Last Updated: June 2020
This Privacy Notice provides you with information about how we will handle your personal information whenever we deal with you and including when you use the following websites and apps which we provide:
- https://guarantees.lifeshine.com – our LifeShine guarantee dealer registration portal.
- any of our local Autoglym distributor websites
together, our "Websites",
- the Autoglym app; and
- the LifeShine app,
together, our "Apps".
Autoglym is committed to protecting and respecting your privacy and complying with data protection laws. This Privacy Notice sets out the basis on which any personal information we collect from or about you, or that you provide to us, will be processed by us. Please read the following carefully to understand the personal information we hold about you, how we use your information and who we share it with. The data controller of the personal information referred to in this Privacy Notice is Altro Limited of Works Road, Letchworth Garden City, Hertfordshire SG6 1NW and with company number 00154159 and 'Autoglym' is an Altro brand.
We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material changes to our Privacy Notice if and where this is required by data protection laws. You can see when this Privacy Notice was last updated at the top of the page.
1. Information We Collect
Where you are a consumer, we also use information provided by the Driver and Vehicle Licensing Agency (DVLA) to provide the "MY GARAGE" feature of the Autoglym App which provides reminders of your MOT and Tax renewal dates and also for our LifeShine portal to enable your dealer to automatically retrieve your car's make, model, colour and vehicle identification number when your car's licence plate number is inserted.
2. Information you provide voluntarily
In using our Websites or our Apps, you may voluntarily provide us with personal information in the following ways:
- Account creation. Some of our Websites and Apps enable you to create an account with us. Where you wish to set-up an account, you will need to provide us with the account registration information which we request (which may include your name, address, contact details and a password). We will use this information to create and administer your account and to process orders for products which you make using your account. If allowed by law, we will also use your contact information to contact you about your requirements and to send you information about products that you may be interested in – for more information about this, please see section 5.
- Buying products. In order to process any orders which you place through our Websites or Apps, we will need to collect delivery information (such as delivery address, contact person, contact telephone number etc.), as well as payment information which will be processed by Sage Pay
- Signing-up to our Newsletter. We ask you on our Websites whether you want to "Sign up" to receive information from us. Where you enter your personal information into this box we will use that personal information to send you the latest case studies, events updates and product news.
- Surveys & contests. Our Websites may request information from users via surveys, contests or for a particular service (e.g. newsletter). Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose this information. Information requested will include contact information and supplementary information on your professional interests, opinions and preferences (e.g. choice of publications, working practices, opinions on industry issues, feedback). We will only use the contact information to administer responses to our surveys and to notify winners. We will use your responses to our surveys to personalise your experience of using our Website and to send you relevant information which is tailored to you and your interests. We will only send you offers based on survey responses where you have provided your consent to us or where the law allows us to do so.
- Product, blog and site comments and feedback. In order to leave a comment on our Websites you have to give us at least your name and email address, which we require name and email address for quality control purposes.
- Contact Us. From time to time, you may wish to contact us with queries or complaints regarding our products and services, including in relation to your account. You may contact us through a variety of channels including e-mail, letter, phone or through our social media channels. When you contact us and provide us with your contact information (such as your name, user name, address, email address and telephone number) and details of your query or complaint. We will use this information to administer your query or complaint and to improve our service in the future. We will manage and record your query or complaint using our Customer Relationship Management (CRM) system, as explained further at section 5 below.
- Registration of your LifeShine guarantee by your dealer. If you have purchased our LifeShine guarantee, your dealer will enter your personal details into our LifeShine portal in order to register your LifeShine guarantee on your behalf. We will also ask your dealer at this point to confirm whether you consent to receiving marketing communications from us.
- Dealership Knowledge Centre. We collect the personal information of staff from dealers who use our Dealership Knowledge Centre (http://knowledgecentre.lifeshine.com/login/) where they request to view a gated article. We may also ask them whether they wish to receive additional information in future from us.
- Autoglym Professional Customers. If you are an Autoglym Professional customer, you will have provided your contact information to your Autoglym Franchisee who will enter your details into our systems so that we can create an account for you.
- Autoglym Academy and the Autoglym Registered Operators Scheme. If you purchase academy training online (or using our Customer Care Centre), we will store details of your accreditation and any formal assessment, individual test scores and responses to any assessed work. We will use this information to offer successful candidates access to the Registered Operators Scheme which is an Autoglym backed promotional scheme which you can apply for using AutoglymProfessional.com or through one of our Autoglym franchisees. If the course is accredited by another organisation, we will pass this information to them to record your accreditation. If you receive an accreditation and only use Autoglym products, we will also collect additional information about your business (including the channels through which you trade, number of vehicles processed, types of vehicle processed, services offered and number of employees). We will use this information to provide you with materials which you can use to promote your business in conjunction with Autoglym
3. Our use of your information
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
We will normally collect personal information from you only where we need the personal information to perform a contract with you, where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms or where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.
Where we collect and process your information for our legitimate interests, this will normally be to operate our Website and App and communicating with you as necessary to provide our products and services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our Website and App, undertaking marketing or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests and we will make clear to you at the relevant time what those legitimate interests are.
Where you have provided us with your contact details, we will use these to send you marketing communications by phone and post and also by e-mail where you have provided your consent or where the law allows us to do so. You can opt-out of receiving marketing communications from us at any time by using the opt-out link at the bottom of every email or by contacting us using the contact details at section 10.
If we ask you to provide personal information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
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 goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
4. Email communications
As explained above, we may send you marketing communications or newsletters by email, either where you have actively consented to these, or where we are entitled to do so by law.
