NEWTON TRAILERS AND AUTHORISED RETAILERS JOINT PRIVACY STATEMENT

Newton Trailers Limited, and each of the retailers in its authorised network (“Retailer” or “Service Partner”) are committed to protecting and respecting your personal information.

In this statement we refer to Newton Trailers Limited and the Retailer collectively as “we”, “us” or “our”, as applicable.

Newton Trailers Limited operates in the bulk transport sector in the UK; Northern Ireland; Europe and Worldwide. We purchase and sell vehicles trailers and their associated parts and services including hire and rental services. We operate in exclusively business to business/entrepreneur sales and services.

From time to time, we receive your contact details and other personal information directly from you or from our group companies and other third parties (“Partners”) where your recent activities or your vehicle information indicates that you may be interested in hearing from a Retailer or where you have made a sales enquiry, require accident or breakdown services, expressed an interest in hearing from the Retailer or have provided your consent for your information to be shared with a Retailer for the purposes of receiving follow up contact (“Enquiries”).

Please see below a list of Partners.

• Knapen Trailers
• STAS Trailers
• SDC Trailers
• Muldoon Trailers
• Cargo Floor
• Keith WALKING FLOOR^®
• SAF Axles
• JOST AXLES
• Hyva Cylinders
• Edbro Cylinders
• VWS Weighers
• Wabco
• Knorr Bremse

This statement describes the relationship between Newton Trailers Limited and the Retailer and their data protection responsibilities in connection with personal information that is received by Newton Trailers Limited and the Retailer in relation to your Enquiries. This statement also describes what types of information we receive about you, how it is used by us, how we share the information with others, how you can manage the information we hold and how you can contact us.

For the purposes of data protection laws, Newton Trailers Limited and the Retailer are “joint controllers” of the processing of your personal information described in this statement. This means that these businesses work together to decide why and how your personal information is processed. It also means that they are jointly responsible to you under the law for that processing.

Not all processing of your personal information is performed by us acting as joint controllers. Newton Trailers Limited makes decisions regarding certain processing of your personal information independently of the Newton Trailers Limited, for which Newton Trailers Limited is solely responsible. Similarly, the Retailer makes decisions for certain processing of your personal information independently of for which the Retailer is solely responsible. Please visit the website of the relevant business using the table below to find out more about processing for which each business makes decisions independently of the other.

Retailer

Please see the privacy statement published on the Retailer’s website and on our website.

www.newtontrailers.com

The contents of this statement may change from time to time so you may wish to check this page occasionally to ensure you are still happy to share your information with us. Where possible, we will also contact you directly to notify you of any substantial changes.

This version of our Privacy Statement is live from January 2024

What are the processing roles of Newton Trailers Limited and the Retailer?

Newton Trailers Limited and the Retailer have different roles in connection with the processing of your information. In brief, the Retailer uses the information to deal with your Enquiries and Newton Trailers Limited uses the information to monitor, manage and analyse the Retailer’s handling of your Enquiry.

The Retailer is the business that has primary responsibility for the day to day handling of your personal information as it receives and deals with your Enquires and has direct contact with you. As a result, it is responsible for areas that closely relate to its interactions with you such as:

• responding to your queries and requests when you exercise your data protection rights;
• making sure it has the legal grounds in place to contact you and for making sure it respects your objections in respect of any contact; and
• managing your consent and keeping records of when you provide and withdraw that consent.

Newton Trailers Limited monitors, manages and analyses how the Retailer deals with your Enquiries. Often this does not involve having any direct access to your personal information and except in rare cases, Newton Trailers Limited will not have any direct contact with you in connection with these activities. Newton Trailers Limited also is responsible for providing the system that stores and manages your personal information which is accessed by the Retailer. As a result, it is responsible for areas that relate to the provision of the system that facilitates the processing your personal information, which includes:

• engaging and managing the supplier of the system that stores your information;
• implementing security measures on that system; and
• setting and implementing retention periods that apply to your information.

What information do we receive?

We receive information about you and your trailer. We only accept and retain information which is necessary, relevant and adequate for the purposes we use that information.

