Privacy Policy

1. Introduction

Pulman Group respects your privacy and is committed to protecting your personal information.

This Privacy Policy explains how we collect, use, store, share and protect personal information when you interact with us. This includes when you use our websites, submit an enquiry, visit one of our dealerships, contact our customer service teams, buy, lease, finance, rent, service or repair a vehicle, make a complaint, respond to marketing, or otherwise deal with a Pulman Group business.

This policy applies to our vehicle sales, fleet, leasing, contract hire, finance and insurance, aftersales, service, repair, warranty, parts, rental, customer support, marketing, website, telephone and CRM activities.

We may update this policy from time to time. The latest version will be available on our website.

2. Who we are

Pulman Group is the trading group of Mike Pulman Holdings Limited. References in this policy to “Pulman”, “Pulman Group”, “we”, “us” or “our” mean the relevant Pulman company, dealership, authorised repairer, trading style or business that you interact with.

The Pulman businesses and trading styles covered by this policy include;

• Pulman Volkswagen;
• Volkswagen Van Centre Durham;
• Pulman Fleet;
• National Vehicle Solutions;
•  Pulman SEAT;
• CUPRA Durham;
• CUPRA Sunderland;
• Pulman Škoda Durham;
• Pulman Škoda Cramlington

The relevant operating company will depend on which Pulman business you deal with.

Pulman Volkswagen, Volkswagen Van Centre Durham, Pulman Fleet and National Vehicle Solutions are trading styles of Mike Pulman Limited.

Pulman SEAT, CUPRA Durham and CUPRA Sunderland are trading styles of Pulman SEAT Limited.

Pulman Škoda Durham and Pulman Škoda Cramlington are trading styles of Pulman Škoda Limited.

Pulman Volkswagen, Volkswagen Van Centre Durham, Pulman Fleet and National Vehicle Solutions are trading styles of Mike Pulman Limited, which is authorised and regulated by the Financial Conduct Authority for credit broking and insurance distribution activities under reference number 308745. We are a credit broker, not a lender.

Pulman SEAT Limited and Pulman Škoda Limited are Appointed Representatives of Mike Pulman Limited, which is authorised and regulated by the Financial Conduct Authority for credit broking and insurance distribution activities under reference number 308745. We are a credit broker, not a lender.

Where Pulman Group companies share systems, staff, customer service, compliance, IT, marketing, reporting or management functions, your personal information may be processed within the Pulman Group for the purposes described in this policy.

3. How to contact us about data protection

If you have any questions about this policy, how we use your personal information, or if you wish to exercise your data protection rights, please contact:

Data Protection Team
Pulman Group
Abbey Road
Framwellgate Moor
Durham
DH1 5HA

Email: [email protected]
Telephone: 0800 0720 228

If these details change, the latest contact details will be available on our website.

4. What personal information we collect

The personal information we collect depends on how you interact with us. We may collect and use the following categories of information:

Identity and contact details

This may include your name, title, address, email address, telephone number, date of birth, driving licence details, proof of identity and proof of address where required.

Business and fleet information

Where you interact with us as a business, fleet, leasing or company vehicle customer, we may collect your business name, trading name, company number, VAT number, job title, business address, business email address, business telephone number, fleet size, replacement cycle, vehicle requirements and other relevant business information.

Vehicle information

This may include vehicle registration number, VIN, make, model, specification, mileage, ownership history, service history, MOT information, warranty information, repair history, diagnostic data, manufacturer records, recall information, valuation data and vehicle usage information you provide to us.

Enquiry and CRM information

This may include the details of your enquiry, vehicle interest, finance or leasing requirements, part-exchange details, test drive requests, service booking requests, quote requests, website form submissions, notes of conversations, customer preferences, contact preferences and enquiry outcomes.

Transaction and contract information

This may include vehicle orders, sales invoices, service invoices, repair orders, finance proposals, insurance product information, warranty products, payment information, deposits, refunds, delivery or collection arrangements and contract documentation.

Finance and insurance information

Where you ask us to assist with finance, leasing, insurance or related products, we may collect information required to discuss your needs and submit proposals. This may include employment details, affordability information, financial information, credit application details, bank details, income and expenditure information, product suitability information, documentation required by lenders or insurers, and records of discussions.

