Liaco
is a trading name of Liaco Limited and its subsidiaries (collectively
referred to as “Liaco”, “we” or “us” in this
notice).
Overview
Maintaining the security of your data and ensuring that you are in
control of how your data is handled is a priority at Liaco. We are dedicated to
ensuring that we are transparent about the data that we collect about you, how
we use it and the conditions whereby we may disclose your data to others. We
will ensure that your data is kept secure and that you are aware of the steps
we have taken to ensure the security of your private information.
Liaco takes the security of your data very seriously and strictly
adheres to guidelines published in the Maltese Data Protection Act 1998 and the
General Data Protection Regulation 2016/679 which is applicable from 25th May
2018. Any questions relating to this notice and our privacy practices should be
sent to dataprotection@liaco.eu
This notice applies whether you visit one of our dealerships or our
websites, and aims to provide you with information about:
Personal data we collect
We will only collect relevant data to enable us to carry out the service
you have requested or accessed, below we have set out in more detail about the
personal data we collect and why we collect it. We review our retention periods
regularly and will only hold your data for as long as it is necessary for the
original purpose it was collected for, as required by law or as set out in any
relevant contract we have with you.
Service Booking
To make an online vehicle service or VRT booking via www.liaco.eu or
over the phone, we require your name, contact information and vehicle details.
This information is required so that we can arrange your booking for you at
your chosen dealer and send you your booking confirmation through your
preferred contact method (email or SMS).
If you have purchased a vehicle from Liaco or you have previously had a
service at one of our dealerships our aftersales system will have stored your
information, along with your service and VRT due date. We will send you our
yearly service/VRT reminder as we feel it will be in your Legitimate Interest
to know when these events occur. You can object to receiving these reminders at
any time.
As an existing customer, should you choose to book your next service via
our service reminder we may use a cookie to pre-populate your details to avoid
you having to type in details on subsequent visits.
Vehicle Search
When you search for a new or used vehicle on our website we may store
information on the vehicles you searched for and viewed in a cookie so that we
can provide personalised content, and suggest other vehicles you may also be
interested in.
Online Enquiry
If you enquire about one of our vehicles we require your name, email
address and contact telephone number to able us to respond to your enquiry.
Test Drive or Courtesy Car
If you book a test drive or take a courtesy car from our service
department we require a copy of your driving licence, we will store a copy of
this in case of any speeding, parking or other motoring offence that may occur.
Sell your car
If you request a valuation for your current vehicle
we require your vehicle details including registration number, mileage, plus
your name, email address and telephone number so that we can send you your indicative
valuation.
Vehicle Purchase
If you decide to purchase a vehicle from Liaco, at the point of sale
under a Contractual Obligation we will collect your full name, address, contact
number, date of birth, driving licence details, payment details, details of the
vehicle you are buying and, if applicable, details of the vehicle you will be
using as a part exchange. Your details will not be used for marketing purposes
unless you provide consent for us to do so. If you purchase a new vehicle we
will be Contractually Obliged to send your details to the manufacturer for
warranty, registration and recall purposes.
Vehicle Finance
If you require finance for your vehicle purchase, we will require
additional information including marital and housing status, number of
dependents, previous address, occupation, employer, business address and bank
details, in addition we will also require proof of address (i.e. utility bill)
and any other relevant information. With your permission this information will be
passed to our selected finance partners..
In Dealership Visit
We operate CCTV in all of our dealerships to monitor our premises,
therefore your image and vehicle registration may be captured and stored for up
to 12 months.
Competitions
If you enter one of our competitions, we require your name, email
address and telephone number so that we can contact the winner. Competitions
are subject to terms and conditions.
Contact by phone
Should you call one of our dealerships or should we contact you in
response to an enquiry, your phone call may be recorded and will be retained
for a maximum of 12 months. The recording will be used for quality and training
purposes only.
Retention
We will retain your personal data for no longer than is necessary and
usually no longer than 7 years after your contract is over (unless otherwise
required)
Liaco uses your personal data for electronic
marketing purposes and we may contact you to update you in accordance with your
selected marketing preferences.
You have the right to opt out of receiving promotion
communication at any time by;
We may use and process your personal
information where it is necessary for us to pursue our Legitimate Interest as a
business for the following purposes;
Automated Processing
When visiting our website, we may collect data
directly from you as set out in this notice, as well as analysing your browsing
and purchasing activity, both online and in dealership, along with your
previous response to marketing communications. The results of this data
(collected by Cookies) allow us to ensure that we contact you with information
on products and offers that are relevant to you. To do so, we use automated
profiling software.
Liaco recommend that you accept cookies for the
following reasons;
Website Banner Marketing
If you visit our website, you may receive
personalised banner advertisements whilst browsing other websites including but
not limited to search engines and social networking. Any banner advertisement
you will see will relate to products you have viewed whilst browsing our
website on your computer or other devices.
These advertisements are provided by Liaco
using ‘Cookies’ placed on your computer or other device. You can remove or
disable cookies at any time – see our cookies policy for more information.
Social Media
You may receive advertising based on
information about you that we have provided to the social media platform or
because, at our request, the platform has identified you as having similar
attributes to the individuals whose details it receives from us.
For the Prevention of fraud and other criminal
activities
To undertake credit checks for finance
To correspond and communicate with you
To comply with a request from you in connection
with the exercise of your rights
For example – where you have asked us not to
contact you for marketing purposes, we will keep a record of this on our
suppression list in order to be able to comply with your request.
For accuracy of data
In order to keep our data up to data and
accurate improvements made be made to our database e.g. by consolidating
records we hold about you.
