PRIVACY NOTICE Belron® Franchisee Portal

This Privacy Notice applies to the web portal www.Belron4Partners.com (the “Portal”) operated by Belron International Limited, Milton Park, Stroude Road, Egham, Surrey, TW20 9EL, England, a company registered in England with company number 2442568 (“Belron” or “we”, “us” or “our”).

1. IMPORTANT NOTICE

This Privacy Notice sets out how we collect and process your personal data in connection with the use of the Portal. This Privacy Notice also provides certain information that is legally required and lists your rights in relation to your personal data.

This Privacy Notice relates to personal information that identifies “you” meaning eligible users of the Portal who are (master) franchisees or their employees and who have been accredited by us.

We refer to this information throughout this Privacy Notice as “personal data”, and section 3 sets out further detail of what this includes.

Please read this Privacy Notice to understand how we may use and treat your personal data.

This Privacy Notice may be amended from time to time, so please check it regularly.

2. DATA CONTROLLER AND CONTACT INFORMATION

The controller within the meaning of applicable data protection laws and regulations as well as other data protection provisions is:

Belron International Limited
Milton Park
Stroude Road
Egham
Surrey
TW20 9EL
United Kingdom
Phone: +44 (0) 1784 476800
Fax: +44 (0) 1784 472900
Email: communications@belron.com

3. CATEGORIES OF PERSONAL DATA COLLECTED

The categories of personal data about you that we may collect, use, store, share and transfer are:

Individual Data. This includes personal data which relates to your identity, such as your first names, last name, username or similar identifier, title, and your contact details such as your address, e-mail address and telephone numbers;

Account and Profile Data, which includes personal data, which relates to your account or profile on the Portal, such as your preferences, feedback and survey responses;

Information Technology Data. This includes personal data, which relates to your use of the Portal, such as your login data, traffic data, weblogs and other communication data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Portal;

4. USE OF YOUR PERSONAL DATA AND BASIS FOR SUCH USE

We may rely on one or more of the following legal bases when processing your personal data. We have set out below the purposes for which we may process your personal data:

Purposes for which we process your personal data in the Portal

Categories of personal data

The basis on which we can do this (this is what the law allows)

To register you as a user

Individual Data;

Account and Profile Data.

The processing is necessary

-to perform a contract with you; and

-our legitimate interest in the provision of goods and services to our customers.

In order to manage our relationship with you including:

to send you important notices, such as communications about changes to our terms and conditions and policies (including this Privacy Notice);

Individual Data;

Account and Profile Data;

The processing is necessary

-to perform a contract with you; and

-our legitimate interest in the provision of goods and services to our customers.

In order to administer and protect our business, deal with any misuse of our website and to comply with our security policies at our locations.

Individual Data;

Account and Profile Data; Information Technology Data;

The processing is necessary

-for our legitimate interest in provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise; and

-to comply with the law.

In order to improve the way in which we work in the future; and to measure or understand the effectiveness of our content and communications.

Individual Data;

Account and Profile Data; Information Technology Data;

The processing is necessary for our legitimate interests to study how our users use the Portal, to optimize it by developing our services and content and ensure they are relevant to you, and to inform our communication strategy.

5. WHO RECEIVES YOUR PERSONAL DATA

We disclose data to such entities with which we cooperate in the processing of data, the provision of applications and/or customer support. In this case, the relevant data will be treated in accordance with the provisions set out herein and it will be ensured that an adequate level of data protection is in place at the contractor.

We may disclose your personal data to:

Our group companies and affiliates or third party data processors who may process data on our behalf to enable us to carry out our usual business practices or who we may need to contact in relation to the operation of the Portal and any query that you may raise with us about its content or a service we will or have provided to you;
HMRC, legal and other regulators or authorities, including those who request your personal data or to report any potential or actual breach of applicable law or regulation or if the disclosure and/or transfer is necessary to prevent misuse of the Portal or individual applications, in particular the violation of Terms of Use, in a legally permissible manner.

