PRIVACY POLICY

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Lada4x4 and Niva Imports:

We respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you contact us, for example:

• by phone, post or email;
• via a contact form on one of our websites;
• by a post or direct message on social media; or
• by speaking to a retailer about one of our products.

This notice will also tell you about your privacy rights and how the law protects you.

Purpose of this privacy notice

This privacy notice aims to give you information on how we collect and processes your personal data when you contact us by any of the methods outlined in paragraph 1.

Our social media pages and websites are not intended for children and we do not knowingly collect data relating to children unless such information is disclosed by a parent or guardian when contacting us.

Data Controller

• Lada4x4 and Niva Imports is the controller of personal data collected in respect of its branded products. Blackheath Developments Ltd is responsible for all associated social media pages and websites including lada4x4.co.uk.

We have appointed a Data Privacy Manager to oversee compliance with this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, or if you require more detail about the legal bases for processing your personal data please contact the Data Privacy Manager using the details set out in paragraph 10 below.

Third-party links

Our websites and social media pages may include links to third-party websites, plug-ins 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 statements. When you leave our website or social media pages, we encourage you to read the privacy notice of every website you visit.

Personal data, or personal information, means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data including first name, last name, marital status, title, date of birth and gender.
• Contact Data including address, email address and telephone numbers.
• Transaction Data including details of products you have purchased which are manufactured by us.
• Profile Data including your interests, preferences, behaviours, hobbies, activities, household or lifestyle information, feedback, opinions and survey responses.
• Health Data including details of your health and wellbeing, illness or injury.
• Technical Data including internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the websites.
• Usage Data including information about how you use our websites and social media pages.

We may also aggregate and/or 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.

Sensitive personal data

“Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place a Data Protection Policy and safeguards which we are required by law to maintain when processing such data.

We do not knowingly collect any other “special categories” of personal data about you (including e.g. details about your race or ethnicity or criminal convictions).

If you fail to provide personal data

If you contact us but you fail to provide certain personal data when requested, we may not be able to help you, investigate the issue raised or respond to or resolve your complaint or query. We will notify you if this is the case at the time.

We collected personal data about you from the following sources:

(1)          From You. You may give us your Identity, Contact, Transaction Data by corresponding with us by post, phone and email or via a contact form on one of our websites or a message on social media.

(2)          Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources including:

• Identity, Contact, Profile and Transaction Data from third parties such as a finance or insurance company in connection with our products, if you ask for details of your complaint, query or feedback to be passed to us for investigation or resolution.
• Technical Data from analytics providers such as Google;
• Identity, Contact, Profile and Transaction Data from third parties such as fraud prevention agencies based within the UK who may gather information from publicly available sources such as Companies House and the Electoral Register or from social media.

(3)          Automated technologies or interactions. As you interact with our websites or social media pages, 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 cookies policy for further details.

How we use your personal data

We will only use your personal data when the law allows us to. We have set out below a description of all the ways we may use your personal data, and which of the legal bases we rely on to do so.

Purpose/ActivityLawful basis for processing, including basis of legitimate interestTo enable us to investigate and deal with your complaint, question, feedback or compliment(a) Necessary to comply with a legal obligation
(b) Necessary for our legitimate interests (for quality monitoring and improvements, to carry out an investigation, to take appropriate action and to provide a meaningful response)
(c) Necessary for the establishment, exercise or defence of legal claims.To provide feedback to the business on the performance of our products.(a) Necessary for our legitimate interests (for quality monitoring and product improvements, new product development and investigations)
(b) Necessary for the establishment, exercise or defence of legal claims.To check for fraud or malicious or unfounded claims(a) Necessary for our legitimate interests (prevention of fraudulent claims)
(b) Necessary for the establishment, exercise or defence of legal claims.To manage our relationship with you which will include:
(a) Providing you with updates and a response to your question or complaint.
(b) Notifying you about changes to our privacy policy
(c) Asking you to leave a review or take a survey(a) Necessary to comply with a legal obligation
(b) Necessary for our legitimate interests (keeping you information as to the progress of your question or complaint, to keep our records updated and to study how consumers use our products)To administer and protect our business and websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligationTo use data analytics to improve our website Necessary for our legitimate interests (to keep our website updated and relevant)

Generally we do not rely on consent as a legal basis for processing your personal data and we do not need your consent if we use special categories of your personal information in accordance with this policy to carry out our legal obligations.

In certain limited circumstances, we may also process other special category data with your explicit written consent or where you have already made the information public.

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.

Marketing

We do not use and will not share with any external third parties, any of the information you have given us via means of contact including websites or social media pages for direct marketing purposes without obtaining your express opt-in consent.

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 our websites may become inaccessible or not function properly. For more information about the cookies we use, please see our cookies policy.

Change of purpose

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 contact us.

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.

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.

We may have to share your data with third parties, including third-party service providers..

We will only share your personal information with third parties where required by law or where we have another legitimate interest in doing so. The categories of third party with whom we share information are as follows:

• Third party service providers who provide our IT software and systems.
• Service providers who provide social media services.
• Professional advisers acting as processors or joint controllers including lawyers, auditors and insurers who provide ad hoc legal, auditing and insurance services.
• Rarely, advisors and fraud prevention agencies acting as processors to provide fraud detection services.

We will also share your personal information internally as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, for system maintenance support and hosting of data and to provide legal and audit services.

All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.

Some of our third party suppliers transfer or process your personal data outside the EEA. To help ensure that your personal information receives an adequate level of protection, we have put in place the following appropriate measures to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU and UK laws on data protection:

(1)          standard contractual clauses approved by the European Commission decision for the transfer of personal data to processors established in third countries from time to time; or

(2)          when sending data to the United States of America, the US-EU Privacy Shield.

If you require further information about these protective measures, please contact the Data Privacy Manager.

We will make every effort 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 have put in place procedures to deal with any suspected personal data breach and will notify you and the applicable regulator, the Information Commissioner’s Office (ICO), of a breach where we are legally required to do so.

How long will you use my personal data for?

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 or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In most cases, we will keep your personal data for a period of three (3) years from the year of collection.

Under certain circumstances, by law you have the right to:

1. Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
2. Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
3. Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
4. Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
5. Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
6. Request the transfer of your personal information to another party.
7. 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 help you, investigate the issue raised or respond to or resolve your complaint or query. We will advise you if this is the case at the time you withdraw your consent.

In some circumstances there may be specific legal reasons why we are not able to comply with your request to exercise your rights. Where this is the case, we will inform you of this.

If you wish to exercise any of the rights set out above, please contact the Data Protection Manager in writing.

You will not usually have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

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.

Time limit to respond

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.

Full name of legal entity and contact details:

Data Privacy Manager

Lada4x4 and Niva Imports
mark.key@blackheathdev.com

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

We reserve the right to make changes to this privacy notice at any time.

This version was last updated on 30 January 2021.

If you have any questions about this privacy notice, please contact the Data Privacy Manager.