Ford Retail Limited trading as TrustFord and TrustFirstParts is the controller and responsible for your personal data (collectively referred to as "TrustFord", "We", "Us" or "our"). We are committed to protecting and respecting your privacy.
From time to time we also work with, or act on behalf of, third parties to assist them in providing goods and services to you such as insurance providers and commercial fleet customers. In these circumstances we would normally act as a data processor on behalf of the relevant third party and will therefore only process your data in accordance with their instructions.
This policy (together with our Website Terms and Conditions and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us as data controller. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Our full details are:
Full name of legal entity: Spellbound Holdings Ltd
Email address: firstname.lastname@example.org
Postal address: 26 New Street, St Helier, JE2 3RA
Telephone number: 01206 754600
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.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.
Information we collect from you
The data we collect about you
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).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, driving licence details.
- Contact Data includes contact address, billing address, delivery address, email address and telephone numbers.
- Vehicle Data includes registration number, chassis number, and registered address.
- Financial Data includes bank account and payment card details, your credit rating and history.
- Transaction Data includes details about payments to and from you and other details of vehicles, parts and other products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, unique visitor ID generated when you visit our websites, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, device, operating system and platform and other technology on the devices you use to access our websites, referring website details, details of searches carried out by you on our websites.
- Profile Data includes your username and password, purchases or orders made by you, vehicle data points of individual vehicles viewed by you on our website (e.g. make, model, price, reg number), your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communication Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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 notice.
Unless we expressly inform you otherwise we will 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.
If you fail to provide personal data
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 is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions.
You may give us your Identity, Contact, Financial, Vehicle, Profile, Marketing and Comunication Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback.
- Automated technologies or interactions.
As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please also see "Cookies" below for further details.
Third parties or publicly available sources.
We may receive personal data about you from various third parties and public sources as set out:
- Technical Data from the following parties:
- analytics providers;
- advertising networks; and
- search information providers.
- Contact, Financial and Transaction Data from providers of credit referencing, technical, payment and delivery services.
- Identity, Contact and Vehicle Data from publicly availably sources.
Aggregated Site Usage Statistics
Cookies may be placed on your computer, phone or other Internet device to provide us with aggregated data of the usage of this site and the mediums which are driving traffic to the site. The data gathered by these is aggregated and therefore your individual usage of this site cannot be attributed to you.
Essential Site Features
Cookies may be placed upon your computer, phone or other Internet device in order to provide essential site features such as allowing you to compare different cars in stock and complete enquiry forms quickly.
Complimentary Site Features
Uses made of the information
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:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- 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.
- Where we need to comply with a legal or regulatory obligation.
We have set out below some more information about the types of lawful basis that we will rely on to process your personal data.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at email@example.com.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that 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 at firstname.lastname@example.org. if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
||Type of data
||Lawful basis for processing including
|To register you as a new customer
|Performance of a contract with you
|To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To enable you to partake in a prize draw, competition or complete a survey
(e) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
|To make suggestions and recommendations to you about goods or services that may be of interest to you
|Necessary for our legitimate interests (to develop our products/services and grow our business)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. [We have established a privacy centre where you can view and make certain decisions about your personal data use www.trustford.co.uk/communications/], or you can contact us at email@example.com at any time to tell us about your preferences.
Promotional offers from us
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).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside the TrustFord group of companies for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time [by logging into the Preference Centre and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or] by contacting us at firstname.lastname@example.org at any time].
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, warranty registration, product/service experience or other transactions.
Change of purpose
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 receive an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at email@example.com.
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.
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.
Disclosure of your information
We may have to share your personal data with the parties set out below for the purposes set out in the table above:
Ford Motor Company and any member of the Ford Motor Company Group, including FCE Bank PLC ("Ford Credit"). A list of the companies within Ford Motor Company Group is available at http://corporate.ford.com/homepage.html.
Other selected vehicle finance providers who we work with.
Providers of customer satisfaction surveys , for the purposes of collating and analysing data on customer satisfaction levels within our customer base. The results of this data analysis
Selected third parties who process your data on our behalf, including:
Vehicle service plan providers, where you request or enquire about a service plan;
Software providers, including:
- providers of dealership management systems, which we use to process and manage the goods and services we provide to you, any financial arrangements between us and you, and the information we hold about you;
- systems for capturing your data as part of the sales process or when you make an enquiry with us;
- CRM systems;
- Vehicle appraisal systems for the purposes of assessing the condition and value of your vehicle
Auditors and quality assurance consultants for the purposes of ensuring we comply with legal and regulatory obligations;
Providers of insurance and warranty products, and other ancillary services and products;
Payment service providers;
Delivery service providers;
The providers of our website and related content management systems;
IT network providers;
analytics and search engine providers that assist us in the improvement and optimisation of our site, products and services;
credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you;
providers of systems which capture and broadcast video of your vehicle for the purposes of appraising you of the work we are undertaking on your vehicle;
We may collect information about you through systems which are provided and hosted by a third party, such as the provider of this site and e-commerce platforms which we utilise in certain areas of our business.
