PRIVACY NOTICE

Constellation Automotive Group Staff Discount Promotion

This Notice has been created to inform you regarding how your personal data is processed in relation to the TDR Group Staff Discount Promotion, as described in the Promotion Terms and Conditions here. This Notice supplements cinch’s general Privacy Policy and Cookies Notice (available here) which applies to our other processing of personal data (in relation to car purchases on and other use of cinch.co.uk).

  1. Who is the data controller of your data?

    A "data controller" is the organisation that decides on the purposes and ways that your personal data is used. In relation to the Promotion, this is:
    Cinch Cars Limited of
    Headway House
    Crosby Way
    Farnham GU9 7XG, UK
    Email: DPO-Office@cinch.co.uk

    If you make a claim for a discount under the Promotion, we will need to exchange your data with your employer in order to verify the claim. They are also a data controller and you should consult with them for further details of how they may process your data.

  2. Why do we process personal data? What data do we process? And what is our lawful basis for that processing?

    We will ask for the following data in order for you to make your claim:

    1. Your order number (given to you when you make a purchase from cinch.co.uk)
    2. Name of your employer
    3. Your unique promotional code (given to you by your employer)
    4. Your name
    5. Email address
    6. Home address
    7. Bank account number and sort code
    8. Follow up information in case of a query regarding your claim.

    We require this data for the following purposes, based on the following legal bases:

    1. To identify you – or the relevant member of your household if you have given your discount to them – as a claimant
    2. To correspond with you regarding the Promotion
    3. To verify that your claim is valid (e.g. whether the car has been returned, or that two claims have been made using the same unique code)
    4. To pay you the discount under the Promotion

    Our legal basis for this processing is that it is necessary for us to perform our contractual obligations to provide the discount under the Promotion Terms and Conditions.

    1. To assist any public or law enforcement authority, for compliance with our legal and regulatory responsibilities in relation to the Promotion and payments, to comply with a request from you in connection with the exercise of your rights under data protection laws, and to verify the accuracy of data we hold about you.

    Our legal basis for this processing is that it is necessary for us to comply with our legal obligations.

  3. How long will cinch keep your data?

    In relation to the Promotion, cinch will not keep your personal data for any longer than necessary to complete the Promotion and pay and account for payments, also allowing for a reasonable period for any queries or disputes to be raised and settled.

    In relation to your car purchase or if you have signed up for an account with cinch, then your data will be held and processed in accordance with our general Privacy Policy and Cookies Policy.

  4. Does cinch provide your personal data to any third parties?

    We’ll need to exchange data with your employer in order to verify your claim.

    cinch will also work with other organisations that provide services such as management of the Promotion and payment of the promotional discounts. These organisations process personal data on our behalf, but our contracts with them oblige them to meet data protection standards as strict as the ones that apply to us, and not to use your data for any other purpose.

    Other circumstances where cinch may need to disclose your personal data to third parties could be: (i) where required by law, stock exchange rules, or any governmental authority, police force, court or regulator; (ii) to enforce or apply the terms of our contracts or to protect the rights, property or safety of our customers; or (iii) in connection with a sale, merger or restructuring of our business or company.

  5. What are your rights in relation to your personal data?

    cinch is committed to ensuring that you can easily exercise your legal rights over your personal data under the laws that apply to us.

    For example, you are entitled to ask at any time:

    • for access to a copy of the personal data that cinch holds about you
    • to have any incorrect personal data about you corrected
    • for data about you to be erased (also referred to as the "right to be forgotten") or if that is not possible (e.g. because the law requires us to keep data for longer) to have processing restricted
    • to object to particular processing
    • to receive an electronic copy of data that you provided to us, for provision to a different service provider (also referred to as "data portability").

    You are also able to withdraw any consent given by you in the past. If you withdraw your consent, any processing of the data that took place before you do so will still be legal.

    cinch can always be contacted at the addresses in Section 1 to resolve any issues or doubts you may have in relation to processing of your data, or exercising your legal rights. If you believe that your rights have not been respected then you are also entitled to complain to the relevant data protection Supervisory Authority (in the UK, the Information Commissioner www.ico.org.uk) to ask them for a decision.

  6. Do you have to provide your personal data to cinch?

    Yes. cinch is not able to operate the Promotion or verify or make payments without processing your personal data as described in this Notice (so for example if you did not provide all personal data required, we might not be able to verify your claim or pay your discount).