ABOUT THIS POLICY

1. We appreciate your interest in our products and services and your visit to this website. Your privacy is important to us and we want you to feel comfortable with how we use and share your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
2. This policy sets out how the ultimate parent company of Qube Automotive Ltd and the companies within the Qube Group that are based in the UK handle your personal data through your use of this website, including when and why it is collected, used and disclosed and how it is kept secure.
3. You will find our contact details at the end of this policy which you can use if you have any questions, including how to update or access your personal information or to make a complaint.
4. This website is not intended for children and we do not knowingly collect data relating to children.
5. This policy may change, so please check this page from time to time to ensure that you’re happy with any changes. (Please see further Changes to this policy in Section 12)
6. It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

WHO WE ARE

1. The Qube Group is made up of different legal entities, details of which can be found here: http://www.qubeautomotiveconsultancy.net. This privacy policy is issued on behalf of the Qube Group so when we mention "Qube”, "we", "us" or "our" in this privacy policy, we are referring to the relevant company in the Qube Group responsible for processing your data. QUBE AUTOMOTIVE LTD is the controller and responsible for this website.
2. We provide high quality, innovative automotive consultancy solutions to clients within the UK and mainland Europe which includes business to business reporting and analysis systems.
3. We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the contact details set out at the end of this policy.

THE DATA WE COLLECT ABOUT YOU

1. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
2. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
   1. Identity Data includes title, first name, middle name and surname
   2. Contact Data includes billing address, delivery address, email address and telephone numbers
   3. Transaction Data includes invoice information and sales (via Dealer Management Systems), but excludes payment methods and details
   4. Technical Data includes internet protocol (IP) address, your login data, browser type and version
   5. Profile Data includes your username (email address) and password
   6. Usage Data includes information about how you use our website, products and services
3. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data, but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
4. We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
5. 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.

HOW YOUR PERSONAL DATA IS COLLECTED

1. Personal data we collect about you: We may automatically collect the following personal data: our web servers store as standard details of your browser and operating system, the website from which you visit our website, the pages that you visit on our website, the date of your visit, and, for security reasons, e.g. to identify attacks on our website, the Internet protocol (IP) address assigned to you by your internet service.
2. We use different methods to collect data from and about you including through:
   1. Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
      1. apply for our products or services;
      2. create an account whether on our website or otherwise;
      3. subscribe to our service or publications;
      4. request marketing to be sent to you
      5. give us feedback or contact us.
   2. Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies.
3. We collect some of this information using cookies. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
4. We may also collect any personal data which you allow to be shared that is part of your public profile on a third party social network.
5. Please see further how we use your personal data in Section 5) for details of the purposes for which we use the personal data we obtain from these sources and the legal basis on which we rely to process that information. The remaining provisions of this policy also apply to any personal data we obtain from these sources.

HOW WE USE YOUR PERSONAL DATA

1. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
   1. Where we need to perform the contract we are about to enter into or have entered into with you.
   2. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
   3. Where we need to comply with a legal obligation.
2. Where you have provided CONSENT

   Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message.

   We may use and process your personal data where you have consented for us to do so to contact you with marketing information about products and services. Please see the Marketing in Section 11 for further details.

   You have the right to withdraw consent to marketing at any time by contacting us. Please see Withdrawing your consent in Section 9.4 for further details.

3. Where it is in your VITAL INTEREST

   We may use your personal data to contact you if we believe processing of your personal data will prevent or reduce any potential harm to you. It is in your vital interests for us to use your personal data in this way

4. Where required to comply with our LEGAL OBLIGATIONS

   We will use your personal data to comply with our legal obligations including:

   1. to assist HMRC, the Police, the Driver and Vehicle Licensing Agency (DVLA) or any other public authority or criminal investigation body;
   2. to identify you when you contact us;
   3. to verify the accuracy of data that we hold about you.
5. Where there is a LEGITIMATE INTEREST

   We may use and process your personal data where it is necessary for us to pursue our legitimate interests as a business for the following purposes:

