This Privacy Policy sets out the basis on which any personal data is collected from you and processed by HTK Heaven, including how we protect your data.
jhkjjhk For the purpose of the General Data Protection Regulations 2018, the Data Controller is HTK Heaven, HTK Heaven is a trading name of HTK Heaven Ltd, company is registered in England and Wales company registration number 09640565. Registered Address Arch 312, Courtenay Road, London. E11 3FE. HTK Heaven comply with new Data Protection Regulation GDPR and Data Protection Act 1998. Information Commission Office (ICO) Data Protection Registration Number ZA443288 . HTK Heaven ltd is regulated and authorised by Financial Conduct Authority. FRN Number 812456. All Rights Reserved. Revisions to the Notice will be updated here so you will always be aware of what information we collect and the legal basis for our processing.

• From that data; or
• From that data and other information which is in our possession, or is likely to come into our possession.

The normal legal basis for us processing your data is that it is necessary for the legitimate interests of HTK Heaven. We have carefully assessed these interests and balanced them with the interests of our customers to ensure fair processing e.g. processing data to facilitate the car buying journey and after sales customer care as efficiently as possible.
If you are making a finance application another legal basis is relied upon; that it is necessary for the entering into and the performance of a contract.
Upon purchasing a vehicle your personal data will be stored for up to 6 years, the legal basis being that it is a necessary for compliance with a legal obligation, as the HMRC require this for accounting purposes.
For more examples of how your personal data may be processed and the legal basis for doing so please see the separate headed section below.

The below are some of the reasons for processing customer data in-line with the legitimate interests of HTK Heaven:

• Supplying goods and services to our customers;
• mproving existing products and services and developing new products and services;
• Handling customer contacts, queries, complaints or disputes;
• Understanding our customers’ behaviour, activities, preferences, and needs in order to provide a tailored service;
• Considering job applications;
• Fulfilling our duties to our customers, colleagues, shareholders and other stakeholders; and
• Allowing our advisers to follow up our service, either by email, telephone, SMS or mail, as part of our customer care procedures;
• Promoting, marketing and advertising our products and services; and
• Sharing your data with selected third-party partners whose products and services support and describe our sales, customers, traffic patterns and other site information to prospective partners, advertisers, investors and other reputable third parties and for other lawful purposes. These statistics will include no personally identifying information.
• For the purpose of detecting fraudulent activity: data that identifies computers or other devices you use to connect to the internet. This includes your Internet Protocol (IP) address.

In particular circumstances we will also process and share your personal data in order to comply with a legal obligation, for example:


• Preventing, investigating and detecting crime, fraud or anti-social behaviour including but not limited to prosecuting offenders, including working with law enforcement agencies;
• Effectively handling legal claims or regulatory enforcement actions taken against HTK Heaven;
• Protecting HTK Heaven, its employees and customers, by taking appropriate legal action against third parties who have committed criminal acts or are in breach of legal obligations;
• Protecting customers, employees and other individuals and maintaining their health and safety;and
• Complying with any other legal and regulatory obligations that may arise.

Lastly, we will process and share your data in the following ways on the condition that your consent has been given:


• Sending promotional, offers and news related communications which are relevant and tailored to you; and
• Sharing your data with third parties so that they can communicate related products and services which may be of interest to you.

Registering for a My Account
In order to register for a My Account, a self-service user profile which allows you to manage vehicles you are interested in, you will be required to supply your full name, email address, password, postcode and mobile telephone number. Your contact details are collected to enable us to contact you directly depending on one or more of the below requests.

Call Back, Test Drive Alerts
If you would like to request a call back, book a test drive, you will be required to register for a My Account.

Live Chat and Online Form
If you use the chat service to communicate with our customer service team, you may disclose personal information in the course of using the service. All conversations and email exchanges are recorded. Any personal information that you disclose during a live chat or via an online form will be accessible to and processed by and made available to HTK Heaven. By submitting personal information to us, you are deemed to have agreed to the terms set out above regarding the use of your personal information.