We receive information about you and your trailer from the manufacturer of your vehicle and other Partners. The information we receive includes some or all of the following:

1. Name (including title);
2. Address;
3. Email address;
4. Vehicle information (including registration number, VIN, service reminders, defects, mileage and warranty repair information);
5. Information relating to a breakdown, accident or service incident that you have experienced;
6. Information relating to your Enquiries, including the time/date and source of your Enquiry; and
7. Any information contained in correspondence you send to us relating to this statement.

We also process information about you that we create when recording our interactions with you. For example, the Retailer may create notes about its communications with you and our systems may create reports containing statistics and analysis regarding the Retailer’s handling of your Enquiries. Newton Trailers Limited may have access to this information.

We may also create personal information about you when corresponding with you.

How do we use this information?

Newton Trailers Limited and the Retailer will only process information that is necessary for the purpose for which it has been received. You will always have the option not to receive marketing communications from us (and you can withdraw your consent or object at any time). We will never send you unsolicited ‘junk’ email or communications, or share your personal information with anyone else who might.

There are various ways in which we may use or process your personal information. We list these below:

Contractual Performance

We may use and process your personal information where your Enquiry is a pre-contract enquiry in anticipation of entering into a contract (and where we have not requested your express consent) or to assist with providing you with accident and breakdown services.

Consent

Where you have provided your consent, we may use and process your information to contact you, manage and resolve your Enquiry in line with that consent.

You can withdraw your consent at any time by contacting the Retailer in the first instance. Please see further How can I manage the information we hold about you?.

Legitimate Interests

We may use and process your personal information as set out below where it is necessary for us to carry out activities for which it is in our legitimate interests as a business to do so.

Processing necessary for us to support customers with sales and other enquiries

1. To contact you, manage and resolve your Enquiry other than in the circumstances described above;
2. To receive, and respond to, correspondence you send to us, including in relation to any complaints or general queries;

Processing necessary for us to respond to understanding our customers’ needs

3. To analyse, evaluate and improve our products and services so that your visit and use of our website, applications, customer service centre and authorised retailers are more useful and enjoyable (we will generally use data amalgamated from many people so that it doesn’t identify you personally);

Processing necessary for us to assess and respond to complaints, claims and regulators

4. To respond to queries, complaints or claims and to manage legal and regulatory requests and requirements;
5. To enforce or protect our legal rights or to establish, bring or defend legal claims;

Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively

6. To monitor, manage and analyse how we handle your Enquiries, including to measure the performance of Retailers and their staff;
7. To verify the accuracy of information that we hold about you and create a better understanding of you as a prospective customer;
8. To contact you if the Retailer closes, moves premises or is replaced;
9. For network and information security purposes i.e. in order for us to take steps to protect your information against loss, damage, theft or unauthorised access;
10. To detect and prevent fraud or other criminal activities;
11. 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); and
12. To inform you of updates to our terms and conditions and policies.

Legal Obligation

We may process your personal information to comply with our legal or regulatory requirements (for example where we are required to disclose this information under a court order).

Vital Interest

Sometimes we will need to process your personal information to contact you if there is an urgent safety or product recall notice and we need to tell you about it.

How do we share this information?

We do not sell your information to third parties, but we do work closely with our Partners and other suppliers which may involve disclosing your information to them.

As joint controllers, Newton Trailers Limited and the Retailer may share your information between them to ensure that your Enquires, and any related complaints, are managed and resolved effectively and efficiently. Your information may also be shared with other retailers in Newton Trailers Limited’s authorised network where appropriate, for example, where a retailer is no longer authorised or where it ceases to trade.

We do not sell your information to third parties. However, we may from time to time disclose your information to the following categories of companies or organisations to which we pass the responsibility to handle services on our behalf and which may include our group companies: customer contact centres, IT service providers, accident and breakdown service providers (“Service Partner”), vehicle rental service providers, lead management service providers, analytics service providers and our legal and other professional advisors.

We will also share your personal information if we have a duty to do so, e.g. in connection with a mandatory requirement from an authorised authority, regulatory body or court, or to enforce or protect our legal rights or to establish, bring or defend legal claims.

Due to the international nature of our business, there may be some instances where your information is processed or stored outside of the UK and EU. In those instances, we will ensure that appropriate safeguards are in place for that transfer and storage as required by applicable law.

We take steps to ensure that any third party partners who handle your information comply with data protection legislation and protect your information just as we do. We only disclose personal information that is necessary for them to provide the service that they are undertaking on our behalf. We will aim to anonymise your information or use aggregated none specific data sets where ever possible.

