1. ABOUT THIS POLICY

1.1 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 information.

 

1.2 This policy sets out how the company of the AM Street Cars that are based in the UK handle your personal information, including when and why it is collected, used and disclosed and how it is kept secure.

 

1.3 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.

 

1.4 This policy may change, so please check this page from time to time to ensure that you’re happy with any changes.

 

1.5 This policy was last updated on 05 July 2024.

 

2. HOW AND WHAT PERSONAL INFORMATION WE COLLECT

2.1 We may collect and process the following personal information about you:

Personal information you give to us:

This is information about you that you give to us by entering information via our websites or our social media pages or by corresponding with us by phone, email or otherwise and is provided entirely voluntarily. The information you give to us includes your name, contact details (such as phone number, email address and address), enquiry details and your opinion of our products.

Personal Information we collect about you:

We store certain information about the browser and operating system you are using; the date and time of your visit; the status of interaction (e.g. whether you were able to access the website or received an error message); the usage of features on the website; any search phrases you entered; how often you visit individual websites; the names of files you access; the amount of data transferred; the Web page from which you accessed our website; and the Web page you visited after visiting our website, whether by clicking on links on our websites or entering a domain directly into the input field of the same tab (or window) of the browser in which you have our websites open.

In addition we store your IP address and the name of your internet provider for seven days. This is for security reasons; in particular, to prevent and detect attacks on our websites or attempts at fraud.

 

2.2 Please see further How we use your personal information in Section 3 for details of the purposes for which we use the personal information 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 information we obtain from these sources.

 

2.3 You are neither legally nor contractually obligated to share your personal information. However, certain features of our website may depend on the sharing of personal information. If you do not provide your personal information in such cases, you may not be able to use those features, or they may be available with very limited functionality.

 

2.4 The purpose of the exchange and other processing of personal data in the context of OneWeb is to carry out analysis measures to recognize website user behaviour, to improve the user-friendliness of the websites and to improve digital products and campaigns. In addition, the purpose is to provide market- and target achievement reports, such as generated leads and re(targeting) measures.

 

3. HOW WE USE YOUR PERSONAL INFORMATION

We will only use your personal data when the law allows us to. We will use your personal data in the following circumstances:

3.1 Consent

We may use and process your personal information where you have consented for us to do so for the following purposes:

• to share your personal information with our authorised dealers to arrange test drives or where you have requested a call back;
• to supply brochures and other material you have specifically requested from us;
• to contact you via email, text message, post or telephone with marketing information about AM Street Cars and Smart vehicles and other products and services (see Marketing section below for further details);
• to share your personal information with our authorised dealers or our recommended third party partners for them to contact you with marketing information about their products and services. Please see the Marketing section below in this policy to find out more about these third parties;
• to process payments on your behalf including but not limited to card payments taken over the phone for the purposes of making payment of a deposit related to a vehicle; and
• to complete other processing activities that you have expressly requested us to complete or you have expressly agreed to us performing.

 

3.2 You may withdraw your consent for us to use your information in any of these ways at any time. Please see Withdrawing your consent in Section 8.4 for further details.

 

3.3 Contract

We may use and process your personal information 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, but not limited to, for the following purposes.

• To exchange information for warranty/aftersales
• To allow for the provision of third party breakdown services by our breakdown provider;
• If you take a finance or lease agreement 
• If you take insurance cover or premium financing

 

3.4 Vital Interests

We may use your personal information to contact you if there are any urgent safety or product recall notices to communicate to you or where we otherwise reasonably believe that the processing of your personal information will prevent or reduce any potential harm to you. It is in your vital interests for us to use your personal information in this way.

 

3.5 Legal Obligations

We will use your personal information to comply with our legal obligations including: (i) to assist HMRC, the Police, the Driver and Vehicle Licensing Agency (DVLA) or any other public authority or criminal investigation body; (ii) to identify you when you contact us; and (iii) to verify the accuracy of data that we hold about you.

 

3.6 Legitimate interests

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

• for analysis, and profiling to inform our marketing strategy, and to enhance and personalise your customer or visitor experience;
• for market research in order to continually improve the products and services that we and our authorised dealers deliver to you;
• to a minister our websites and for internal operations, including troubleshooting, testing, statistical purposes;
• 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;
• for the prevention of fraud and other criminal activities;
• to undertake credit checks for finance;
• for the processing of your personal data for the purposes of (further) development of risk instruments and the related reporting by the market 
• to correspond and communicate with you;
• to create a better understanding of you as a customer or visitor;
• for network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access;
• 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);
• for the purposes of corporate restructure or reorganisation or sale of our business or assets;
• or 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;

to enforce or protect our contractual or other legal rights or to bring or defend legal proceedings; and for general administration including managing your queries, complaints, or claims, and to send service messages to you.