General Administration
We may need to process your data to manage your
queries, complaints, or claims and may result in us contacting you by the
contact details you have previously provided.
We may use and process your personal data where
it is necessary for the performance of a contract with you or in order to take steps at your request before entering into
a contract with you including for the following purposes;
We may use your personal information to contact
you if there are urgent safety or product recall notices to communicate to you
or where we otherwise reasonably believe that the processing of your personal
information may prevent or reduce any potential harm to you.
We will use your personal data to comply with
our Legal Obligations
Collection of general data and information
Our website collects a series of general data.
This general data and information is stored in the server log files. General
data includes (1) the browser types and versions used, (2) the operating system
used by the accessing system, (3) the website from which an accessing system
reaches our website (so-called referrers), (4) the sub-websites, (5) the date
and time of access to the Internet site, (6) an Internet protocol address (IP
address), (7) the Internet service provider of the accessing system, and (8)
any other similar data and information that may be used in the event of attacks
on our information technology systems.
When using general data and information, we do
not draw any conclusions about visitors. Rather, this information is needed to
(1) deliver the content of our website correctly, (2) optimise the content of
our website as well as its advertisement, (3) ensure the long-term viability of
our information technology systems and website technology, and (4) provide law
enforcement authorities with the information necessary for criminal prosecution
in case of a cyber-attack. Therefore, we only analyse anonymously collected
data and information statistically, with the aim of increasing the data
protection and data security of our enterprise, and to ensure an optimal level
of protection for the personal data we process. The anonymous data of the
server log files are stored separately from all personal data provided by
individuals.
Sharing
Data with third parties
In order to make
certain services available to you, we may disclose your personal information to
third parties. We will only disclose the minimum amount of personal data in order to provide the service. We have data sharing
agreements in place with each of our third-party suppliers and have completed
the necessary security checks to ensure that your data is kept safe once it is
passed to them. Our third-party suppliers only have the rights to use your data
for the purpose of fulfilling the service required of them, they do not have
marketing rights over your data, unless you have specifically expressed third
party consent. Your data will be shared with third parties under the following
circumstances;
• If
your enquiry leads to the purchase of a new vehicle your information will be
shared with the relevant manufacturer for warranty, registration
and safety recall purposes. We will ask for your consent to pass your
information to the manufacturer for marketing purposes. We recommend that you read
the manufacturers privacy policy to see how they will use your data.
• If
your enquiry leads to the purchase of a vehicle with a finance agreement, we
will disclose your information to our selected finance partners. If you are
accepted for finance, the finance company with become the data controller for
your information and we recommend that you read their privacy policy to see how
they will use your data.
Marketing
When you provide us with your personal data we
may ask you to set your marketing preferences with us so that you can choose
(if any) the information you'd like to hear more about as set out in the 'When
Consent is required' section. This may be done by;
• Registering
for offers via our website; or
• Visiting
our dealership / contacting us via telephone
If you opt-in to receive marketing from
manufacturers, we recommend that you read their privacy policy to see how they
will use your data and how to alter your marketing preferences with them should
you wish to in the future.
From time to time, we may ask you to refresh
your marketing preferences by asking you to confirm that you consent to
continue receiving marketing information from us
Legal rights
Your Rights
You have a number of rights in relation to your
personal information under data protection law. In relation to certain rights,
we may ask you for your information to confirm your identity and, where
applicable, to help us search for your personal information. Except in rare cases,
we will respond to you within 30 days after we have received this information
or, where no such information is required, after we have received your request.
Accessing your personal
information
You have the right to ask for a copy of the information we hold about
you by emailing or writing to us at the end of this notice. This will be
provided in a readable format (CSV or PDF) free of charge. We may not provide
you with a copy of your information if this concerns other individuals or we have
another lawful reason to withhold that information.
Correcting and updating
your personal information
The accuracy of your information is important to us and we are working
on ways to make it easier for you to review and correct the information we hold
about you. In the meantime, if you change your name or address/email address,
or you discover that any of the other information we hold about you is
inaccurate or out of date, please let us know by contacting us via the details
at the end of this notice.
Withdrawing your consent
Where we rely on your consent as the legal basis for processing your
personal information, as set out under ‘How we use your personal data’ section,
you may withdraw your consent at any time by contacting us using the details at
the end of this notice. If you would like to withdraw your consent to receiving
any direct marketing to which you previously opted-in, you can also do this by
selecting the ‘amend my preferences’ or ‘unsubscribe’ link located at the
bottom of our emails. If you withdraw your consent, our use of your personal
information before you withdraw is still lawful.
Objecting to our use of
automated processing
You may contest to a decision made about you based on automated
processing by contacting us on the details at the end of this notice.
Erasing your personal
information or restricting its processing
In certain circumstances, you may ask for your personal data to be
removed from our systems by emailing or writing to us at the address at the end
of this notice. Unless there is a reason that the law allows us to use your
personal information for longer, we will make reasonable efforts to comply with
your request.
You may also ask us to restrict processing your personal data in the
following situations;
In these situations, we may only process your personal information
whilst its processing is restricted if we have your consent or are legally
permitted to do so, for example for storage purposes, to protect the rights of
another individual or company in connection with legal proceedings.
Contact us
Complaining to the Maltese
data protection regulator;
You have the right to complain to the Information Commissioners Officer
(ICO) if you are concerned about the way we have processed your personal
information. Please visit the ICO website for further details.
How to contact us
Please contact us if you have any questions about our privacy notice or
information we hold about you:
By email: dataprotection@liaco.eu
Or write to us at: Data Protection Officer, Liaco Limited, Triq il-Mosta,
Lija, LJA 9012.