How long do we keep your information for?

We will hold your personal information in an identifiable format for as long as is necessary. The nature of our business interaction is ‘Business to Business/Entrepreneur. The Retailer may continue to retain and use this information, but it will do so independently of its arrangement with Newton Trailers Limited based on its own privacy statement that it provides to you.

Where your Enquiry has led you to have an ongoing relationship with the Retailer, the Retailer may continue to retain and use this information, but it will do so independently of its arrangement with Newton Trailers Limited described in this statement. Any processing that the Retailer carries out will be based on its own privacy statement that it provides to you.

The only exceptions to the periods mentioned above are where:

• the law requires us to hold your personal information for a longer period, or delete it sooner;
• you have raised a legal claim, complaint or concern regarding a product or service offered by us, in which case we will retain your information for a period of 6 years following the date of that complaint or query; or
• 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 or required under the law (see further How can I manage the information we hold about you?);

How can I manage the information we hold about you?

You have the right as an individual to access your personal information we hold about you and make corrections if necessary. You also have the right to withdraw any consent you have previously given us and ask us to erase information we hold about you. You can also object to us using your personal information (where we rely on our business interests to process and use your personal information).

You have a number of rights in relation to your personal information under data protection law. In relation to most rights, we will ask you for 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 1 month after we have received any request (including any identification documents requested).

You have the right to:

1. Ask for a copy of the information that we hold about you;
2. Correct and update your information;
3. Withdraw your consent (where we rely on it). Please see further How do we use this information;
4. Object to our use of your information (where we rely on our legitimate interests to use your personal information) provided we do not have any continuing lawful reason to continue to use and process the information. When we do rely on our legitimate interests to use your personal information for direct marketing, we will always comply with your right to object;
5. Erase your information (or restrict the use of it), provided we do not have any continuing lawful reason to continue to use and process that information;
6. Transfer your information in a structured data file (in a commonly used and machine readable format), where we rely on your consent to use and process your personal information or need to process it in connection with your contract.

If you wish to exercise the above rights and/or manage your information, please contact the Retailer in the first instance using the details available on its website.

If you wish to contact Newton Trailers Limited, you can do so by post to:

Newton Trailers Limited, Station Yard, Station Road, Ridgmont MK430XP

If you have any other data protection concerns or complaints, you can address them to our Data Protection Team at accounts@newtontrailers.com

If you are unhappy, you have the right to lodge a complaint with a data protection regulator in Europe, in particular in a country you work or live or where your legal rights have been infringed. The contact details for the Information Commissioner’s Office, the data protection regulator in the UK, are below:

Post:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Privacy statement

Newton Trailers Limited (“we”/”us”) are committed to protecting and respecting any personal information you share with us.

This statement describes what types of information we collect from you, how it is used by us, how we share data with others, how you can manage the information we hold and how you can contact us. The information below describes processing relating to the information we obtain from you and other visitors and customers through a variety of different interactions, including when you visit our websites or social media pages, or contact our customer services centre.

For the purposes of data protection laws, we are a ‘controller’ of your personal information which means we decide why and how it is processed. It also means we are responsible for that processing, which extends to those of our subcontractors who process your information based on our instructions. We work with other, more independent, organisations in connection with some of the processing activities described in this statement, such as social media platforms, authorised dealers and our group companies. Where that information is collected and sent to other organisations for processing that is in both our and their interests, we will be making decisions together in relation to that particular processing. and will be ‘joint controllers’ with the organisations involved. As joint controllers, we and the other organisations involved in making these decisions will be jointly responsible to you under data protection laws for this processing. In other circumstances, the organisation receiving your information will be separately responsible to you and use your personal information in the ways described in its privacy statement (and not ours).

You will always have the option not to receive marketing communications from us. We will never send you unsolicited ‘junk’ email or communications, or share your data with anyone else who might. We do not sell your information to third parties, but we do work closely with our authorised dealers and repairers, Newton Trailers Limited and selected partners who help us to provide you with the information, products and services that you request from us. For example, Wabco, who provides diagnostics and trailer assistance on our behalf.

The contents of this statement may change from time to time so you may wish to check this page occasionally to ensure you are still happy to share your information with us. Where possible, we will also contact you directly to notify you of any substantial changes.