• To provide information to government bodies or agencies for administration purposes.

 

4. OTHERS WHO MAY RECEIVE OR HAVE ACCESS TO YOUR PERSONAL INFORMATION

4.1 Group companies

We may share your information with other companies within the AM Street Cars. They may use your personal information in the ways set out in How we use your personal information in Section 3, in connection with products and services that complement our own range of products and services, for example finance or insurance products.

 

4.2 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 information 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.

 

4.3 Authorised dealers in our network

We may share your information with other companies within our Authorised Dealer Network. They may use your personal information in the ways set out in How we use your personal information in Section 3 or in connection with products and services that complement our own range of products and services, for example finance or insurance products.

 

4.4 Third parties who provide products and service

We work closely with various third parties to bring you a range of products and services which are complimentary to ours.

When you enquire about or purchase one or more of these products or services through us (e.g. via our websites), the relevant third party may use your details to provide you with information and carry out their obligations arising from any contracts you have entered into with them.

These third party product providers may share your information with us which we will use in accordance with this policy. In some cases, they will be acting as a controller of your information and therefore we advise you to read their privacy policy.

 

4.5 Other ways we may share your personal information

• We may transfer your personal information 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 information 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 information 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.

 

5. WHERE WE STORE YOUR PERSONAL INFORMATION OUTSIDE THE EEA

5.1 All information you provide to us may be transferred to countries outside the United Kingdom or European Economic Area (EEA, in particular USA and India. Further countries listed in our Consent Management System under “Cookie Settings” in the footer at the bottom of our website). By way of example, this may happen where any of our group companies are incorporated in a country outside of the UK/EEA or if any of our servers or those of our third-party service providers are from time to time located in a country outside of the UK/EEA. These countries may not have similar data protection laws to the UK/EU.

 

5.2 If we transfer your information outside of the UK/EEA in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this policy. These steps include imposing contractual obligations on the recipient of your personal information or ensuring that the recipients are subscribed to ‘international frameworks’ including but not limited to the use of UK/EU standard contractual clauses, binding corporate rules or other applicable instruments (if any) that aim to ensure adequate protection.

Please contact us using the details at the end of this policy for more information about the protections that we put in place and to obtain a copy of the relevant documents. 

 

6. HOW LONG WE KEEP YOUR PERSONAL INFORMATION FOR

6.1 If we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws.

 

6.2 We do not retain personal information in an identifiable format for longer than is necessary.

 

6.3 We may need your personal information to establish, bring or defend legal claims, in which case we will retain your personal information for 7 years after the last occasion on which we have used your personal information in one of the ways specified in How we use your personal information in Section 3.

 

6.4 The only exceptions to this are where:

• the law requires us to hold your personal information for a longer period, or delete it sooner;
• you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted in this section 6, or because we are required under the law (see further Erasing your personal information or restricting its processing in Section 7.6);
• and in limited cases, the law permits us to keep your personal information indefinitely provided we put certain protections in place.
• Where credit checks are completed, we will retain this information for 7 years, from the end of the finance agreement.

In addition to the above we will also store personal information only if you share that information; for instance, by filling out a registration form, contact form, survey, contest entry or to execute a contract. In such cases we will, store only the data we are allowed to keep based on the lawful basis described in

 

7. YOUR RIGHTS

 

7.1 Your ‘data subject’ 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 information to confirm your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within 1 month after we have received this information or, where no such information is required, after we have received your request.

 

7.2 Accessing your personal information

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 information if this concerns other individuals or we have another lawful reason to withhold that information.

 

7.3 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 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.

 

7.4 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 information in Section 3, 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 to which you previously opted-in, you can also do so using our unsubscribe tool. If you withdraw your consent, our use of your personal information before you withdraw is still lawful.

 

7.5 Objecting to our use of your personal information and automated decisions made about you

Where we rely on our legitimate business interests as the legal basis for processing your personal information for any purpose(s), as out under How we use your personal information in Section 3, you may object to us using your personal information 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 information, we will temporarily stop processing your personal information 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 information for direct marketing purposes and we will automatically comply with your request. If you would like to do so, please use our unsubscribe tool.

You may also contest a decision made about you based on automated processing by contacting the data protection department.