   1. for analysis, and profiling to inform our marketing strategy, and to enhance and personalise your customer or visitor experience;
   2. for market research in order to continually improve the products and services that we and our clients deliver to you;
   3. to administer our websites and for internal operations, including troubleshooting, testing, statistical purposes;
   4. for marketing activities (other than where we rely on your consent) e.g. to tailor marketing communications or send targeted marketing messages via social media and other third-party platforms;
   5. for the prevention of fraud and other criminal activities;
   6. to correspond and communicate with you;
   7. to create a better understanding of you as a customer or visitor;
   8. for network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access;
   9. 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 lists in order to be able to comply with your request);
   10. for the purposes of corporate restructure or reorganisation or sale of our business or assets;
   11. for efficiency, accuracy or other improvements of our databases and systems e.g. by combining systems or consolidating records we or our group companies hold about you;
   12. to enforce or protect our contractual or other legal rights or to bring or defend legal proceedings; and
   13. for general administration including managing your queries, complaints, or claims, and to send service messages to you.
6. We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.
7. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
8. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
9. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

DISCLOSURES OF YOUR PERSONAL DATA

1. Our suppliers and service providers

   We may disclose your information to our third-party service providers, agents, subcontractors and other organisations for the purposes of providing services to us or directly to you on our behalf. Such third parties may include cloud services providers (such as hosting and email management) or advertising agencies, administrative services or other third parties who provide services to us.

   When we use third party service providers, we only disclose to them any personal data that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.

2. Other ways we may share your personal data

   We may transfer your personal data to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation. We may also transfer your personal data if we’re under a duty to disclose or share it in order to comply with any legal obligation (e.g. by sharing your personal data with the DVLA), to detect or report a crime, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our visitors and customers.

   However, we will always take steps with the aim of ensuring that your privacy rights continue to be protected.

   We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

IS YOUR PERSONAL DATA STORED OUTSIDE THE EEA

1. All information provided is stored with the EEA.
2. We do not transfer your personal data outside the UK.
3. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

HOW LONG WE KEEP YOUR PERSONAL DATA FOR

1. We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
2. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

YOUR RIGHTS

1. Your ‘data subject’ rights:

   You have a number of rights in relation to your personal data under data protection law. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal data. 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.

2. Accessing your personal data

   You have the right to ask for a copy of the information that we hold about you by emailing or writing to us at the address at the end of this policy. We may not provide you with a copy of your personal data if this concerns other individuals or we have another lawful reason to withhold that information.

3. Correcting and updating your personal data

   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 that 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 is inaccurate or out of date, please let us know by contacting us in any of the details described at the end of this policy.

4. Withdrawing your consent

   Where we rely on your consent as the legal basis for processing your personal data, as set out under How we use your personal data in Section 5), you may withdraw your consent at any time by contacting us using the details at the end of this policy. If you would like to withdraw your consent to receiving any direct marketing, please inform us by emailing or writing using the address at the end of this policy.

   If you withdraw your consent, our use of your personal data before you withdraw is still lawful.

5. Objecting to our use of your personal data and automated decisions made about you.

   Where we rely on our legitimate business interests as the legal basis for processing your personal data for any purpose(s), as set out under How we use your personal data in Section 5), you may object to us using your personal data for these purposes by emailing or writing to us at the address at the end of this policy. Except for the purposes for which we are sure we can continue to process your personal data, we will temporarily stop processing your personal data in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise we will provide you with our justification as to why we need to continue using your data.

   You may object to us using your personal data for direct marketing purposes and we will automatically comply with your request.

6. Erasing your personal data 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 policy. Unless there is a reason that the law allows us to use your personal data 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:

   1. where you believe it is unlawful for us to do so,
   2. you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings.

   In these situations, we may only process your personal data 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 or in connection with legal proceedings.

7. Transferring your personal data in a structured data file

   Where we rely on your consent as the legal basis for processing your personal data or need to process it in connection with your contract, as set out under Section 5) How we use your personal data, you may ask us to provide you with a copy of that information in a structured data file. We will provide this to you electronically in a structured, commonly used and machine-readable form, such as a CSV file.

   You can ask us to send your personal data directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal data if this concerns other individuals or we have another lawful reason to withhold that information.