This version of our Privacy Statement is live from 3rd January 2024.

What information do we collect?

How do we use this information?

How do we share information?

How long do we keep your information for?

We collect information about you or your vehicle/trailer when you use Newton Trailers Limited websites, applications and our customer service centres. We also obtain information about you or your vehicle/trailer from our authorised dealers and repairers, Newton Trailers Limited and other companies who provide services to us, such as external agencies, consultants and IT providers. Some of this information does not identify you personally, but provides us with information about how you use our services and engage with us (we use this information to improve our services and make them more useful to you).

The information we collect includes some or all of the following:

1. Name (including title);
2. Address;
3. Phone number;
4. Date of birth;
5. Email address;
6. Vehicle information (including registration number, vehicle identification number (VIN), service reminders, mileage and warranty repair information);
7. The date and time you used our services;
8. The pages you visited on our website, the features you used and how long you visited us for;
9. Your IP address;
10. Your GPS location (where you have permitted access to this);
11. The Internet browser and devices you are using;
12. Cookie, Pixels or Beacon information
13. The website address from which you accessed our website;
14. Details of any transactions between you and us or any authorised repairer;
15. Where you engage with us in a business context, we may collect your job title, company contact details (including email addresses), fleet size and company details (some of which we may obtain from online or public business directories, including social media);
16. Voice recordings of calls you make to our customer service centre;
17. “Live chat” records;
18. Live Transcription records of your calls, messages, chats and WhatsApp
19. Any information within correspondence you send to us including in any competition entries you submit;
20. Your social media name and identification number, any information you post on our social media pages, posts in which you include a hashtag or mention relating to us and information regarding your activities on our social media pages generally (for example, the time and date of your posts and your ‘likes’);
21. Your direct marketing preferences;
22. Details of services provided by our group companies authorised dealers that you have received or for which you have registered;
23. Information we receive about you from data cleansing, enrichment and other data providers such as Experian Ltd, Creditsafe; Vehicle Weighing Solutions and DVSA including information about your age, income, life stage, location, financial, shopping and digital attitudes, household composition, company directorships, likelihood of owning a motor vehicle/trailer, vehicle/trailer ownership, current address; business address; number of staff; operating segment; weigher system location; weigher activity, weights and internal trailer body status/picture/ contents/ segment
24. Where you act on behalf of a business, any information we collect as part of business telemarketing activity;
25. Where your vehicle is financed by Newton Trailers Limited we may collect basic agreement information (agreement end date, parity date, service plan details, extended warranty information and finance agreement length).
26. Where you sign up to single login, connected vehicle/trailer and other services provided by the manufacturer of your vehicle (who is a company in our group), we may receive information about your account, profile or vehicle, including usage information;
27. Information about your insurance policies relating to your vehicle/trailer, including the type, level and period of cover, which we receive from insurance companies or brokers
28. Any personal information that we obtain from you directly is provided to us on a voluntary basis. However, if you do not give this information to us, you may be unable to receive certain services from us or our partners or communicate with us effectively.

Newton Trailers Limited will only process information that is necessary for the purpose for which it has been collected. You will always have the option not to receive marketing communications from us (and you can withdraw your consent or object at any time). We will never send you unsolicited ‘junk’ email or communications, or share your personal information with anyone else who might.

There are various ways in which we may use or process your personal information. We list these below:

Consent

Where you have provided your consent, we may use and process your information:

1. To contact you from time to time about promotions, events, products, services or information which we think may be of interest to you (don’t worry, we won’t bombard you);
2. To share your personal information with our recommended third party partners, so that they can contact you with marketing information about their products and services (we will, of course, give you details about these third parties before you give your permission for us to send information to them).
3. Where the vehicle manufacturer/trailer manufacturer has obtained your consent on our behalf:
   • To undertake market analysis and research; and
   • To use mathematical and statistical methods to create information and offers customised for you based on your information, including by making predictions about your behaviour.

We rely on our legitimate interests as the legal reason to use your information for these purposes if we collect your information from another source.

You can withdraw your consent at any time by contacting us on the details here or, in relation to any marketing messages you receive, by using the unsubscribe option included in those messages.