 

7.6 Erasing your personal information or restricting its processing

In certain circumstances, you may ask for your personal information 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 information for longer, we will make reasonable efforts to comply with your request.
You may also ask us to restrict processing your personal information in the following situations:

• where you believe it is unlawful for us to do so,
• 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 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 or in connection with legal proceedings.

 

 7.7 Transferring your personal information in a structured data file

Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with your contract, as set out under Section 3 How we use your personal information, 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 information 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 information if this concerns other individuals or we have another lawful reason to withhold that information.

 

7.8 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 information. Please visit the ICO’s website for further details.

 

8. SECURITY / COOKIES / LINKS / SOCIAL PLUGINS

8.1 Security measures we put in place to protect your personal information

All companies within the AM Street Cars use technical and organisational security measures to protect the personal information 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.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information whilst in transit to our website and any transmission is at your own risk.

Where we have given (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.

 

8.2 Use of 'cookies'

'Cookies' are small pieces of information sent to your device and stored on its hard drive to allow our websites to recognise you when you visit. Information on the cookies that we use and their features can be found in the cookies section.

 8.3 Links to other websites

Our website may contain links to other websites run by other organisations which we do not control. 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 information to third party websites is at your own risk.

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.

 

8.4 Third Parties and Social plugins

Our websites may also contain third-party offers. If you click on any such offers, we will transfer the amount of data required to the appropriate provider (e.g. the fact that you found the offer in question on our website and, if applicable, additional information that you have already provided for this purpose on our websites).

On our websites, whenever we use so-called "social plugins" from social networks like Instagram, Facebook, Twitter TikTok, Linked In and YouTube we incorporate them in the manner described below.

When you visit our websites, social media plugins are deactivated. That means no information whatsoever is transferred to the operators of those networks. If you wish to use one of the networks, click on the appropriate plugin in order to be connected directly to that network's server.

If you have a user account with that network and are logged in at the moment you activate the plugin, the network will be able to detect your visit to our websites and assign it to your user account. If you wish to prevent that, please log off from the network before activating the social plugin. A social network will not be able to detect that you have visited other AM Street Cars websites unless you have activated its social plugin on those sites as well.

When you activate a social plugin, the network transfers the content thus made available directly to your browser, which incorporates it into our websites. In that situation, data transfers initiated and controlled by the respective social network may also take place. Your connection to a social network, the data transfers that take place between the network and your system, and your interactions on that platform are governed exclusively by the respective network's data protection provisions.

The social plugin will remain active until you deactivate it or delete your cookies.

Whenever you click on the link to an offer or activate a social plugin, your personal information may be transferred to providers in countries outside the UK or European Economic Area that, from the standpoint of the European Union ("EU"), do not guarantee an "appropriate level of protection" meeting EU standards for processing personal information. Please keep these circumstances in mind before you click on a link or activate a social plugin, thereby causing your data to be transferred.

 

9. ANALYSIS OF USER DATA AND USE OF ANALYTICS TOOLS

9.1 We want the content of our websites to match your preferences as closely as possible, thereby improving what we offer you. To identify especially popular areas of our websites, we use the following analysis tools: Google Analytics and Adobe Analytics.

 

9.2 When we employ these analytics tools, information may be transferred to servers located in the US and processed there.

 

9.3 If you do not wish us to use the above named analytics tools to collect and analyse information about your visit to our websites, you may permanently object to the practice (opt out) at any time.

We will comply with your rejection by placing an opt-out cookie in your browser. This cookie will only indicate that you have opted out. Please note that, for technical reasons, an opt-out cookie affects only the browser in which it has been installed. If you delete the cookie or use a different browser or device, you will need to opt out again.

 

9.4 You can opt-out of cookies using our cookies consent mechanism. Below you will find information about the providers of the analytics tools and the respective opt-out procedures:

1. Google Analytics from Google Inc. ("Google"):

You can prevent your information from being transferred as well as collected and processed by Google. Google provides information about this at the following link: https://tools.google.com/dlpage/gaoptout?hl=gb

1. Adobe Analytics from Adobe Systems Inc. ("Adobe")

You can follow this link to opt out of analysis using Adobe Analytics: http://www.adobe.com/uk/privacy/opt-out.html.

iii. Facebook Ireland Ltd (“Facebook”)

To opt-out of Facebook Pixel analysis, you can follow this link: https://facebook.com/ads/preferences

 

10. TARGETING AND RETARGETING 

10.1 We use so-called targeting, retargeting and cookie-less technologies in order to tailor our online marketing (e.g. banner ads) more specifically to your needs and interests. Adobe Target, Flashtalking by Simplicity Marketing Limited, Google Search Ad, Google Display & Video 360, Facebook Pixel, Salesforce Data Management Platform, Trade Desk from The Trade Desk Inc. These are monitored and used when you visit other websites that work together with the providers of these (re-)targeting technologies, so as to inform you while meeting your interests as closely as possible.