8. Request restriction of processing your personal data

   The right to obtain restriction of the processing is a new right that you can exercise:

   1. While complaints such as accuracy are pending for a period of time.
   2. If the processing is unlawful, but you object to erasure. You may want to secure the data for evidential purposes.
   3. Where we no longer need your personal data for our own purposes but your data is required by you for the establishment, exercise or defence of legal claims.
   4. Where you have objected to processing pursuant to your right to object pending verification of whether our legitimate grounds override yours.

9. Complaining to the UK data protection regulator

   You have the right to complain to the Information Commissioners Office (ICO) if you are concerned about the way we have processed your personal data. Please visit the ICO’s website for further details https://ico.org.uk/

   We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

10. If you wish to exercise any of the rights set out above, please contact us.
11. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
12. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
13. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

DATA SECURITY

1. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
2. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
3. We use technical and organisational security measures to protect the personal data supplied by you and managed by us against manipulation, loss, destruction, and access by third parties. Our security measures are continually improved in line with technological developments.
4. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information whilst in transit to our website and any transmission is at your own risk.
5. Where we have provided (or where you have chosen) a password which enables you to access an account, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

THIRD PARTY LINKS

1. Our website may contain links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. This policy does not apply to those other websites and Apps‚ so we encourage you to read their privacy statements. We are not responsible for the privacy policies and practices of other websites and Apps (even if you access them using links that we provide) and we provide links to those websites solely for your information and convenience. We specifically disclaim responsibility for their content, privacy practices and terms of use, and we make no endorsements, representations or promises about their accuracy, content or thoroughness. Your disclosure of personal data to third party websites is at your own risk.
2. In addition, if you linked to our website from a third-party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third-party website and recommend that you check the policy of that third-party website.
3. We use so-called social plugins (buttons) of social networks such as Facebook, Google+ and Twitter.
4. When you visit our websites, these buttons are deactivated by default, i.e. without your intervention they will not send any data to the respective social networks. Before you are able to use these buttons, you must activate them by clicking on them. They then remain active until you deactivate them again or delete your cookies. Please see Cookies in Section 4.3 for further details regarding our use of cookies.
5. After their activation, a direct link to the server of the respective social network is established. The contents of the button are then transmitted from the social network directly to your browser and incorporated in the website.
6. After activation of a button, the social network can retrieve data, independently of whether you interact with the button or not. If you are logged on to a social network, the network can assign your visit to the website to your user account. A social network cannot assign a visit to websites operated by our other group companies unless and until you activate the respective button there as well.
7. If you are a member of a social network and do not wish it to combine data retrieved from your visit to our websites with your membership data, you must log out from the social network concerned before activating the buttons.
8. We have no influence on the scope of data that is collected by the social networks through their buttons. The data use policies of the social networks provide information on the purpose and extent of the data that they collect, how this data is processed and used, the rights available to you and the settings that you can use to protect your privacy.

MARKETING

1. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
2. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
3. You will receive marketing communications from us by email or SMS (where applicable) if you have requested information or purchased service from us, and you have not opted out of receiving that marketing.
4. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
5. We may contact you with targeted advertising delivered online through social media and platforms (operated by other companies) by using your personal data or use your personal data to tailor marketing to improve its relevance to you, unless you object.
6. 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.
7. You can ask us or third parties to stop sending you marketing messages at any time in any of the ways mentioned above. Please see Withdrawing your Consent in Section 9.4 and Objecting to our use of your personal data and automated decisions made about you in Section 9.5 above for further details on how you can do this.
8. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transaction.

CHANGES TO THIS POLICY AND YOUR DUTY TO INFORM US OF CHANGES

1. We keep our privacy policy under regular review. This version was last updated on 18 Dec 2024. Any changes will be notified to you by posting an updated version on our website. We recommend you regularly check for changes and review this policy when you visit our website. If you do not agree with any aspect of the updated policy, you must promptly notify us and cease using our services
2. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

CONTACT US

If you have any questions about this privacy policy or our privacy practices, suggestions or complaints about the processing of your personal data or wish to contact us to amend/update your marketing preferences, please contact our data privacy manager in the following ways:

Full name of legal entity: QUBE AUTOMOTIVE LTD
Email address: dataofficer@qubeautomotive.com
Postal address: 10 Hollingworth Court,Turkey Mill, Ashford Road, Maidstone Kent, ME14 5PP
Telephone number: +44 (0)333 241 2945