Contractual Performance

We may use and process your personal information where this is necessary to perform a contract with you and to fulfil and complete your orders, purchases and other transactions entered into with us (or one of our authorised dealers or selected partners).

Legitimate Interests

We may use and process your personal information as set out below where it is necessary for us to carry out activities for which it is in our legitimate interests as a business to do so.

Processing necessary for us to support customers with sales and other enquiriess

Processing necessary for us to support customers with sales and other enquiries

1. To respond to correspondence you send to us and fulfil the requests you make to us (for example: test drives, service requests, brochure requests or information about specific vehicles);
2. To provide vehicle support and services (for example warranty services);
3. To provide service, maintenance and warranty information and reminders, unless you object;

Processing necessary for us to respond to understanding our customers’ needs

4. To analyse, evaluate and improve our products and services so that your visit and use of our website, applications, customer service centre and dealer network are more useful and enjoyable (we will generally use data amalgamated from many people so that it doesn’t identify you personally);
5. To undertake market analysis and research (including contacting you with customer surveys) so that we can better understand you as a customer and provide tailored offers, products and services that we think you will be interested in.
6. For product development purposes (for example to improve vehicle quality, performance and safety);
7. We use automated methods to analyse, combine and evaluate information that you have provided to us (including by using information we receive from third party data providers and by receiving and sharing your personal information within our group of companies like Newton Trailers Limited).

We collect and analyse this information in this way so that we can deliver the most appropriate customer experience to you by tailoring and making relevant all our services and communications, including by making predictions about your current or future needs or interests (for example, when you might be ready to change your vehicle and the models you may be interested in);

Processing necessary for us to promote our business, brands and products and measure the reach and effectiveness of our campaigns

8. To contact you from time to time with marketing information after you have purchased a product or service from us, made a purchasing enquiry or requested a test drive, brochure or other information of interest. We will only contact you with information about our own products and services (and in ways the law allows), which we hope you will like. You have the right to object to us sending you this information at any time;
9. To contact you from time to time with marketing information (unless you object) if you have expressly indicated to us that you are acting on behalf of a corporate business or where we have obtained your corporate business contact details from our authorised dealer network or an online or public business directory. In relation to any such information we send by email or SMS, we will include an option allowing you to object to receiving future messages by unsubscribing;
10. To tailor the marketing information we send based on information we hold about you (e.g. by sending offers and information based on a vehicle you own).
11. To use mathematical and statistical methods to create information and offers customised for you based on your information, including by making predictions about your behaviour. This may include predicting your preferences, suitable product recommendations, your likelihood of making another purchase or your loyalty to a vehicle brand or model.
12. To identify and record when you have received, opened or engaged with our website or electronic communications.
13. To administer competitions and promotions that you enter with us from time to time and to distribute prizes;
14. To send you information on our extended warranty products where you are benefiting from a current warranty and it is about to expire. You have the right to object to us sending this information at any time;
15. To identify the extent to which your interactions and communications with us or our content contributed to your engagement with us or our brands; Processing necessary for us to communicate with you and to assess and respond to complaints, claims and regulators
16. To communicate with you (including through social media) including to respond to queries, complaints or claims and to manage legal and regulatory requests and requirements;
17. To enforce or protect our legal rights or to establish, bring or defend legal claims;

Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively

18. To verify the accuracy of information that we hold about you and create a better understanding of you as a customer. We may use information about you from third party data providers for this purpose, including data cleansing service providers that provide the latest home address or vehicle ownership information for you;
19. For network and information security purposes i.e. in order for us to take steps to protect your information against loss, damage, theft or unauthorised access;
20. 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);
21. To inform you of updates to our terms and conditions and policies;
22. For cookies that are essential for our website to function properly.
23. To contact you when we or your local authorised dealer opens, closes, moves premises or is no longer an authorised dealer

Legal Obligation

We may process your personal information to comply with our legal or regulatory requirements (for example to register your vehicle/trailer with the DVLA, to assist, or respond to a request for information from, an authorised authority, regulatory body or court, or to respond to a court order).

Vital Interest

Sometimes we will need to process your personal information to contact you if there is an urgent safety or product recall notice and we need to tell you about it. Newton Trailers Limited will only process information that is necessary for the purpose for which it has been collected. You will always have the option not to receive marketing communications from us (and you can withdraw your consent or object at any time). We will never send you unsolicited ‘junk’ email or communications, or share your personal information with anyone else who might.

