of care. The legal responsibility for maintaining the vehicle in line with the manufacturer’s guidelines is with you.

 

Contact data / Analytics data / Vehicle data / Voice data Contractual performance / Legitimate Interest

To contact you if there is an urgent safety or product recall notice issued by the manufacturer to arrange rectification works at our authorised dealership.

 

Contact data / Vehicle data Vital interest

To sell you vehicle parts or accessories.

 

Contact data / Vehicle data / Transactional data / Identification data (e.g. if you are purchasing a replacement key for the vehicle) Performance of a contract
Processing necessary for us to promote our business and engage with our customers
Processing activity Type of data Legal Basis

Personalise the marketing and offers you receive from Agnew Group through various channels, including email, post, SMS, phone and digital channels such as websites, apps and social media.

 

Contact data / Analytics data / Website data / Social Network data / Vehicle data / Transaction data Consent (e.g. for device information cookies & similar technologies / Legitimate interest

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.

 

Social Network data / Website data / Analytics data Consent (e.g. for device information cookies & similar technologies / Legitimate interest

To identify and record when you have received, opened or engaged with our website or electronic communications.

 

Contact data / Social Network data / Website data / Analytics data Legitimate interest

To administer competitions and promotions that you enter with us from time to time and to distribute prizes.

 

Contact data / Social Network data / Image data Consent

To undertake market analysis and research (including contacting you with customer surveys) so that we can better understand you as a customer and provide tailored offers, products and services that we think you will be interested in.

 

Contact data / Transactional data / Voice data / Analytics data Legitimate interest

We may take photographic images of you when you collect your new vehicle from the dealership or record video footage during dealership events with your consent to promote our business via social media channels or via our websites.

 

Image data / Contact data Consent

Assess the effectiveness of the marketing activities of the Agnew Group

 

Contact data / Analytics data / Website data / Social Network data / Transactional data Legitimate interest·      Consent (e.g. for device information cookies & similar technologies

Use Agnew Group customer data matches to identify relevant audiences and find them on digital channels for the purposes of marketing.

 

Contact data / Analytics data / Social Network data / Website data Consent (e.g. for device information cookies & similar technologies
Processing necessary for our business to operate and fulfil data protection laws
Processing activity Type of data Legal Basis

For general administration and accounting purposes.

 

Contact data / Audio data / Vehicle data / Transactional data / Identity data / Chat data Contractual performance / Legitimate Interest / Legal obligation

Processing necessary for us to operate technical aspects of our business efficiently and effectively.

 

Contact data / Vehicle data / Transactional data / Website data / Analytics data Contractual performance / Legitimate Interest

For network and information security purposes i.e. for us to take steps to protect your personal data against loss, damage, theft or unauthorised access and to protect our business.

 

Contact data / Identity data / Image data / Financial data / Website data / Analytics data Legitimate interest

Providing customer service support, including verifying your identity, and for purposes of training and process improvement.

 

Contact data / Vehicle data / Transactional data / Audio data / Identity data / Financial data /Website data / Social Network data / Chat data Legitimate interest / Contractual necessity / Consent

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)

 

All types of data depending on the request Legal or regulatory obligation

To allow the creation and maintenance of your online account on one of our websites and to save vehicle searches.

 

Contact data / Website data / Analytics data / Vehicle data / Social Network data (if applicable) Performance of a contract / Legitimate interest / Consent (e.g. for device information cookies & similar technologies

To inform you of updates to our terms and conditions and policies.

 

Contact data Legal or regulatory obligation / Contractual performance

Compliance with all other legal obligations, we use your personal data to meet our contractual and legal obligations.

 

All types of data depending on the request Legal or regulatory obligation

 

11.1 Under certain circumstances, you have rights under data protection laws. These are set out below:

11.1.1 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.

11.1.2 The right to request correction of 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.

11.1.3 The right to 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.

11.1.4 The right to 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.

11.1.5 The right to 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 over riding legitimate grounds to use it.

11.1.6 The right to 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.

11.1.7 The right to 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 carried out before you withdraw your consent. 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.

11.2 If you wish to exercise any of the rights set out above, please contact us using the details set out in Section 20 (How to contact us or make a complaint) or click on this link to complete the respective online web form.

11.3 We aim to make exercising your rights simple, accessible, and free of charge. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We will not refuse requests without a clear and lawful justification.

11.4 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 for further information in relation to your request to speed up our response. The timeline for response will be paused until receipt of the additional information from you. If we do not receive this additional information from you within the specified period, we have the right to refuse your request.

11.5 We try to respond to all legitimate requests within one calendar month of receipt, in accordance with legislation. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated via our secure privacy portal provided by OneTrust.