Communications information

This may include emails, letters, web forms, live chat, SMS messages, social media messages, telephone call records, call recordings, voicemail, call metadata and notes made by our staff.

Website, device and technical information

When you use our websites, we may collect information such as IP address, device type, browser type, pages visited, time spent on pages, referral source, website journey, cookie identifiers, analytics information and marketing attribution information.

Marketing information

This may include your marketing preferences, communication preferences, consent records, opt-out records, campaign activity, email engagement, events attended and areas of interest.

CCTV and site security information

If you visit one of our premises, CCTV may capture your image, vehicle or registration number. We may also keep visitor, incident or site security records where necessary.

Customer feedback and complaints

This may include survey responses, reviews, complaints, investigation records, correspondence, call recordings and evidence provided by you or third parties.

Vulnerability and additional support information

Where you tell us about a vulnerability, disability, health condition, financial difficulty, bereavement, communication need or other circumstance that may affect how we support you, we may record relevant information so that we can provide appropriate support.

We will only record vulnerability or additional support information where it is necessary and proportionate.

5. Where we collect information from

We may collect personal information directly from you when you:

• use one of our websites;
• submit an enquiry;
• contact us by phone, email, web form, live chat, SMS, post or social media;
•  visit a showroom, workshop, office or event;
• request a quote, valuation, test drive, finance proposal, leasing quote, insurance product, service booking, MOT, repair, warranty claim or callback;
• purchase, lease, finance, insure, rent, service or repair a vehicle;
• enter into a contract with us;
• make a complaint;
• exercise your data protection rights;
• respond to marketing or customer surveys.

We may also receive information from third parties, including:

• vehicle manufacturers and importers;
•  finance providers, lenders, brokers and leasing companies;
•  insurers, warranty providers and roadside assistance providers;
•  credit reference agencies and fraud prevention agencies;
• vehicle valuation, vehicle history and data providers;
• website, advertising, lead generation and vehicle listing platforms;
•  CRM, dealer management, telephone, marketing and technology providers;
• DVLA, DVSA, Companies House and other lawful public sources;
• your employer, fleet manager, company representative or authorised contact;
•  professional advisers, regulators, ombudsman services and public authorities.

6. Our lawful bases for using personal information

We only use personal information where we have a lawful basis under data protection law. Depending on the circumstances, we may rely on one or more of the following lawful bases.

Performance of a contract

We use personal information where it is necessary to enter into or perform a contract with you, such as selling, leasing, servicing, repairing or delivering a vehicle.

Steps before entering into a contract

We use personal information where you ask us to provide a quote, discuss a potential purchase, arrange a test drive, provide a leasing proposal, submit a finance proposal or respond to a service request before a contract is entered into.

Legitimate interests

We use personal information where it is necessary for our legitimate business interests and your interests, rights and freedoms do not override those interests.

Our legitimate interests may include:

• responding to enquiries;
• managing customer relationships;
• operating our dealerships, websites, systems and contact centres;
•  recording and monitoring calls;
•  improving customer service;
• managing complaints and disputes;
• preventing fraud and protecting our business;
• carrying out business reporting and analysis;
• maintaining accurate customer and vehicle records;
• sending certain business-to-business communications;
•  sending postal marketing where lawful;
• managing service reminders and customer care;
• protecting our legal rights.

Where we rely on legitimate interests, we consider the impact on individuals and use personal information in a way that is proportionate and within reasonable expectations.

Legal obligation

We use personal information where necessary to comply with legal obligations, including tax, accounting, consumer protection, vehicle safety, health and safety, financial services, data protection and regulatory obligations.

Consent

We rely on consent where required, for example for certain types of electronic marketing, some cookies and, in some circumstances, processing special category information.

You can withdraw consent at any time where we rely on consent.

Vital interests

In rare cases, we may use personal information where necessary to protect someone’s life or safety.

7. How we use your personal information

We use personal information for the purposes set out below.

To respond to enquiries and requests

We use your information to respond to enquiries, provide quotations, discuss vehicles or services, arrange test drives, book appointments, answer questions, provide fleet or leasing information, and manage follow-up relating to your specific request.