6. PERSONAL DATA ABOUT OTHER PEOPLE

If you provide personal data to us about someone else (such as one of your directors or employees) you must ensure that you are entitled to disclose that personal data to us and that, without our taking any further steps, we may collect, use and disclose that personal data as described in this Privacy Notice.

You must ensure the individual concerned is aware of the various matters detailed in this Privacy Notice, as those matters relate to that individual, including our identity, how to contact us, the way in which we collect and use personal data and our personal data disclosure practices, that individual’s right to obtain access to the personal data and make complaints about the handling of the personal data, and the consequences if the personal data is not provided.

7. ACCURACY OF YOUR PERSONAL INFORMATION

It is important that the personal data we hold about you is accurate and current, and we take all reasonable precautions to ensure that this is the case, but we do not undertake to check or verify the accuracy of personal data provided by you.

Please keep us informed if your personal data changes during your relationship with us either by logging onto your account on the Portal or by contacting us.

8. TRANSFERS OF YOUR PERSONAL DATA

The data that we collect from you may be transferred to, and stored at, a destination outside of the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the provision of support services or data analysis that will assist us in improving our services to you and others in the future. By submitting your personal data to us, you agree to such transfer, storing or processing.

If you are in the EU, we rely on EU standard contractual clauses, Binding Corporate Rules or, where relevant, specific consent pursuant to Art. 49 GDPR in order to achieve EU an adequate level of protection in the third country.

9. SECURITY

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice.

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 website; 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.

We have given you login credentials and/or a password which enables you to access certain parts of the Portal, you are responsible for keeping that password confidential.

10. RETENTION OF YOUR PERSONAL DATA

We will store your personal data for the time period that we believe is appropriate in accordance with the (master) franchise agreement our data retention policy.

11. YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA

Under data protection law, you have rights including:

Your right of access – You have the right to ask us for copies of your personal information.
Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
Your right to object to processing – You have the right to object to the processing of your personal information in certain circumstances.
Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

If you would like to exercise any of the rights set out above, please contact us using the contact details set out in section 2.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

You can also complain to the Information Commissioner’s Office (please see https://ico.org.uk/concerns/ for how to do this) or other relevant supervisory body, if you have any concerns about our use of your personal data.

12. COOKIE POLICY / USE OF COOKIES

What is a cookie?We use ‘cookies’ to collect certain information when you use the Portal. A cookie is a small amount of data, which often includes a unique identifier, which is sent to your computer browser from a website’s computer and is stored on your computer’s hard drive.

What are cookies used for?

Cookies allow us to recognise your computer or access device each time it is used to visit the Portal and to keep count of how often you return to the Portal. If your browser preferences allow it, the Portal can send its own cookie to your browser, but in order to safeguard your privacy, your browser will only permit a website to access cookies which it has already sent to you. It will not allow a website to access cookies sent to you by a third-party website.

We use two types of cookies to collect this information. Cookies enable us to customise our Portal to best suit your needs and provide you with an improved online experience. In addition, cookies are used to measure usage of various pages on the Portal to help us make our Portal more pertinent to your needs and easier for you to access.

The first type of cookie is called a ‘session’ cookie, which is temporary and is deleted automatically once you leave the Belron site. The second is called a ‘persistent’ cookie, which remains on your computer hard drive until you delete it.

We do not use cookies for any purpose other than to provide an online communication service expressly requested by the user or to enable or facilitate electronic communication.

Belron does not use cookies to gather information concerning your visits to other sites, nor to ascertain any personally identifiable information about you, apart from what you provide voluntarily during your dealings with the Belron group.

As part of the above we use MATOMO. MATOMO uses cookies to analyse how users use the Portal. These cookies are used to collect, analyse and report information and users’ data, to measure, collect, analyse and report for purposes of understanding and optimizing the Portal. We use the information to compile reports and to help us improve the Portal. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.

You have the possibility of objecting to the use of audience measurement tracers strictly necessary for the functioning and current administration of the Portal in the cookie management window located at the top right of each page of the Portal.

13. WEBSITE ANALYTICS

You may choose to prevent this website from aggregating and analyzing the actions you take here. Doing so will protect your privacy, but will also prevent the owner from learning from your actions and creating a better experience for you and other users.