11.6 You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at any time.

12.1 We use a variety of security measures, including encryption and authentication tools, to help protect and maintain the security, integrity and availability of your personal data.

12.2 Although data transmission over the Internet or website cannot be guaranteed to be secure, we and our business partners work hard to maintain physical, electronic and procedural safeguards to protect your personal data in accordance with applicable data protection requirements. Our main security measures are:

12.2.1 restricted personal access to your data on a 'need to know' basis and for the communicated purpose only;

12.2.2 highly confidential data stored in encrypted form;

12.2.3 firewalled IT systems to prohibit unauthorised access e.g. from hackers;

12.2.4 we require all of our service providers to have appropriate measures in place to maintain the security of your personal data; and

12.2.5 permanently monitored access to IT systems to detect, prevent and stop misuse of personal data.

Where we have given you (or where you have chosen) a password that enables you to access any personalised area in a Agnew Group website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

It is your responsibility to ensure that your desktop or mobile device is virus protected. We accept no responsibility for any loss you may suffer as a result of accessing and downloading information from our websites or from within communications we send to you.

In the event of a personal data breach, we will assess the risk and, where required, notify the Information Commissioner’s Office and affected individuals in accordance with UK GDPR.

13.1 Electronic marketing communications (e.g. email, SMS) are sent in compliance with the Privacy and Electronic Communications Regulations (PECR).

13.2 If you are wondering why you have received a marketing communication from us, this is because we collected your personal data when, for example, we were negotiating a vehicle sale, you asked us for a quotation, reserved a vehicle or you booked your vehicle into our workshop for maintenance works.

13.3 You have the right at any time to opt out or update your preferences in terms of the marketing you receive from us and the way we communicate with you. You can change your marketing preferences, or withdraw your consent in relation to how Agnew Group use your personal information in one of the following ways:

13.3.1 if you receive marketing emails and don’t want to in the future, please use the ‘unsubscribe’ link within the email footer and we will remove you automatically from future dealership campaigns; or

13.3.2 by completing the respective web-based form on the Agnew Group website to object to the processing for marketing purposes; or

13.3.3 by sending an email data@agnews.co.uk; or

13.3.4 by writing to us at Data Privacy & Compliance Team, Agnew Group, 18 Boucher Way, Belfast, BT12 6RE.

14.1 Retention periods are determined based on legal obligations, regulatory requirements, limitation periods, and business needs.

14.2 Details of retention periods for different aspects of your personal data are available throughout this policy. We provide a snapshot below of our group data retention policy for your information:

14.2.1 vehicle sales or service documentation up to 7 years all formats, unless we have a legal obligation to retain sales documentation for longer periods;

14.2.2 electronic communications by email may be held for up to 3 years;

14.2.3 CCTV if retained by the dealership for up to 30 days;

14.2.4 landline telephone calls only may be recorded up to period of 12 months.

Your personal data will be securely deleted/destroyed after the time periods specified above have expired. We do not guarantee electronic data retained in communications will be held for the specified periods above.

Our websites may include links to third-party websites and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy notices and statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Social plug-ins are integrated into our websites from social networks such as Facebook, You Tube, Instagram, LinkedIn and X. When you visit our websites, the social plug-in is deactivated, therefore no personal data is transmitted to the operators of the respective plug-in. If you want to use one of the social networks, click on the respective social plug-in to establish a direct connection to the server of the respective network.

If you have a user account on the social network and are logged in when you activate the social plug-in, the network can associate your visit to our website with your user account. If you want to avoid this, please log out of the social network before activating the social plug-in. A social network cannot associate a visit to other Agnew Group websites until you have activated an existing social plug-in.

When you activate a social plug-in, the network transfers the content that becomes available directly to your browser, which integrates it into our websites. In this situation, data transmissions can also take place that are initiated and controlled by the respective social network. Your connection to a social network, the data transfers taking place between the network and your system, and your interactions on that platform are governed solely by the privacy policies of that social network.

A social plug-in will remain active until you deactivate it or delete your cookies (see section 16).

If you activate a social plug-in, you do so at your own risk, personal data may reach providers in countries outside the UK/European Union that may not guarantee an "adequate level of protection" for the processing of personal data in accordance with UK/EU standards. Please remember this fact before activating a social plug-in and thereby triggering a transfer of your personal data.

Cookies may be used when you are visiting our websites. Technically, these are so-called HTML cookies and similar software tools such as Web/DOM Storage or Local Shared Objects (so-called "Flash cookies"), which we collectively refer to as cookies.

Cookies are small files that are stored on your desktop, notebook or mobile device while you visit a website. Cookies make it possible, for example, to determine whether there has already been a connection between the device and the website; consider your preferred settings, offer you certain functions (e.g. to save vehicle search history) or recognize your usage-based interests. Cookies may also contain personal data.