Where you submit an enquiry, we may contact you using the contact details you have provided for the purpose of responding to that enquiry.

Declining marketing does not prevent us from responding to a specific enquiry, order, booking, complaint or service request. However, if you do not provide a contact method, or you tell us that you do not want to be contacted at all, we may be unable to respond to your enquiry.

To sell, lease, finance, rent or supply vehicles and services

We use your information to process orders, prepare documentation, arrange payment, arrange vehicle delivery or collection, administer contracts, manage part-exchanges, provide invoices, process refunds, and support the customer relationship.

To provide aftersales, service, repair, parts and warranty support

We use your information to book and carry out servicing, repairs, MOTs, warranty work, recalls, technical checks, diagnostic work, parts supply, goodwill requests and manufacturer support.

We may use vehicle, mileage, service and repair information to remind you about servicing, MOT, repair, warranty, recall, safety or aftersales requirements.

To assist with finance, leasing and insurance

Where you ask us to assist with finance, leasing, insurance or related products, we use your information to:

•  discuss your requirements;
• assess product suitability where required;
• submit proposals to lenders, funders, brokers or insurers;
• support affordability and eligibility checks;
•  verify identity and prevent fraud;
• keep records of regulated activity;
• respond to questions, complaints or disputes;
• meet FCA and other regulatory obligations.

We are a credit broker, not a lender. Finance providers, funders, insurers and product providers may act as independent controllers and will provide their own privacy information.

To support vulnerable customers and customers needing additional support

Where you tell us about a vulnerability or additional support need, we may use that information to provide appropriate support, make reasonable adjustments, communicate with you in a suitable way, handle your enquiry or complaint fairly, and meet our regulatory obligations, including Consumer Duty obligations.

We will only record information that is relevant, necessary and proportionate. Where the information is special category data, we will identify an appropriate lawful basis and special category condition.

To manage Pulman Fleet and National Vehicle Solutions enquiries

If you submit an enquiry through Pulman Fleet, National Vehicle Solutions or a fleet, leasing or contract hire website, we may use your information to respond to your enquiry, prepare quotations, discuss funding options, liaise with funders or suppliers, manage orders, support renewals and administer customer relationships.

For Pulman Fleet and National Vehicle Solutions activity, we may use Motor Complete as a website and CRM platform to manage enquiries, quotations, customer communications and related CRM records.

To operate our dealer management, CRM and business systems

We use systems to manage customer, vehicle, sales, aftersales, finance, insurance, fleet and enquiry records.

This includes Pinewood as our dealer management system. Pinewood is used to store and manage customer records, vehicle records, enquiries, sales activity, service and repair records, workshop activity, parts, warranty, CRM activity, reporting and related dealership processes.

We may also use other CRM, website, telephone, marketing, reporting, document management, payment, finance and business systems.

Where technology providers process personal information on our behalf, they are required to process it in accordance with applicable data protection law and our contractual requirements.

To record and monitor calls

We use a telephone system provided by Zoom to manage inbound and outbound calls. This may include call logs, call metadata, voicemail, call recordings, and where enabled, call summaries, SMS/MMS or related telephone records.

We may record calls for;

•  training;
• monitoring;
• quality assurance;
• customer service;
• complaint handling;
• regulatory compliance;
• fraud prevention;
• dispute resolution;
• confirming details of enquiries, bookings, orders, finance or insurance discussions.

Standard call recordings are usually retained for up to 365 days, unless they are required for a complaint, dispute, finance, insurance, regulatory, legal, safeguarding, vulnerability or investigation purpose. Where a call is relevant to one of those matters, we may retain the recording, transcript or note of the call for longer, normally up to 6 years where necessary.

To manage complaints, disputes and legal claims

We use personal information to investigate and respond to complaints, resolve disputes, liaise with manufacturers, finance providers, insurers, ombudsman services, regulators, legal advisers and other relevant parties, and protect our legal rights.

To meet legal, regulatory and FCA obligations

We may use personal information to meet legal and regulatory obligations relating to:

• financial services;
• insurance distribution;
• Consumer Duty;
• anti-fraud checks;
•  tax and accounting;
•  consumer protection;
• product safety;
• vehicle recalls;
•  warranty administration;
• data protection;
• health and safety;
• complaints and dispute handling.