There are various ways in which we may use or process your personal information. We list these below:

Consent

Where you have provided your consent, we may use and process your information:

1. To contact you from time to time about promotions, events, products, services or information which we think may be of interest to you (don’t worry, we won’t bombard you);
2. To share your personal information with our recommended third-party partners, so that they can contact you with marketing information about their products and services (we will, of course, give you details about these third parties before you give your permission for us to send information to them).
3. Where the vehicle manufacturer/trailer manufacturer has obtained your consent on our behalf:
   • To undertake market analysis and research; and
   • To use mathematical and statistical methods to create information and offers customised for you based on your information, including by making predictions about your behaviour.

We rely on our legitimate interests as the legal reason to use your information for these purposes if we collect your information from another source.

You can withdraw your consent at any time by contacting us on the details here or, in relation to any marketing messages you receive, by using the unsubscribe option included in those messages.

Contractual Performance

We may use and process your personal information where this is necessary to perform a contract with you and to fulfil and complete your orders, purchases and other transactions entered into with us (or one of our authorised dealers or selected partners).

Legitimate Interests

We may use and process your personal information as set out below where it is necessary for us to carry out activities for which it is in our legitimate interests as a business to do so.

Processing necessary for us to support customers with sales and other enquiries

1. To respond to correspondence you send to us and fulfil the requests you make to us (for example: test drives, service requests, brochure requests or information about specific vehicles);
2. To provide vehicle/trailer support and services (for example warranty services);
3. To provide service, maintenance and warranty information and reminders, unless you object;
4. Where we act as an authorised dealer; for example for Knapen Trailers; STAS Trailers; SDC Trailers; Muldoon Trailers; we will be required to share information with the manufacturer that allows them to contact you directly and transfers your consents as appropriate to their information systems. This allows them for example in the case of a safety recall to contact you directly.

Processing necessary for us to respond to understanding customers’ and drivers’ needs

5. To analyse, evaluate and improve our products and services so that your visit and use of our website, applications, customer service centre and dealer network are more useful and enjoyable (we will generally use data amalgamated from many people so that it doesn’t identify you personally);
6. To undertake market analysis and research (including contacting you with customer surveys) so that we can better understand you as a customer and provide tailored offers, products and services that we think you will be interested in. We will only send such offers to you if you have provided your consent for us to do so;
7. For product development purposes (for example to improve vehicle quality, performance and safety);
8. We use automated methods to analyse, combine and evaluate information that you have provided to us (including by using information we receive from third party data providers and by receiving and sharing your personal information within our group of companies like Newton Trailers Limited.

We collect and analyse this information in this way so that we can deliver the most appropriate customer experience to you by tailoring and making relevant all our services and communications, including by making predictions about your current or future needs or interests (for example, when you might be ready to change your vehicle and the models you may be interested in);

Processing necessary for us to promote our business, brands and products and measure the reach and effectiveness of our campaigns

9. To contact you from time to time with marketing information after you have purchased a product or service from us, made a purchasing enquiry or requested a test drive/hire, brochure or other information of interest. We will only contact you with information about our own products and services (and in ways the law allows), which we hope you will like. You have the right to object to us sending you this information at any time;
10. To contact you from time to time with marketing information (unless you object) if you have expressly indicated to us that you are acting on behalf of a corporate business or where we have obtained your corporate business contact details from our authorised dealer network or an online or public business directory. In relation to any such information we send by email or SMS, we will include an option allowing you to object to receiving future messages by unsubscribing;
11. To tailor the marketing information we send based on information we hold about you (e.g. by sending offers and information based on a vehicle you own).
12. To use mathematical and statistical methods to create information and offers customised for you based on your information, including by making predictions about your behaviour. This may include predicting your preferences, suitable product recommendations, your likelihood of making another purchase or your loyalty to a vehicle/trailer brand or model.
13. To identify and record when you have received, opened or engaged with our website or electronic communications.
14. To administer competitions and promotions that you enter with us from time to time and to distribute prizes;
15. To send you information on our extended warranty products where you are benefiting from a current Newton Trailers Limited warranty and it is about to expire. You have the right to object to us sending this information at any time;
16. To identify the extent to which your interactions and communications with us or our content contributed to your engagement with us or our brand; Processing necessary for us to communicate with you and to assess and respond to complaints, claims and regulators
17. To communicate with you (including through social media) including to respond to queries, complaints or claims and to manage legal and regulatory requests and requirements;
18. To enforce or protect our legal rights or to establish, bring or defend legal claims; Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively
19. To verify the accuracy of information that we hold about you and create a better understanding of you as a customer. We may use information about you from third party data providers for this purpose, including data cleansing service providers that provide the latest home address or vehicle ownership information for you;
20. For network and information security purposes i.e. in order for us to take steps to protect your information against loss, damage, theft or unauthorised access;
21. 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);
22. To inform you of updates to our terms and conditions and policies;
23. For cookies that are essential for our website to function properly.
24. To contact you when your local authorised dealer opens, closes, moves premises or is no longer an authorised dealer.