 

When the above technologies are used, cookies on our websites and (in the case of retargeting) on the websites of others register your interest in our products and services. In the process, random identifiers (so-called cookie IDs) are used which are not brought into connection with your name, your address or similar information, even if this information is known to us (e.g. from an existing contractual relationship), unless you have consented to this.

 

Further information about the above technologies from the respective providers, and the associated processing of personal data, can be found at the following links:

Adobe: https://www.adobe.com/uk/privacy.html
 Google: https://policies.google.com/technologies/partner-sites
 Simplicity Marketing Limited: https://www.flashtalking.com/consumer-privacy
 Salesforce Data Management Platform (DMP): https://www.salesforce.com/uk/company/privacy/
 Trade Desk from the Trade Desk Inc. https://www.adsrvr.org/
 Facebook Ireland Ltd., Dublin, Ireland: https://www.facebook.com/about/privacy/update and https://help.instagram.com/519522125107875
 You can manage and deactivate the use of cookies on the following websites for the technology providers listed there or in your browser as explained in our cookie statement:

https://www.youronlinechoices.com/uk/your-ad-choices

https://optout.aboutads.info

During the retargeting process, we may also collect information about your interest in the products and services of our retargeting partners.

For legal reasons, the use of tracking and (re-) targeting technologies is sometimes only possible with your express consent (so called opt in see 10.2). In other cases you can object to the use of such technologies if you wish (so called opt out see 10.3),

 

10.2 Use of online marketing products – Opt-in

We only use online marketing products from Google (e.g. Search Ad, Display & Video 360) and Facebook (so-called “Facebook Pixel”) with your express consent, which you can grant by clicking on the "Agree" button in the so-called Cookie Information Layer ("Opt-in"). We store this consent in a cookie on your device so that you are not asked for consent again each time you visit our websites, and for legal reasons, also on our servers with the IP address and a time stamp; we delete this information or restrict its processing if you withdraw your consent or 6 months at the latest after your last visit to our websites.

 

Should you change your mind at any time, you can withdraw your consent by clicking on the following link:

Withdraw consent to online marketing products from Google and Facebook.

To delete cookies set with your consent when visiting our websites after your consent to these online marketing products is withdrawn, please visit the following websites or delete the cookies in your browser as explained in our cookies statement:

Google: https://adssettings.google.co.uk/anonymous
Facebook and Instagram: http://facebook.com/ads/preferences 

 

11. MARKETING

11.1 We may collect your preferences to send you marketing information directly from us by email/SMS(where applicable) including:

• if you register an account with us online; or
• if you book a test drive or request a call back.

We will only do so if you have consented to receiving such marketing information directly from us.

 

11.2 We may contact you with targeted advertising delivered online through social media and platforms (operated by other companies) by using your personal information, or use your personal information to tailor marketing to improve its relevance to you, unless you object.

 

11.3 We will only share your personal information with recommended third parties for them to contact you with marketing information about their products and services where you have indicated that you would like us to do so. Please use the link on the page requesting your consent to find out more about these third parties. Once shared, the relevant third party’s privacy policy will apply to their processing of your personal information, not ours. If you’d like to opt-out of receiving marketing from a third party after providing your consent, you can do so at any time by contacting the relevant third party directly.

 

11.5 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.

 

11.6 You have the right to opt-out of our use of your personal information to provide marketing to you in any of the ways mentioned above. Please see Withdrawing your Consent in Section 7.4 and Objecting to our use of your personal information and automated decisions made about you in Section 7.5 above for further details on how you can do this.

 

12. CHANGES TO THIS POLICY

We may review this policy from time to time and any changes will be notified to you by posting an updated version on our website and/or by contacting you by email. Any changes will take effect 7 days after the date of our email or the date on which we post the modified terms on our website, whichever is the earlier. 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.

 

13. CONTACT US

If you have any questions, suggestions or complaints about the processing of your personal information or wish to contact us to amend/update your marketing preferences, please contact the AM Street Cars.

 

14. COOKIES TABLE

Google analytics

_ga

_gat

Third party

These cookies are used to collect information about how visitors use our website. We use the information to compile reports and to help us improve the website. 

Persistent

2 years

https://privacy.google.com/?hl=en#