Registering with us and viewing vehicles
We collect the following information by creating or updating your unique Customer Record Form (“CRF”) : name, telephone number, email, postcode, gender, your thoughts on the vehicles you have viewed, proposed method of funding the vehicle purchase, whether you require finance or part exchange and your driver’s licence details.
Due to our belief that customers should be able to view cars by themselves at their own leisure, customer’s contact details and identifying information are required to establish a record and track the possession of keys, what cars are being viewed and when. In order to facilitate a test drive, your driver’s licence number will also be recorded. If a passport or driver’s licence is scanned to auto-populate the CRF your image will be cropped onto the form. Our system will also automatically flag if your driver’s licence details do not meet our test drive requirements by checking the length the licence has been held by you and also your age. Information recorded will be primarily used to help support your car buying journey. This includes contacting you following your visit to offer assistance in the event that you have been unsuccessful in finding the right car.
Your CRF will also be relied upon in the event that a Health and Safety or Security matter requires it, where necessary CCTV operated on the HTK Heaven premises will be used in conjunction. This may include contacting you or passing on your details in the event of the emergency services requiring access to them.
Please note that most service related conversions at our service desks and on the phone are recorded for Training and Compliance purposes and are utilised in the event of addressing a complaint and to providing feedback to staff where applicable.

Finance Applications
In addition to information collected when registering and updating your CRF, in order to complete a finance proposal, the following information is required: date of birth, nationality, residence status, marital status, number of dependent children, ID type available, address, current employment details, proof of employment and previous employment details. Financial details also required include: bank details, income, expenditure, home valuation, assets valuation, whether this is a replacement loan, whether a change in your circumstances is currently expected and also the purpose of the vehicle under consideration for purchase is recorded. In submitting a finance application, your details are held and used in credit scoring or other automated decision-making processes. Your application may be submitted to multiple finance companies, their Privacy Notices are listed below and can be viewed on their website link or you may wish to call them for more information.

Post-sale
In addition to the data collected initially via your CRF, your address, the registration number of the vehicle purchased along with any additional products or services required is also collected. Your address is used to verify your identity alongside bills and other methods of identification. Any correspondence received in the course of facilitating an after-sale service will also be recorded.

For marketing communications
We will automatically contact you with regard to your services, for example, with updates to your requested alerts, applications or appointments.
Subject to your consent, we will use your personal information to contact you with information about offers, news and promotions. When you register with gcwings.co.uk or create a CRF in our showroom, we ask you whether you would like to receive offers, news or promotional marketing communications from HTK Heaven that we feel may be of interest to you and if you would like to receive third party information. In order to receive these communications, you will need to opt in during registration.
If you no longer wish to receive marketing communication from us you can log in to your My Account or call our team on 0208 597 5123 or by writing to the Data Controller, Compliance Department, 597-601 High Road Ilford, IG3 8EE. Remember that if you say you do not wish to receive any promotional material from us, this will preclude you from receiving any of our offers, news or promotions which may be of interest to you.

6. How do we protect your information?
HTK Heaven will take all reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy. Our team constantly review and improve our measures to protect your personal information from unauthorised access, accidental loss, disclosure or destruction.
Our security measures include:

• Regular scenario planning and crisis management exercises to ensure we are ready to respond to cyber security attacks and data security incidents;
• Daily testing of our security and IT systems;
• Security controls which protect the entire HTK Heaven infrastructure from external attack and unauthorised access; and
• HTK Heaven policies outlining our data security approach and training for employees.

• To employees and agents of HTK Heaven to deal with your accounts, products and services related to HTK Heaven;
• With your agreement, to additional service providers whose products and services may be of interest to you, such as mechanical breakdown insurance or exterior and interior car protection products; and
• o third parties using aggregate information and statistics for the purposes of monitoring usage of our services in order to help us develop our services, for example, to additional service partners and advertisers. These statistics do not include information that can be used to identify any individual.

• For the purposes of the prevention or detection of offences, and/or the apprehension or prosecution of offenders, we may share any information that we collect with the police, other public or private sector agencies, governmental or representative bodies in accordance with the relevant legislation. This may also include public authorities, insurance companies, finance companies, automotive advertising companies and/or other agencies;
• In order to comply with any legal or regulatory requirements;
• To finance companies, if making a finance application through HTK Heaven; and
• To credit reference agencies, if making a finance application through HTK Heaven.

• Erasure
  If you feel that there is no compelling reason for your personal data to continue to be processed you can request erasure. If consent was originally obtained this can simply be withdrawn. In other circumstances the request will be considered by the Compliance Department.
  
