CUPRA UK – Privacy Statement
CUPRA UK (including the SEAT brand), a trading division of Volkswagen Group United Kingdom 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, Volkswagen Financial Services and selected partners who help us to provide you with the information, products and services that you request from us. For example, the AA who provides roadside 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 the 5th November 2020.
What information do we collect?
We collect information about you and your vehicle when you engage with our website, social media pages, applications or customer services centre. We also receive such information from third party sources including our group companies, data providers and our authorised dealer network. We only collect information which is necessary, relevant and adequate for the purpose you are providing it for.
We collect information about you or your vehicle when you use CUPRA UK’s (including the SEAT brand) websites, applications and our customer service centres. We also obtain information about you or your vehicle from our authorised dealers and repairers, Volkswagen Financial Services 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);
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;
13. The website address from which you accessed our website;
14. Details of any transactions between you and us or any authorised dealer;
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. Any information within correspondence you send to us including in any competition entries you submit;
19. 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’);
20. Your direct marketing preferences;
21. Details of services provided by our group companies or authorised dealers that you have received or for which you have registered;
22. Information we receive about you from data cleansing, enrichment and other data providers such as Experian Ltd, Sky UK Ltd and Auto Express (GB) Ltd including information about your age, income, life stage, location, financial, shopping and digital attitudes, household composition, company directorships, likelihood of owning a motor vehicle, vehicle ownership, current address;
23. Where you act on behalf of a business, any information we collect as part of business telemarketing activity; and
24. Where your vehicle is financed by Volkswagen Financial Services we may collect basic agreement information (agreement end date, parity date, service plan details, extended warranty information and finance agreement length).
25. Where you sign up to single login, connected vehicle 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.
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.
How do we use this information?
CUPRA UK (including the SEAT brand) 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:
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 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.
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).
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 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 customers’ and drivers’ 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. We will only send such offers to you if you have provided your consent for us to do so;
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 Volkswagen Financial Services), see details about our relevant group companies below:
• Volkswagen Financial Services (UK) Limited
• Volkswagen AG
• Audi AG
• SEAT S.A
• SEAT CUPRA, S.A.U.
• SKODA AUTO a.s.
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 contact you with targeted advertising delivered online through social media, search engines, third party websites and applications and other platforms operated by other companies, unless you object. You may receive advertising based on information about you that we have provided to the platform or allowed it to collect using cookies on our website or code in our applications (or a combination of the two). You may also receive advertising because, at our request, the platform has identified you as falling within a group whose attributes we have selected or a group that has similar attributes to the individuals whose details it has received from us (or a combination of the two). To find out more, please refer to the information provided in the help pages of the platforms on which you receive advertising from us. Please also see the section below for further information regarding our use of social media platforms specifically;
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 CUPRA or SEAT 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;
24. To contact you when your local authorised dealer opens, closes, moves premises or is no longer an authorised dealer.
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 dealer network, Volkswagen Financial Services, 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 dealer network in situations where we need to pass your information to them in order to manage any request, provide a service or handle any complaint you may have made to us. For example, where you have requested a test drive, we will need to share your personal information with your selected dealer so that they can contact you to arrange for the test drive 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 (or other companies within our Group) 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 Volkswagen Financial Services UK 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. Volkswagen Financial Services UK 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, Twitter, 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.
Our relationship with Facebook and LinkedIn. As we are joint controllers with these platforms for certain processing, we and each platform have:
- entered into agreements in which we have agreed each of our data protection responsibilities for the processing of your personal information described above;
- agreed that we are responsible for providing to you the information in this privacy statement about our relationship with each platform; and
- agreed that each platform is responsible for responding to you when you exercise your rights under data protection law in relation to that platform’s processing of your personal information as a joint controller.
Facebook and LinkedIn also processes, as our processor, personal information that we submit for the purposes of matching, online targeting, measurement, reporting and analytics purposes. These services include the processing these platforms carry out when they display our advertisements to you in your news feed at our request after matching contact details for you that we have uploaded to them. These advertisements may include forms through which we collect contact information you give to us.
Further information. The Facebook company that is a joint controller of your personal information is Facebook Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The LinkedIn company that is a joint controller of your personal information is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. For further information regarding these platforms and their use of your personal information, please see:
- Facebook’s Controller Addendum for Page Insights and Controller Addendum for Business Tools and LinkedIn’s Page Insights Joint Controller Addendum which include information regarding how our and those platforms’ responsibilities to you are allocated as controllers of your personal information;
- Facebook’s help pages regarding its Page Insights and Business Tools and its terms and conditions relating to those tools; and
- LinkedIn’s help pages regarding its Page Insights and its terms and conditions relating to its advertising services, including LinkedIn Insight Tag.
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.
How long do we keep your information for?
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.
If we have a relationship with you (e.g. you are a customer or the registered driver of a leased or other vehicle purchased from us or an authorised dealer), we hold your personal information for 6 years from the date our relationship ends. We hold your personal information after our relationship ends to establish, bring or defend legal claims. 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.
Where we have obtained your personal information following a request for information, test drive, brochure, quotation or any other information on any of our products or services, we hold your personal information for 1 year and 6 months 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 relationship with you, we will retain information we need to market to you for 3 years and 6 months 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.
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);
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.
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.
You can exercise the above rights and/or manage your information by contacting us using the details below:
Post: CUPRA Customer Services, PO Box 9004, LEEDS, LS1 9WA
Phone: 0800 049 7106
If you have any specific data protection concerns or a complaint, you can address it to our Data Protection Team at firstname.lastname@example.org.
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:
Information Commissioner's Office
Cheshire SK9 5AF
Call: 0303 123 1113