Legal Obligation

We may process your personal information to comply with our legal or regulatory requirements (for example to register your vehicle/trailer with the DVLA, to assist, or respond to a request for information from, an authorised authority, regulatory body or court, or to respond to a court order).

Vital Interest

Sometimes we will need to process your personal information to contact you if there is an urgent safety or product recall notice and we need to tell you about it.

We do not sell your information to third parties, but we do work closely with our dealer network, Newton Trailers Limited, our group companies and with third party suppliers who fulfil business activities for us (like roadside assistance, marketing, events, social media platforms and market research etc.)

Service providers. We do not sell your information to third parties. However, we may from time to time disclose your information to the following categories of companies or organisations to which we pass the responsibility to handle services on our behalf: roadside assistance service providers, customer contact centres, mobility and car hire providers, hosting providers, data cleansing and verification providers, direct marketing communications agencies and consultants, market research and market analytics service providers, our legal and other professional advisors.

Dealers. We will also share your information with our authorised supplier and our authorised dealer network in situations where we need to pass your information to them in order to manage any request, provide a service (including to fulfil and manage your orders) or handle any complaint you may have made to us. For example, where you have requested a test drive/hire, we will need to share your personal information with your selected dealer so that they can contact you to arrange for the test drive/hire to take place.

Sharing for legal reasons. We will also share your personal information if we have a duty to do so, e.g. to register your car with the DVLA, to assist an authorised authority, regulatory body or court, or to enforce or protect our legal rights or to establish, bring or defend legal claims.

Group companies. There are also circumstances where we share your information with our parent (Beachampton Group Limited) in order to understand you as a customer, fulfil orders, transactions, handle complaints or provide you with a service or information that you have requested. For example, we will share information with End Finance Services UK Limited or Moorgate Finance Limited where you enquire about their services through us or where you make a complaint to us and later make the same or similar complaint to them. End Finance Limited may use your information to provide you with information and carry out their obligations arising from contracts you enter into with them. For more information, please see their privacy statement.

Social Media Platforms

We use a number of different social media platforms to communicate with you and to promote products and services. We process your personal information using these platforms in a variety of ways, as follows:

Pages. We use your personal information when you post content or otherwise interact with us on our official pages on Facebook, Instagram, LinkedIn, X, Snapchat, TikTok and other social media platforms. We also use the Page Insights service for Facebook, Instagram and LinkedIn to view statistical information and reports regarding your interactions with the pages we administer on those platforms and their content. Where those interactions are recorded and form part of the information we access through these Page Insights services, we and the relevant platform are joint controllers of the processing necessary to provide that service to us.

Safeguards

Transfers outside Europe. Due to the international nature of our business, there may be some instances where your information is processed or stored outside of the UK and EU. In those instances, we will ensure that appropriate safeguards are in place for that transfer and storage as required by applicable law.

Safeguards. We take steps to ensure that any third-party partners who handle your information comply with data protection legislation and protect your information just as we do. We only disclose personal information that is necessary for them to provide the service that they are undertaking on our behalf. We will aim to anonymise your information or use aggregated none specific data sets where ever possible.

Retention Policy

We will not hold your personal information in an identifiable format for any longer than is necessary. If you are a customer or otherwise have a relationship with us we will hold personal information about you for a longer period than if we have obtained your details in connection with a prospective relationship.

