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Privacy Policy

1. Scope

All data subjects whose personal data is collected, in line with the requirements of the GDPR.

2. Responsibilities

2.1 The management team is responsible for ensuring that this notice is made available to data subjects prior to David Manners Group (DMG) collecting/processing their personal data. DMG businesses are DMG, Abingdon MG Parts Ltd, Mini Spares Centre (Midlands) Ltd and The Morris Minor Centre (Birmingham). 

2.2 All Employees/Staff of DMG who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secured.

3. Privacy notice

3.1 Who are we?

The David Manners Group comprises of four of the most established market leaders in the car parts industry.

We supply parts for modern and classic Jaguar & Daimler, MG & Triumph, Mazda MX5, Classic Mini and Morris Minor cars.

Our management team and data protection representatives can be contacted directly here:

katie.storey@davidmanners.co.uk

3.2 The personal data we would like to collect from/process on you is:

Personal data type:

Source (where DMG obtained the personal data from if it has not been collected directly from you, the data subject. Note if the personal data has been accessed from publicly accessible sources)

Name
Address
Telephone Number
Age
Payment Information
Location
People whom purchases have been dispatched to
Content of reviews
Emails to us
Phone conversations with us
Information and documents regarding identity
Credit information history
Login email addresses and passwords

Purchase and content use history which we sometimes aggregate with similar information from other customers to create features such as best sellers


The full uniform resource locators (URL) click stream to through and from our website (including time and date)


Cookie number
Products and content you viewed or searched for, page response times, length of visit for web pages, page interaction information (such as scrolling, clicks and mouse overs)
Phone numbers used to call us

Information from other sources including; updated delivery and address information from our carriers or other third parties

Carriers or third parties




3.3 Our legal basis for processing personal data:

Processing is necessary for DMG to meet contractual obligations or to take steps to enter into a contract e.g. provide a quote or complete an order.

Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child. This includes direct marketing, fraud prevention, internal administration and market research.

3.4 What purposes does DMG process your personal information?

We process your personal information to operate, provide and improve the services that we offer to our customers. These purposes include:

  • Purchase and delivery of products and services - We use your personal information to take and handle orders, deliver products and services, process payments and communicate with you about orders, products and services and promotional offers across all of our brands. 
  • Provide, troubleshoot and improve services - We use your personal information to provide functionality, analyse performance, fix errors and improve usability and effectiveness of services.
  • Recommendations and personalisation - We use your personal information to recommend products and services that might be of interest to you, identify your preferences and personalise your experience with us. 
  • Comply with legal obligations - In some cases we have a legal obligation to collect and process your personal information. For instance we collect from buyers and sellers information regarding place of establishment and bank account information with identity verification and other purposes. 
  • Communicate with you - We use your personal information to communicate with you in relation to DMG via different channels (e.g. phone, email, post and social media live chat).
  • Advertising- We use your personal information to send you interest based advertising for products and services that might be of interest for you. 
  • Fraud prevention and credit risks - We process personal information to prevent and detect fraud and abuse in order to protect the security of our customers DMG and others. 
  • Purposes for which we seek your consent - We may also ask for your consent to process your personal information for a specific purpose that we communicate to you. When you consent to our processing of your personal information for a specified purpose, you may withdraw your consent at any time and we will stop processing your data for that purpose.

3.5 How will DMG protect your information?

All information held is on a secure server. The secure server software (SSL) encrypts all information you input before it is sent to us. Here at our premises the information is also held in secure form and is not accessible to anyone outside of DMG staff. This provides many security features.

Authentication: This assures your browser that your data is being sent to the correct computer server, and that the server is secure. 

Encryption: This encodes the data, so that it cannot be read anywhere other than the secure server.

Data integrity: This checks the data being transferred to ensure it has not been altered. Communication between the merchant’s site server and real credit occurs via the internet using the simple commerce messaging protocol (SCMP). SCMP uses DES and public key cryptography to provide privacy, message authentication, no-repudiation and integrity. SCMP messages are digitally signed and converted to ASCII format (“armoured”) from transmission over a Hyper Text Transfer Protocol (HTTP) connection, enabling messages to pass though firewalls and proxy servers

Furthermore, as required by the UK Data Protection Act, we follow strict security procedures in the storage and disclosure of information which you have given us, to prevent unauthorised access. 