We will also disclose your personal information to third parties:
In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
If Ford Retail Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
For a full list of third parties whom we share data with please contact us.
We share your personal data within the Ford Group. This will occasionally involve transferring your data outside the European Economic Area (EEA).
Some of our external third party suppliers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
Where we store your personal data
We will store the data we collect from you in line with our data retention policy, copies of which can be obtained on request in writing to The Data Protection Officer, TrustFord, 2 Charter Court, Colchester, CO4 9YA, or by emailing firstname.lastname@example.org.
All hard copy information you provide to us is stored and disposed of securely at our sites.
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 data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
You can exercise your rights by telling us your preferences when we collect your data or by contacting us at any time.
Information you provide to Ford Credit
You may also use www.trustford.co.uk to view Ford Credit finance products and we may assist you with applying for such products online or when you visit our dealerships. Ford Credit may request additional personal information from you in order to verify your identity and allow access to your Ford Credit account. Ford Credit will use this personal information as described when you apply for finance, or once you are a Ford Credit customer, as set out in your agreement with Ford Credit.
TrustFord does not represent, warrant, endorse or hold responsibility over any external sites that may be linked to and from this site. Any external site that you visit by clicking through a link on this site is outside the control of TrustFord and you visit entirely at your own risk.
The site may contain links to other sites which are outside our control and are not covered by this Policy. If you access other sites using the links provided, the operators of those sites may collect information from you which will be used by them in accordance with their privacy policies, which may differ from ours.
The site may also offer you the opportunity to share or follow information about TrustFord, the Site or the products and/or services available through it using third party social networking functionality (such as through "share this", "like" or "follow" buttons).
We offer this functionality in order to generate interest in the site among the members of your social networks, and to permit you to share and follow opinions, news and recommendations about the site with your contacts. However, you should be aware that sharing personal information with a social network may result in that information being collected by the social network provider and being made publicly-available, including through internet search engines.
Other Legal Notices
All rights, including copyright and database right, in the website and its contents, are owned by or licensed to TrustFord, or otherwise used by TrustFord as permitted by applicable law or the copyright holder. You may not copy, reproduce, republish, download, post, broadcast or transmit any text, images, graphic, logo, button, icon, image and their selection and arrangement thereof, and any underlying source code and software, for any commercial or public purpose without prior written permission from TrustFord or the copyright holder.
You may not adapt, alter or create any of the material or information in this site or use it for any other purpose other than for your personal non-commercial use. You agree to use this site only for lawful purposes.
TrustFord reserves the right to use for its own purposes any material submitted to the site, including text and images, either on the site or in any other form, including for publicity purposes. TrustFord reserves the right to monitor submissions to the site and to edit or reject any submissions.
We try to ensure that information on our site is accurate, complete and up-to-date. In using this site, however, you agree to be bound by the Terms & Conditions, which take effect on the date when you first use the site.
Without prejudice to your statutory rights, the site and all information, text, names, images, pictures, logos, links and icons and other materials (without limitation) are provided 'AS IS' and on an 'IS AVAILABLE' basis without representation warranty or endorsement, express or implied. In particular, we do not warrant or represent the accuracy or completeness of information provided on this site nor do we guarantee that use of this site will be uninterrupted or error-free, or that the site and its servers are free of computer viruses or bugs.
In no event will TrustFord be liable to any person for any damage or loss that may arise from the use of any information contained in our site or products displayed on our site, including, without limitation, indirect or consequential damages, or any damages whatsoever arising from use or loss of use, data, or profits, whether in action of contract, negligence or other tortious action, arising out of or in connection with the use of the site.
Notwithstanding anything else in these Terms & Conditions, we will not be liable for claims relating to the functionality or availability of this site.
All names, images, logos identifying TrustFord are proprietary marks of TrustFord. All third party brand, product, service and company names contained on this site are the trademarks, service marks and trade names of their respective holders. TrustFord does not give permission for their use by any person other than the holders. Any such use may constitute an infringement of the holders' rights.
The software downloads from this site have been thoroughly scanned and tested at all stages of production, but - as with all new software - we still recommend that you run a virus checker before use. We also recommend that you have an up-to-date backup of your hard disk before using the software. TrustFord cannot accept responsibility for any disruption, damage and/or loss of data on your data or computer system that may occur while using the software. Consult your network administrator before installing any software on a networked computer.
These Terms & Conditions shall be governed by and construed in accordance with the laws of England and Wales. Disputes arising here shall be exclusively subject to the jurisdiction of the courts of England and Wales.
TrustFord reserves the right to change any of its terms and conditions at any time by posting changes online.
If you do not accept these Terms in full, you must stop using this website immediately.