Whether and which cookies are used when you visit our websites depends on which areas and functions of our websites you use and whether you agree to the use of cookies that are not strictly necessary. You will find further information in the Agnew Group Cookie Policy and decision-making options by clicking on the button below.

Cookie Settings

You will be asked to set cookie preferences when you access one of our websites for the first time via the Cookie banner on the front screen. When you re-visit our websites, we may ask you to update your cookie preferences periodically.

The use of cookies also depends on the settings of the web browser you are using (e.g., Microsoft Edge, Google Chrome, Apple Safari, Mozilla Firefox). Most web browsers are pre-set to automatically accept certain types of cookies; however, you can usually change this setting. You can delete stored cookies at any time. Web/DOM storage and local shared objects can be deleted separately.

Cookies are tied to the device and to the respective web browser you use. If you use multiple devices or web browsers, you can make decisions or settings differently.

If you decide against the use of cookies or delete them, you may not have access to all functions of our websites or individual functions may be limited. 

Where we transfer personal data outside the UK, we ensure an adequate level of protection by:

• Using UK International Data Transfer Agreements (IDTAs) or Standard Contractual Clauses (SCCs);
• Conducting transfer risk assessments where required;
• Ensuring supplementary safeguards are applied where necessary.

Isaac Agnew Holdings Limited is registered in Northern Ireland under Company number: NI00668 and headquartered in Belfast. The Agnew Group is part of the Sytner Group.

The following Agnew Group companies are covered by this policy. All these companies have their registered office address at 18 Boucher Way, Belfast, BT12 6RE:

18.1 Companies trading within the Agnew Group

18.1.1 Isaac Agnew Limited No: NI010842. Isaac Agnew Limited is directly authorised by the Financial Conduct Authority (FCA) for consumer credit activities under Firm Reference Number (FRN) 687467. Isaac Agnew Limited is also an Appointed Representative of Sytner Group Limited, which is authorised and regulated by the FCA for Insurance Mediation Activities, under FRN 310540.

18.1.2 Agnew Leasing Limited No: NI011916. Agnew Leasing Limited is directly authorised by the Financial Conduct Authority (FCA) for consumer credit activities under Firm Reference Number (FRN) 687475. Agnew Leasing Limited is also an Appointed Representative of Sytner Group Limited, which is authorised and regulated by the FCA for Insurance Mediation Activities, under FRN 310540.

18.1.3 IAPCB Limited No: NI020068. IAPCB Limited is directly authorised by the Financial Conduct Authority (FCA) for consumer credit activities under Firm Reference Number (FRN) 686197. IAPCB Limited is also an Appointed Representative of Sytner Group Limited, which is authorised and regulated by the FCA for Insurance Mediation Activities, under FRN 310540.

18.1.4 Agnew Commercials Limited No: NI013173. Agnew Commercials Limited is directly authorised by the Financial Conduct Authority (FCA) for consumer credit activities under Firm Reference Number (FRN) 672959. Agnew Commercials Limited is also an Appointed Representative of Sytner Group Limited, which is authorised and regulated by the FCA for Insurance Mediation Activities, under FRN 310540.

18.1.5 Trade Parts Specialist (NI) Limited No: NI064523.

We share your personal data with the respective vehicle manufacturer listed in alphabetical order below. For information about how each manufacturer collects, uses and processes your personal data please click on the relevant privacy notice link for further information.

19.1 Audi UK 

19.2 BMW Group UK

19.3 Daimler Group (UK) Limited

19.4 MINI

19.5 Porsche Cars Great Britain Limited

19.6 Skoda

19.7 Smart see Daimler UK privacy notice link under clause 19.3

19.8 Volkswagen UK

19.9 Volkswagen Commercial Vehicles

19.10 Volvo Cars UK Limited

20.1 We have a designated Data Protection Team who are responsible for overseeing data protection for the Agnew Group. If you have any questions about this policy, your rights under data protection legislation as set out in Section 11 (What rights you have under data protection legislation) or the processing of your personal data generally you can contact us free of charge at any time by using the details below:

20.1.1 by completing the respective web-based form on the Agnew Group website;
20.1.2 by sending an email to our Data Privacy & Compliance Team data@agnews.co.uk;
20.1.3 by writing to us at Data Privacy & Compliance Team, Agnew Group, 18 Boucher Way, Belfast, BT12 6RE.

20.2 If you are dissatisfied with our use of your personal data or our response to any exercise of these rights you have the right to complain to your data protection authority, this in the UK is the Information Commissioner's Office (ICO) ico.org.uk.

20.3 Isaac Agnew Holdings Limited is registered with the ICO as a data controller under reference Z6467482.

 

End of Policy