It is important for you to protect against unauthorised access to your password and your computers. Be sure to sign off when you finish using a shared computer. 

3.6 Consent

By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified.

Consent is required for DMG to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used. 

You may withdraw consent at any time by contacting katie.storey@davidmanners.co.uk.

3.7 Disclosure

DMG will not pass on your personal data to third parties without first obtaining your consent. The following third parties will receive your personal data for the following purpose(s) as part of the processing activities:

Third country (non-EU)/international organisation

Safeguards in place to protect your personal data

Retrieve a copy of the safeguards in place here:

DHLPrivacy StandardsAvailable on website
APC DirectPrivacy StandardsAvailable on website


3.8 Retention Period

DMG will process personal data and will keep your personal information to enable your continued use of DMG for as long as it is required in order to fulfil the relevant purposes described in this privacy notice, as may be required by law such as for tax and accounting purposes, or as otherwise communicated to you. For example we retain your transaction history so that you can review past purchases (and repeat orders if required) and what addresses you have orders shipped to and to improve the relevancy of products. 

3.9 Your rights as a data subject

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

  • Right of access – you have the right to request a copy of the information that we hold about you.
  • Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
  • Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
  • Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
  • Right of portability – you have the right to have the data we hold about you transferred to another organisation.
  • Right to object – you have the right to object to certain types of processing such as direct marketing.
  • Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
  • Right to judicial review – in the event that DMG refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.10 below.

All of the above requests will be forwarded on should there be a third party involved (as stated in 3.7 above) in the processing of your personal data.

3.10 Complaints

In the event that you wish to make a complaint about how your personal data is being processed by DMG (or third parties as described in 3.7 above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and DMG’s data protection representatives management team.

The details for each of these contacts are: 


GDPR Owner Contact Details
Contact NameKatie Storey
Address Line 1991 Wolverhampton Road
Address Line 2Oldbury
Address Line 3West Midlands
Address Line 4B69 4RJ
Address Line 5
Emailkatie.storey@davidmanners.co.uk



4 Online Privacy Statement

Personal data

Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as: 

“any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

Why does DMG need to collect and store personal data?

In order for us to provide you with a service or product we need to collect personal data. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy. 

In terms of being contacted for marketing purposes DMG would contact you for additional consent.

Will DMG share my personal data with anyone else?

We may pass your personal data on to third-party service providers contracted to DMG in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on our behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with DMG’s procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.

How will DMG use the personal data it collects about me? 

DMG will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. DMG is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

Under what circumstances will DMG contact me?

Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.

Can I find out the personal data that the organisation holds about me?

DMG at your request, can confirm what information we hold about you and how it is processed. If DMG does hold personal data about you, you can request the following information: 

  • Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU. 
  • Contact details of the data protection officer, where applicable.
  • The purpose of the processing as well as the legal basis for processing.
  • If the processing is based on the legitimate interests of DMG or a third party, information about those interests.
  • The categories of personal data collected, stored and processed.
  • Recipients or categories of recipients that the data is disclosed to.
  • If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
  • How long the data will be stored.
  • Details of your rights to correct, erase, restrict or object to such processing.
  • Information about your right to withdraw consent at any time.
  • How to lodge a complaint with the supervisory authority.
  • Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
  • The source of personal data if it wasn’t collected directly from you.
  • Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

What forms of ID will I need to provide in order to access this? 

DMG accepts the following forms of ID when information on your personal data is requested: Passport, driving licence or birth certificate.

Contact details of the management team / GDPR Owner:


management team / 

GDPR Owner contact details

Contact NameKatie Storey
Address Line 1991 Wolverhampton Road
Address Line 2Oldbury
Address Line 3West Midlands
Address Line 4B69 4RJ
Address Line 5
Emailkatie.storey@davidmanners.co.uk


Document Owner and Approval

The management team & GDPR Owner is the owner of this document and is responsible for ensuring that this record is reviewed in line with the review requirements of the GDPR. 

Change History Record

IssueDescription of ChangeApprovalDate of Issue
1Initial IssueKatie StoreyFebruary 2020


















Copyright © 2017 David Manners Group. All rights reserved.

Mini Spares Midlands | 991 Wolverhampton Road | Oldbury | West Midlands | B69 4RJ