To send marketing communications

We may use your information to send marketing communications about vehicles, services, offers, events, finance or leasing offers, aftersales offers, warranty products, service plans, accessories and related products or services.

For email, SMS and similar electronic marketing, we will only send marketing where the law allows us to do so. This will usually be where you have given consent or where the soft opt-in applies.

You can opt out of marketing at any time by using the unsubscribe link in our messages or by contacting us.

If you opt out of marketing, we may retain limited information on a suppression list to ensure we respect your preference.

To carry out business analysis and improve our services

We may use personal information to understand business performance, improve our websites, improve customer service, manage staffing, measure response times, analyse sales and aftersales activity, review marketing performance, improve systems and plan future services.

Where possible, we use aggregated or anonymised information for reporting.

To protect our premises, people, systems and business

We use personal information for security, fraud prevention, system monitoring, CCTV, incident management, cyber security, access control, audit and business continuity purposes.

8. Contact preferences and declined contact

We distinguish between;

• contacting you about a specific enquiry, order, booking, contract, complaint, safety issue or service matter; and
• sending you marketing communications.

If you decline marketing contact, we will not use your information for marketing. We may still contact you where necessary about a specific enquiry you have submitted, an order, a service booking, a finance application, a complaint, a safety notice, a vehicle recall, a legal or regulatory matter, or another non-marketing purpose.

If you tell us that you do not want to be contacted at all, or you submit an enquiry without selecting any contact method, we may be unable to respond to your enquiry. We will not add you to marketing activity and may retain limited information to record and respect your preference.

9. Marketing and PECR

We comply with data protection law and the Privacy and Electronic Communications Regulations when sending marketing.

We may send marketing by email, SMS, telephone, post, social media or other channels where lawful.

For individual customers, sole traders and some partnerships, email and SMS marketing will usually require consent or a valid soft opt-in.

The soft opt-in may apply where:

•  you have given us your contact details during a sale or negotiation for a sale;
• we are marketing our own similar products or services;
• you were given a clear opportunity to opt out when your details were collected; and
• you are given a clear opportunity to opt out in every marketing message.

For corporate business contacts, different rules may apply, but we will still respect objections and opt-outs.

You can opt out of marketing at any time.

We may still send service messages that are not marketing, such as appointment confirmations, safety notices, recall information, contractual updates, finance or insurance administration, complaint responses or important customer service communications.

10. Cookies and website tracking

Our websites may use cookies and similar technologies to operate the website, remember your preferences, analyse website performance, understand customer journeys and support marketing activity.

Some cookies are necessary for the website to work. Other cookies, such as analytics or advertising cookies, may require your consent.

Further information about the cookies we use, how long they last and how you can manage your preferences is available in our Cookie Policy or cookie settings tool.

11. Who we share your information with

We may share personal information where necessary and lawful with:

• Pulman Group companies and trading businesses;
• vehicle manufacturers and importers;
• finance providers, funders, leasing companies and lenders;
•  insurance providers, warranty providers, roadside assistance providers and added-value product providers;
•  credit reference agencies and fraud prevention agencies;
• Pinewood and other dealer management system providers;
• Motor Complete and other website or CRM providers;
•  Zoom and other telephone, call recording or communications providers;
• TekCor4 or other aftersales, predictive service, CRM or vehicle data providers where relevant;
• website, hosting, IT, cyber security, cloud storage and system providers;
• marketing, analytics, advertising, lead generation, email and customer survey providers;
•  payment processors and finance administration providers;
• vehicle delivery, logistics, repair, bodyshop, valeting, accessory and parts suppliers;
•  professional advisers including accountants, auditors, insurers and legal advisers;
•  regulators, public authorities, law enforcement agencies, courts and ombudsman services;
• DVLA, DVSA or other public bodies where required or lawful;
• any third party where necessary to protect our rights, customers, employees, systems or business.

We do not sell your personal information

12. Vehicle manufacturers and brand partners

Where you purchase, lease, service or repair a vehicle, or where we assist with a warranty, recall, technical, goodwill or customer care matter, we may share relevant personal information with the relevant vehicle manufacturer, importer or brand partner.