If at any stage you no longer wish to receive these types of email, please use the opt-out link at the bottom of every email or contact us using the contact details provided at section 10.
To opt-out of any other types of marketing (such as postal marketing or telemarking), then please contact us using the contact details provided at section 10.
Please note that even where you have opted-out of marketing communications, we may still need to send you service messages, for example, a confirmation email about a product you have ordered.
5. Telephone communications
When you telephone us your call may be recorded for training and quality purposes. We will only do this in order to make sure that our teams are operating as well as they can, allowing us to provide you with our greatest level of customer service. This data is used only by us for improving the quality and performance of our product and service. We will also record the fact that we have spoken with you on our CRM so that we have a record of your call and can manage our relationship with you.
6. Our disclosure of your information
We do not sell or rent any of your personal information to any third party. However, your personal information may be shared with or disclosed to third parties from time to time, as described in this section.
We may disclose your personal information to the following categories of recipients:
- Our Autoglym Professional services are a collaboration between us and our Franchisees, and as such, if you are an Autoglym Professional user, your personal information will be shared between us and your local Autoglym Franchisee. Some of the circumstances in which information will be shared include (each in relation to Autoglym Professional only):
- if you sign-up during a sales meeting with your Franchisee, the relevant information will be disclosed to us;
- your personal information may also be made available to your local Autoglym Franchisee as part of our service delivery model (please note that your Autoglym Franchisee is likely to be a separate controller of your personal information);
- Franchisees may choose to upload special discounts for their existing customers who become Autoglym Professional users;
- products ordered for normal (non-express) delivery will be fulfilled by our Franchisees, and details of your order will therefore need to be disclosed to the relevant Franchisee;
- your order history and statistical information about your use of Autoglym Professional may be provided to your local Franchisee so that they have a better understanding of your needs; and
- details of a new web-only Autoglym Professional account will be provided to your local Franchisee for the purposes of managing your account locally, including making sales calls.
- any of our distributors who provides our products or services to you the country in which you are located in order to manage any enquiry or complaint which we receive from you. If you contact or deal direct with one of our distributors, they will collect and process your information in accordance with data protection laws and they will be the data controller of any information which you provide to them.
- to our third party service providers who provide data processing services to us (for example, to support the performance of our Website and our App, and enhance the security of our Website and our App, to send you e-mails and to provide you with materials, products and services that you have ordered or requested from us).
- to your dealer where you make a claim under your LifeShine guarantee in order to allow your claim to be processed and to improve the quality of our service;
- to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
- to a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice;
- to any other person with your consent to the disclosure.
We store and process your personal information within the European Economic Area ("EEA"). However, if at any time we need to make an ad-hoc or ongoing transfer of your personal information outside of the EEA, we will take steps to ensure that the information receives the same level of protection as if it remained within the EEA, including by entering into data transfer agreements, using the EU Commission approved Standard Contractual Clauses, or by relying on certification schemes such as the EU - US Privacy Shield. You may have a right to details of the mechanism under which your data is transferred outside of the EEA.
If you would like more details of the mechanism under which your data is transferred outside of the EEA, please contact us using the contact details in section 10.
When you allow cookies and tracking technologies to be used when visiting our Websites and our Apps, your information may be used by other companies such as Facebook and Google. You can find out more information about the other organisations which may have access to your personal information from your use of our Websites and our Apps in our Cookies Policy which also provides information on how you can manage and disable cookies and tracking technologies.
7. Security of your information
We employ appropriate technical and organisational security measures in an effort to protect your personal information from unauthorised access, improper use or disclosure, unauthorised modification or unlawful destruction or accidental loss. However, it is important to remember that no web based platform can be 100% secure and we cannot be held responsible for unauthorised or unintended access that is outside of our control.
If we become aware of any breach of your personal information, we will take steps to promptly assess and remediate the breach. Where appropriate, and in accordance with our legal obligations, we may also take steps to notify you about the breach, in particular where we believe that the breach has resulted in a high risk to your rights and freedoms.
8. Retention of your information
We only keep personal information only for as long as required to fulfil the purposes for which it was collected. However, in some circumstances we may retain personal information for longer periods of time, for instance where we are required to do so in accordance with legal, tax and accounting requirements. For example, in order to provide our LifeShine guarantee, LifeShine guarantee registrations will be retained by us until we are informed that the ownership of the vehicle to which the guarantee relates has been transferred or the vehicle has been written off. We may also keep a copy after this period to manage any claim which you or we may have in respect of the LifeShine guarantee until the limitation period for any claim has expired.
In specific circumstances we may also retain your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
9. Your rights
You have the following rights in respect of your personal information:
- If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details in section 10.
- In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details in section 10.
- You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the "unsubscribe" or "opt-out" link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details in section 10.
- Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
In some circumstances we will 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.
We will respond to and manage any requests which you make in relation to the rights set out above in accordance with data protection laws. In addition to the above, you have the right to lodge a complaint with your local data protection authority or the Information Commissioner's Office which regulates our processing of your information in the United Kingdom - you can find contact details for data protection authorities in EU countries here. We are keen to address any issues with our use of your personal information or the exercising of your rights, and in the first instance we would ask that you attempt to resolve the problem with us directly.
In relation to all of these rights, please contact us using the details given below. Please note that we may request proof of identity, and we reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
10. Contact us
If you have any questions about this Notice, or any queries or complaints about how your personal information is used, or if you wish to exercise any of your information rights, please contact us by email at email@example.com.