• Portability
  In event that data has been processed on the basis of consent or for entering into or the performance of a contract you may request to have the data provided to you in a structured, commonly used and machine readable form (usually in CSV format).
  
• Object
  If you no longer wish your data processed due to grounds relating to your particular situation, where we are relying upon legitimate interests, you can exercise your right to object. Where this is concerned with direct marketing it will be stopped immediately. Customers have the right to withdraw consent given to communications at any time.
  
• Consent
  Necessary for performance of a contract Compliance with a legal obligation Necessary for the purposes of the legitimate interests

• Make our website work as you would expect;
• Save you having to register every time you visit My Garage;
• Remember your settings during and between visits;
• Improve the speed and security of the website;
• Allow you to share pages with social networks, like Facebook;
• Continuously improve our website for you; and
• Help our marketing be more targeted to your needs.

• Collect any personally identifiable information (without your express permission);
• Collect any sensitive information (without your express permission);
• Pass personally identifiable data to third parties; or to
• Pay sales commissions.

• Strictly Necessary Website Cookies
  These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services such as:
  
  • Determining if you are logged in or not;
  • Remembering your search settings;
  • Remembering if you have accepted our terms and conditions; and
  • Remembering your preferences such as layout
  You can set your browser to block or alert you about these cookies, but some parts of the website will not then work. These cookies do not store any personally identifiable information.
  Cookies don't harm your computer. Like other online companies, we use cookies to provide you with more relevant and useful information. We don&apost store personally identifiable information such as credit card details, but we do use information gathered from cookies to help improve your experience of the HTK Heaven website.
  
• Advertising
  Cookies are widely used in online advertising. Neither us, advertisers or our advertising partners can gain personally identifiable information from these cookies. They will be used to build a profile of your interests and show you relevant adverts on other sites. They do not store direct personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.
  You can learn more about online advertising at http://www.youronlinechoices.com. You can opt-out of almost all advertising cookies at http://www.youronlinechoices.com/uk/your-ad-choices. It is also worth noting that opting out of advertising cookies will not mean you won't see adverts, just simply that they won't be tailored to you any longer.
• Third Party Cookies
  Our website, like most websites, includes functionality provided by third parties. A common example is an embedded YouTube video or pulling through Google Reviews. Disabling these cookies will likely break the functions offered by these third parties.
• Site Improvement Cookies
  From time to time we test new designs or website features. We do this by showing slightly different versions of our website to different people and anonymously monitoring how our website visitors respond to these different versions. We might also use anonymised heat mapping software to understand popular pages and specific functionality on our website. This helps us to offer you a better user experience.
• Remarketing Cookies
  You may notice that sometimes after visiting a website you see increased numbers of adverts from the site you visited. This is because advertisers, including ourselves, pay for these adverts. The technology to do this is made possible by cookies, and as such, we may place a so called “remarketing cookie” during your visit. We use these adverts to offer targeted messages to encourage you to come back to our site. However, we are unable to proactively reach out to you as the whole process is entirely anonymised and you can opt out of these cookies at any time as explained above and below.
• Social Website Cookies
  These cookies are set by a range of social media services that we have added to the website to enable you to share our content with your friends and other networks. They are capable of tracking your browser across other websites and building up a profile of your interests. This may therefore impact the content and messages you see on other websites you visit.
  If you do not allow these cookies you may not be able to use or see these sharing tools.
  The privacy implications on this will vary from social network to social network and will be dependent on the privacy settings you have chosen on these networks.
• When do our cookies expire?
  Except for essential cookies, most of the cookies on our websites expire at the end of your current session on our website. However, some of our cookies have an extended lifespan which ranges from 1 day to 26 years. Some of our cookies are persistent and will never expire. If the cookie used is a flash cookie, please note that flash cookies do not expire.

• Cookie settings in Edge - https://support.microsoft.com/en-us/help/196955
• Cookie settings in Firefox - https://support.mozilla.org/en-GB/kb/enable-and-disable-cookies-website-preferences
• Cookie settings in Chrome - https://support.google.com/accounts/answer/61416
• Cookie settings in Safari - https://support.apple.com/kb/ph21411