This may include Volkswagen, Volkswagen Commercial Vehicles, SEAT, CUPRA, Škoda and their associated group companies, systems, service providers and finance or customer care partners.

Manufacturers may use your information for their own purposes, including warranty administration, recalls, safety notices, technical support, customer care, brand surveys, market analysis and regulatory obligations. In many cases, manufacturers will act as independent controllers and will provide their own privacy information.

13. Finance, leasing and insurance providers

Where you ask us to assist with finance, leasing, contract hire, insurance or related products, we may share your information with finance providers, funders, lenders, brokers, insurers, product providers, credit reference agencies and fraud prevention agencies.

These organisations may use your information to assess applications, verify identity, carry out credit and affordability checks, prevent fraud, administer agreements, manage arrears, respond to complaints and meet legal or regulatory obligations.

These organisations usually act as independent controllers and will provide their own privacy information

14. Processors and service providers

Some third parties process personal information on our behalf. These may include DMS, CRM, website, telephone, call recording, IT, hosting, marketing, reporting, document management, payment and customer service providers.

Where a provider acts as our processor, they must process personal information only in accordance with our instructions, our contract and applicable data protection law.

Some providers may also act as independent controllers for limited purposes, such as account administration, security, service improvement, legal compliance or where they determine their own purposes. Where this applies, their own privacy information will explain how they use personal information.

15. International transfers

Some of our suppliers, systems or service providers may process personal information outside the United Kingdom.

Where personal information is transferred outside the UK, we will take steps to ensure appropriate safeguards are in place. This may include adequacy regulations, standard contractual clauses, the UK International Data Transfer Agreement, the UK Addendum to EU standard contractual clauses, or other lawful transfer mechanisms

16. How long we keep personal information

We keep personal information only for as long as necessary for the purpose for which it was collected, including to meet legal, regulatory, accounting, tax, warranty, safety, complaint handling and legal claim requirements.

The table below sets out our usual retention periods. In some cases, we may retain information for longer where necessary, for example where there is a complaint, legal claim, regulatory matter, safety issue, fraud concern, finance or insurance issue, or ongoing customer relationship.

At the end of the relevant retention period, we will delete, anonymise or securely archive the information unless we have a lawful reason to keep it for longer.

17. Security

We take appropriate technical and organisational measures to protect personal information against unauthorised access, loss, misuse, alteration or disclosure.

These measures may include access controls, password protection, staff training, supplier due diligence, system permissions, secure storage, encryption where appropriate, audit controls, cyber security measures, backup processes and secure disposal procedures.

Access to personal information is limited to people who need it for their role

18. Your data protection rights

You have rights under data protection law. These include:

Right of access

You can ask us for a copy of the personal information we hold about you.

Right to rectification

You can ask us to correct inaccurate or incomplete personal information.

Right to erasure

You can ask us to delete personal information in certain circumstances.

Right to restriction

You can ask us to restrict how we use your personal information in certain circumstances.

Right to object

You can object to processing based on legitimate interests in certain circumstances.

You have an absolute right to object to direct marketing at any time.

Right to withdraw consent

Where we rely on consent, you can withdraw that consent at any time.

Right to data portability

In certain circumstances, you can ask us to provide your information in a structured, commonly used and machine-readable format.

Rights relating to automated decision-making

You have rights relating to decisions based solely on automated processing where those decisions have legal or similarly significant effects.

We do not usually make decisions about customers based solely on automated processing that have legal or similarly significant effects. If this changes, we will provide appropriate information.

These rights do not apply in every situation. For example, we may need to keep certain information to comply with legal, regulatory, contractual, tax, accounting, complaint handling, safety or legal claim obligations.

To exercise your rights, please contact us using the details in section 3.

19. Complaints

If you are unhappy with how we use your personal information, please contact us first so that we can try to resolve your concern.

You also have the right to complain to the Information Commissioner’s Office.

Information Commissioner’s Office
Website: www.ico.org.uk

Telephone: 0303 123 1113

20. Changes to this policy

We may update this Privacy Policy from time to time to reflect changes in our business, systems, legal obligations or how we use personal information.

The latest version will be published on our website. Where appropriate, we may also notify you of significant changes by other means.

The latest version will be published on our website. Where appropriate, we may also notify you of significant changes by other means.