BRITISH MOTORS

PRIVACY POLICY

Policy relating to the Personal Data (Privacy) Ordinance (“Privacy Policy”)

We, British Motors Limited (“BML”) are committed to protecting your personal data privacy. This Privacy Policy is intended to explain our privacy practices.

By providing your personal data to us, you are consenting to this Privacy Policy and to the collection, use, access, transfer, storage and processing of your personal information as described in this Privacy Policy.

Collection of Personal Data

“Personal data” refers to any data which directly or indirectly identifies you as an individual. We collect and use personal data that we believe to be relevant and necessary to conduct our business with you. The types of personal data we collect may include, but not limited to:

Contact information such as your name, email address, mailing address, telephone number, and fax number;
Unique identifiers such as your HKID and passport number; and
Billing information such as your credit card number, bank account information, and billing address.

If you choose not to provide your personal data to us, you will in most cases still be able to use most of our website. However, we may not be able to provide you with all of our products or services or access to certain parts of our website which may require registration.

Use of Personal Data

Your personal data may be used for the following purposes:-

(a) purchase of our products/services;
(b) processing your application for and providing vehicle insurance and/or financing or leasing of vehicles;
(c) arranging for the maintenance, repair and other after-sale services of vehicles;
(d) implementing product recalls;
(e) providing you with warranty updates;
(f) assessment, maintenance and improvement of our services (including without limitation, conducting service experience surveys);
(g) providing you with customer service and responding to your queries, feedback or claims;
(h) conducting market analysis, statistical or other surveys, research and studies;
(i) direct marketing. Please refer to the section “Direct Marketing” below for further information;
(j) retention of proper business and customer records. Please refer to the sections “Disclosure of Personal Data”, “Storage of Personal Data” and “Date Retention” below for further information;
(k) detecting, investigating and preventing activities that may be against the law; and
(l) for compliance with any applicable laws and regulations.

Direct Marketing

We intend to use your personal data for direct marketing carried out by BML and provision of important vehicle updates, and for such purposes your personal data held by BML may be provided to Jaguar Land Rover Limited and our affiliated companies in the automobile sector for such use. The intended kinds of personal data to be used and the intended classes of marketing subjects are specified below. However, we may not so use or provide your personal data unless exempted by the Personal Data (Privacy) Ordinance (“the Ordinance”) or we have received your consent.

For the above direct marketing use, BML, Jaguar Land Rover Limited and our affiliated companies in the automobile sector may use your name and contact information for the following marketing subjects:

1. the supply of our products and/or services which we may offer to you or you may require from us from time to time;
2. the provision of important vehicle updates from time to time; or
3. marketing, promotional and customer relationship management purposes, such as sending you updates on latest offers and promotions in connection with our products and services and conducting market research.

You can always opt-out free-of-charge by contacting our Customer Experience Department, British Motors Limited at 11/F Tower B, Manulife Financial Centre, 223-231 Wai Yip Street, Kwun Tong, Kowloon, Hong Kong or by email to us if you no longer wish any of your personal data to be used in any of the described direct marketing purposes.

Disclosure of Personal Data

Personal data supplied to BML will be kept confidential. However, we may disclose such data to or such data may become accessible or known to, the following persons or in the following circumstances:

(a) our agents, service providers and consultants who process data on our behalf, provide maintenance services of our database or data entry services or who otherwise provide us with technical support;
(b) our employees who need to know such data in order to process it for us or for the performance of their duties;
(c) Jaguar Land Rover Limited and our affiliated companies in the automobile sector for purposes mentioned above and for direct marketing purposes (subject to any consent requirement relating to “Direct Marketing” above);
(d) our professional advisers including financial advisers and legal advisers;
(e) in cases where it is required by law or law enforcement agencies or a court order;
(f) when we believe in good faith that disclosure is necessary to protect your safety or the safety of others or for the detection, investigation or prevention of illegal activities including fraud; or
(g) as a result of a sale, merger, acquisition, consolidation, group reorganization, change of control, liquidation, or transfer of our assets.

Without prejudice to the foregoing, we may also transfer your personal data (including your name, email address and phone numbers) and information and service history relating to all Jaguar Land Rover vehicle(s) currently and/or previously owned by you to Jaguar Land Rover Limited, the manufacturer of Jaguar Land Rover vehicles based in the U.K., and our affiliated companies in the automobile sector, for the purpose of market analysis, research, surveys and other similar activities organized by such entities. For the aforesaid purpose, any such entities may contact you by telephone, email and/or SMS and disclose your personal data and relevant vehicle information to its officer(s), employee(s), principal(s), agent(s), contractor(s) and professional adviser(s) acting for it in connection with such purpose.

Further, your personal data will be transferred to and held on the information technology systems and database of Jaguar Land Rover Limited, Inchcape Hong Kong Limited, and other companies within the British Motors group, Inchcape group or Jaguar Land Rover group which handle the hosting, storage, retention or processing of data for BML. Please refer to the sections “Storage of Personal Data” and “Date Retention” below for further information.

Other disclosure of your personal data will only be undertaken after we have obtained your prescribed consent, or as may be required by law.

Storage of Personal Data

Due to the international nature of our business, we may process and store your personal data outside Hong Kong. We may therefore transfer your personal data to Jaguar Land Rover Limited, Inchcape Hong Kong Limited, and other companies within the British Motors group, Inchcape group or Jaguar Land Rover group which handle the hosting, storage, retention or processing of data for BML, within or outside Hong Kong for data processing and storage. This may involve a transfer of your personal data to a jurisdiction where the level of personal data protection may be different. We will use our best endeavours to procure the potential transferees to prevent unauthorized or accidental access, processing, erasure, loss or use of the personal data transferred to them.

Data Retention

Unless there is a specific legal requirement for us to keep the data, we will take all reasonably practicable steps to erase, and procure the transferees of your personal data to erase, your personal data that is no longer required for the purposes for which the data was originally collected.

Commitment to Data Security

Security is our top priority. We take appropriate steps to ensure that your personal data will be protected. We use a variety of physical, technological and organizational measures to safeguard and secure your personal data from unauthorized or accidental access, processing, erasure or other use.

Please however note that no data transmission over the Internet can be guaranteed to be completely secure. As such, we do not guarantee the security of any data that you transmit to us or receive from us over our website.

Other Information Collected

We may collect anonymous information about how you have used our website by means of cookies. We may also collect anonymous information about the referring website (for example Google search) or the referring banner which leads you to our website. Such information collected does not personally identify you but may be helpful to us for marketing purposes or improving the services we provide.

Changes to the Privacy Policy

We will post on our website at www.jaguar.com.hk / www.landrover.com.hk any changes to our Privacy Policy, so that you will know from time to time updates to our Privacy Policy.

Access to and Correction of Personal Data

You are entitled to request access to personal data held by us about you and to correct such data. In accordance with the terms of the Ordinance, we may charge a reasonable fee for the processing of such data access or correction requests.

You may direct your request in writing to Customer Experience Department at 11/F Tower B, Manulife Financial Centre, 223-231 Wai Yip Street, Kwun Tong, Kowloon, Hong Kong or by email to us.