Last updated 03 July 2020
IM Group is dedicated to protecting the confidentiality and privacy of information entrusted to us in accordance with the EU General Data Protection Regulation (GDPR) and the UK Data Protection Act 2018. Please read this Privacy Notice to learn about your rights, what information we collect, how we use and protect it.)
This Privacy Notice applies to IM Group and its entities, namely, IM Group Limited, IM Facilities Limited, International Motors Limited, Subaru (UK) Limited, Isuzu (UK) Limited, IM Parts and Service Limited, Daihatsu Vehicle Distributors Limited, IM Trade Assist Limited, Great Wall Motor Distributors (UK) Limited, IM Insurance Limited, International Motors Finance Limited (49%), IM Automotive Limited, IM European Motors Limited, IM Properties PLC, IM Properties (Coleshill) Limited, IM Properties Development Limited, IM Properties Finance Limited, Spitfire Bespoke Homes Limited, IM Properties (Bvp 1) Limited, IM Properties (Mell Square 1) Limited, The Hub Management Company Ltd, IM Properties (Logistics) Limited, BVP Management Company Limited and I.M. UK Trade Company Limited.
If you have questions or comments about this Privacy Notice or how we handle personal data, please direct your correspondence to:
Data Protection Officer IM Group Ltd The Gate International Drive Solihull West Midlands B90 4WA
Telephone: 0121 730 8079
The IM Group and its entities operate in various markets, but mainly in automotive and property. We may obtain the following categories of personal data about individuals:
IM Group will only use the personal data for the benefit of its customers or for some other lawful purpose. For example, we may use your personal data:
We study this 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 can only use your personal data to send you marketing messages if we have either your consent or a ‘legitimate interest’. That is when we have a business or commercial reason to use your information. It must not unfairly go against what is right. You can ask us to stop sending you marketing messages by contacting us at any time. Whatever you choose, you’ll still receive details of product recalls, and other important information. We may ask you to confirm or update your choices. We will also ask you to do this if there are changes in the law, regulation, or the structure of our business. If you change your mind you can update your choices at any time by contacting us. It will never sell the personal data to a third party. We will only pass the personal data to third parties where there is a business driven need to do so and where we have an Article 28 Agreement in place with them.
Where we do not have your consent pursuant to Article 6 1. (a) of GDPR, we always have a legitimate interest pursuant to Article 6 1. (f). In addition, or alternatively from time to time we process personal data pursuant to lawful bases contained in other provisions of Article 6 such as the performance of a contractual obligation.
a) Some Examples: in some cases, we may have multiple legal bases for processing your data. For example, if we need to notify vehicle owners of a safety recall campaign initiated by the manufacturer, we may need to contact all current vehicle owners which will include not only our direct customers but also people who purchased their vehicle second hand. Accordingly, we must obtain a list of all current keepers from DVLA and use it to contact the current keepers to direct them to their nearest authorised dealer
b) Legitimate Interest is also the basis of some of our Direct Marketing communications and related profiling to help us to offer our customers relevant products and services, including deciding whether to offer our customers certain products and services. We will send marketing to our customers by SMS, email, phone, post and social media and digital channels for example, using Facebook Custom Audiences and Google Custom Match. (In some cases, however, we will also have consent of our customers for direct marketing communications).
Whatever the legal basis upon which our processing rests we always aim to practise data minimisation so as to ensure that we only hold that personal data which is necessary for the task in hand and that we only retain that data for as long as necessary to fulfil our legal obligation or legitimate business interest. We never transfer personal data to third parties unless we have a proper reason for doing so and where we have an Article 28 agreement (or equivalent) in place. Privacy by Design is the principle we follow whenever we gather, use or process personal data.
As well as IM Group and its entities, we often share the personal data with third parties who carry out processing on our behalf pursuant to the terms of an Article 28 agreement. Such processing is necessary for IM Group to do their job properly and to service the needs of its customers throughout its various businesses. As a generality, such third parties fall into the following main categories:
On our secure computer systems and in some cases in hard form in our offices or in our onsite storage facility. We have invested in state of the art technical and organisational security measures to safeguard your personal data.
IM Group operate in the following countries:
Generally, we are unlikely to transfer your personal data outside the European Economic Area (‘EEA’). We will only send your data outside of the EEA to:
If we do transfer personal data to our agents or advisers outside of the EEA, we will make sure that it is protected in the same way as if it was being used in the EEA. We’ll use one of these safeguards:
If we collect your personal data, the length of time we retain it is determined by several factors including the purpose for which we use that data and our obligations under other laws. We do not retain personal data in an identifiable format for longer than is necessary.
We may need your personal data to establish, bring or defend legal claims, in which case we will retain your personal information for 7 years after the last occasion on which we have used your personal information in one of the ways specified in How will your information be used? in paragraph 4 above. The only exceptions to this are where:
Our websites may contain links to other sites, including sites maintained by our partners or member dealerships that are not governed by this Privacy Notice. Please review the destination websites’ privacy notices before submitting personal data on those sites. Whilst we try to link only to sites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other sites.