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

Customer/driven relationships. If we have a relationship with you (e.g. you are a customer or the registered driver of a leased or hired or other vehicle purchased from us or an authorised dealer), we hold your personal information for 25 years from the date our relationship ends. We hold your personal information after our relationship ends to establish, bring or defend legal claims. For clarity, if you have provided your consent, we will continue to send marketing to you during those 25 years unless you opt-out. Our relationship may end for a number of reasons including where the vehicle warranty or lease expires, or we have been made aware that you no longer own or drive that vehicle.

Prospective relationships. Where we have obtained your personal information following a request for information, test drive/ trial rental, brochure, quotation or any other information on any of our products or services, we hold your personal information for 25 years from the date we collect that information, unless during that period we form a relationship with you e.g. you purchase or lease a vehicle or consent for us to send you marketing information.

Where you have consented to receive marketing, regardless of whether or not we have a prospective relationship with you based on an information request, we will retain information we need to market to you for 25 years from the date consent was given. Each time you provide your consent, the time period will refresh.

We hold your personal information for the above periods to give us an opportunity to form a relationship with you.

Exceptions. The only exceptions to the periods mentioned above are where:

• The law requires us to hold your personal information for a longer period, or delete it sooner;
• Where you have raised a legal claim, complaint or concern regarding a product or service offered by us, in which case we will retain your information for a period of 6 years following the date of that complaint or query; or
• 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 or required under the law (see further How can I manage the information we hold about you below).

You have the right as an individual to access your personal information we hold about you and make corrections if necessary. You also have the right to withdraw any consent you have previously given us and ask us to erase information we hold about you. You can also object to us using your personal information (where we rely on our business interests to process and use your personal information).

You have a number of rights in relation to your personal information under data protection law. In relation to most rights, we will ask you for 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 1 month after we have received any request (including any identification documents requested).

You have the right to:

1. Ask for a copy of the information that we hold about you;
2. Correct and update your information;
3. Withdraw your consent (where we rely on it). Please see further 'How do we use this information' above;
4. Object to our use of your information (where we rely on our legitimate interests to use your personal information) provided we do not have any continuing lawful reason to continue to use and process the information. When we do rely on our legitimate interests to use your personal information for direct marketing, we will always comply with your right to object;
5. Erase your information (or restrict the use of it), provided we do not have any continuing lawful reason to continue to use and process that information;
6. Transfer your information in a structured data file (in a commonly used and machinereadable format), where we rely on your consent to use and process your personal information or need to process it in connection with your contract.

You also have the right not to be subject to purely automated decisions (including profiling) where this has a significant effect on you. We do not envisage that any decisions will be taken about you in this way, however we will update this statement if this changes.

Cookies

To allow our website to keep track of and process any orders you create, a small data file containing an encrypted unique identifier is sent and stored by your computers' web browser in the form of a cookie. The cookies on our website do not collect any personal data about you and are used solely for the purposes of identifying you to our systems through the order process.

If you wish, you can usually adjust your browser so that your computer does not accept cookies but in order to make an online purchase with us you must have cookies enabled.

Please remember our cookies do not contain confidential information such as your home address, telephone number or credit card details. We do not exchange cookies with any third party websites or external data suppliers.

Newton Trailers utilises the use of Google Analytics Services throughout the Newton Trailers Website. For more information on how Google uses information collected from sites or apps that use their services, please refer to Googles Privacy Policies at https://policies.google.com/technologies/partner-sites

Security

We endeavour to take all reasonable steps to protect the personal information you supply when placing an order, this includes the use of leading encryption technologies. However, due to the inherent open nature of the Internet we cannot guarantee that communications between you and us will be free from unauthorised access by third parties. Your use of our website demonstrates your acceptance of this risk.

Contact

You can exercise the above rights and/or manage your information by contacting us using the details below:

Post: Newton Trailers Limited, Station Yard, Station Road, Ridgmont, MK430XP
Email: accounts@newtontrailers.com
Phone: 01525 872466

If you have any specific data protection concerns or a complaint, you can address it to our Data Protection Team at accounts@newtontrailers.com

If you are unhappy, you have the right to lodge a complaint with a data protection regulator in Europe, in particular in a country you work or live or where your legal rights have been infringed. The contact details for the Information Commissioner’s Office, the data protection regulator in the UK, are below:

Post:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF