Privacy Policy

We understand that privacy and the security of your personal information is extremely important. This policy sets out what we do with your information and what we do to keep it secure. It also explains where and how we collect your personal information, as well as your rights over any personal information we hold about you.

This policy applies to you if you use our products or services within the dealership, over the telephone, via our website, or interacting with us on social media (our Services). This policy demonstrates our commitment to protecting your personal information.

Please read this Privacy Notice to learn about your rights, what information we collect, how we use and protect it.

In this Privacy Policy, references to we, us and our (or other words of similar import) means that Horizon Magna Motor Co. Ltd processes your personal information (as defined below) and interacts with you (i.e the entity from whom your purchase a vehicle or other services).

The documents you receive from any dealership within Horizon Magna Motor Co. Ltd will identify the relevant dealership that you are dealing with in a particular instance. These include :

Poole Subaru 

As part of your dealings with Horizon Magna Motor Co. Ltd we will collect and process personal information about you in order to supply vehicles, goods and services to you and to administer our relationship with you. This may involve sharing your personal information with third parties. The Privacy Policy document sets out in detail how we will use your personal information and how you can exercise your rights with respect to personal information.

If you have questions or comments about this Privacy Notice or how we handle personal data, please direct your correspondence to:

Data Protection Officer
Horizon Motor Co. Ltd
397-399 Ringwood Road
Poole, Dorset
BH12 4LT

Email: privacy.officer@hmmgcars.net

  • Directly: We obtain personal data directly from individuals in a variety of ways, including obtaining personal data from individuals who provide us with their business card(s), complete our online forms, engage in webchats, subscribe to our newsletters, attend marketing events we host, visit our offices, have purchased motor vehicles from a member of our nationwide dealer networks, or for recruitment purposes. We may also obtain personal data directly when, for example, we are establishing a business relationship.
  • Indirectly:We obtain personal data indirectly about individuals from a variety of sources. We may attach personal data to our customer relationship management system to better understand and serve our customers, subscribers and individuals, satisfy a legal obligation, or pursue our legitimate interests.
    • Online: We collect information about you that you give to us via our websites or our social media pages or by contacting us by phone, email or otherwise.
    • Cookies: We may automatically collect personal data that our web servers store as standard details of your browser and operating system, the website from which you visit our websites, the pages that you visit on our websites, the date of your visit, and, for security reasons, e.g. to identify attacks on our websites, the Internet protocol (IP) address assigned to you by your internet service. We collect some of this information using cookies, please see our Cookies Policy for further information;
    • Social media: We may also collect personal data which you allow to be shared that is part of your public profile on a third-party social network;
    • Third party: We may obtain certain personal data about you from sources outside our business which may include our dealer networks or other third-party companies, such as estate agents.
    • Analytical / trend data: From time to time we also hold marketing and analytical data relating to our customers including history of those communications, whether our customers open them or click on links, and information about products or services we think our customers may be interested in, and analytical data to help target offers to our customers that we think are of interest or of relevance. This may include insights about customers or potential customers gained from analysis or profiling of customers.
    • Recruitment: We may obtain personal data about candidates from an employment agency to aid in recruitment.

We may collect and process information about you including your name, date of birth, address, contact details (including email address and mobile telephone number), vehicle details, purchase history and data collected as part of any finance application or payment (including previous addresses, employment details and bank account details). This information is referred to in this Privacy Policy as personal information. We may obtain the following categories of personal data about individuals:

  • Personal data: Here is a list of personal data we commonly collect to conduct our business activities:
    • Contact details including but not limited to name, physical address, company name and contact details, work and personal landline and mobile numbers, email addresses.
    • Other details including but not limited to date of birth, gender, marital status and contact preferences.
    • In the automotive division we capture names and addresses when vehicles are registered. We need to do this as part of our contractual obligation to provide breakdown cover for new vehicles. This data is passed to organisations such as the AA, the RAC and Allianz Worldwide Partners (AWP).
    • Very occasionally, we also hold details of our customers financial arrangements where there is a business-related need for us to do so.
    • CCTV at some of our sites may collect images of visitors. Our policy is to automatically overwrite CCTV footage within 30 days.
    • Your opinion of our products through surveys we will send you about our vehicles, products services, and dealerships;
  • Sensitive personal data: We typically do not collect sensitive or special categories of personal data about individuals other than our own employees.
  • Child data:Although we do not intentionally collect information from individuals under 13 years of age.
  • Location-based data: We may process geographical locations you enter when seeking an office near you.
  • Correspondence: We also hold electronic copies of our correspondence sent to or received from our customers and any contractors and suppliers who work with us. This correspondence is primarily in email format, mainly where an issue/problem has been raised by the customer and we write back, advising of the course of action being taken to resolve the issue.
  • Profiling: From time to time we also hold marketing and analytical data relating to our customers including history of those communications, whether our customers open them or click on links, and information about products or services we think our customers may be interested in, and analytical data to help target offers to our customers that we think are of interest or of relevance. This may include insights about customers or potential customers gained from analysis or profiling of customers.

We may collect and process the following information about you :

  • Information that you provide by filling in forms, including those on our website.
  • A copy of your driving licence when you test drive a vehicle or are provided with a courtesy car.
  • When you enquire about or purchase a vehicle or services we collect personal information to respond to your enquiry and to process and complete your purchase.
  • Details about the transactions you carry out with us.
  • CCTV footage in which you feature when you visit our premises.
  • Information contained in and records of communications between us, including e-mails, letters and SMS text messages.
  • Details of your visits to our website including, but not limited to, traffic and location data (including the country and IP address of where your computer is located) and the resources that you access (including the pages of the website that you view).
  • We will collect information concerning your marketing preferences.
  • We will also collect information to enable third parties to carry out credit reference checks on you (if you are purchasing a vehicle on finance) and we will receive and process information about the outcome of those checks in order to complete your purchase.

We may use your personal data:

  • In the automotive division we capture names and addresses when vehicles are registered. We need to do this as part of our contractual obligation to provide breakdown cover for new vehicles. This data is passed to organisations such as the AA, the RAC and AWP;
  • Manage and administer your vehicle’s routine maintenance, product recalls, warranty repairs and MOT testing requirements.
  • for analysis, and profiling to inform our marketing strategy, and to enhance and personalise your customer or visitor experience;
  • for market research in order to continually improve the products and services that we and our authorised dealers and agents deliver to you;
  • to respond to your requests or enquiries;
  • to process claims under vehicle, part or other warranties / obligations or to process goodwill payments or insurance products.
  • for marketing activities e.g., to tailor marketing communications or send targeted marketing messages via social media and other third-party platforms;
  • to create a better understanding of you as a customer or visitor;
  • to administer our websites and for internal operations, including troubleshooting, testing, statistical purposes;
  • for the prevention of fraud and other criminal activities;
  • to undertake credit checks for finance;
  • to correspond and communicate with you;
  • for network and information security for us to take steps to protect your information against loss or damage, theft or unauthorised access;
  • for efficiency, accuracy or other improvements of our databases and systems e.g., by combining systems or consolidating records we or our group companies hold about you;
  • for general administration including managing your queries, complaints, or claims, and to send service messages to you.
  • 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);
  • for the purposes of corporate restructure or reorganisation or sale of our business or assets;
  • to enforce or protect our contractual or other legal rights or to bring or defend legal proceedings; and
  • for direct marketing communications and related profiling to help us to offer our customers relevant products and service, including deciding whether to offer our customers certain products and service. We’ll send marketing to our customers by SMS, email, phone, post, social media and digital channels (for example, using Facebook Custom Audiences and Google Custom Match). Offers may relate to any of our products and services as well as to any other offers and advice we think may be of interest
  • to provide personalised content and services to our customers, such as tailoring our products and services, our digital customer experience and offerings, and deciding which offers or promotions to show our customers on our digital channels
  • We may use your personal data to tell you about relevant products, services and offers. This is what we mean when we talk about ‘marketing’. The personal data we have for you is made up of what you tell us, and data we collect when you buy one of our products or services from us or one of our dealers. We may also collect digital data relating to your web browsing and your interactions with our marketing emails.
  • We may use our customers’ home or work address, phone numbers, email address and social media or digital channels (for example, Facebook, Google and message facilities in other platforms) to contact you according to our customers’ marketing preferences.

Keeping you informed of our Products & Services

We would like to tell you about offers, products and services from us from time to time, that we think you might be interested in. Where you have consented to us doing so, we may do this via post, by email, text message, online, using social media, or by any other electronic means.


We will still need to send you occasional service-related messages. If you wish to amend your marketing preferences, you can do so by contacting our Privacy Officer, as detailed below.

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. We 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 need to do so and where we have an Article 28 Agreement in place with them.

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to honour the terms of the contract, for example, to provide you with goods or services. In this case, we may have to cancel a product or service you have with us; however, we will notify you if this is the case at the time.

Where we do not have your consent pursuant to Article 6 1. (a) of GDPR, we may 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.

  • Consent: there may be circumstances where we hold personal data with your consent, such as when you provide it to us through online forms or an events registration system. You can remove your consent at any time. You can do this by contacting privacy.officer@hmmgcars.net.
  • Contractual Obligations:we often have a duty to process personal data as part of a contractual obligation. In these circumstances we will only retain personal data for as long as is necessary to fulfil that obligation.
  • Legal obligations: We may process personal data in order to meet our legal and regulatory obligations or mandates.
  • Vital interests:the processing is necessary to protect someone’s life.
  • Legitimate Interest: to enable us to carry on our various businesses we inevitably need to process personal data in a vast variety of situations. Where we rely on Legitimate Interest we will always carry out, beforehand, a Legitimate Interest Assessment to ensure that our use of personal data does not exceed that which is strictly necessary to perform the job in hand, nor that it unnecessarily infringes the rights and expectation of privacy of the Data Subject.

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:

  • Car Dealerships and Service Centres within our dealer networks
  • Roadside Assistance Providers (e.g., AA,  RAC and AWP)
  • Holders of the Vehicle Safety Recall Databases (e.g., SMMT, SIMI and GI Solutions Group Ltd.)
  • Insurance Companies
  • Accident Management and Repair Service Providers
  • Fraud Prevention Agencies
  • Credit References
  • Agents and Advisers who we use to help us carry out our business
  • We may pass personal information to external agencies and organisations (including the police and law enforcement agencies) for the purpose of preventing and detecting fraud and criminal activities. We may also disclose personal information to the police and other law enforcement agencies in connection with the prevention and detection of crime.
  • In the event that we sell or buy any business assets (including car dealerships), we may disclose personal information held by us about our customers to the prospective seller or buyer of such business or assets. If we or substantially all of our assets are acquired by a third party, personal information held by us about our customers will be one of those transferred assets.
  • We may pass your personal information to the relevant franchise manufacturing partner relating to your vehicle. They may contact you directly regarding your vehicle and to obtain feedback and/or provide offers.

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 technical and organisational security measures to safeguard your personal data.

Access and Correction of your personal information

You have the right to access the personal information that we hold about you in many circumstances. This is sometimes called a ‘Subject Access Request’. If we agree that we are obliged to provide personal information to you (or someone else on your behalf), we will provide it to you or them, free of charge. Before providing personal information to you or another person on your behalf, we will ask you to complete a Subject Access Request Form (available upon request from our Privacy Officer (contact details provided below)). The form will ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information.

If any of the personal information we hold about you is inaccurate or out of date, you may ask us to correct it.

If you would like to exercise these rights, please contact us privacy.officer@hmmgcars.net

Right to stop or limit our processing of your data

You have the right to object to us processing your personal information if we are not entitled to use it any more, to have your information deleted if we are keeping it too long or have its processing restricted in certain circumstances.

If you would like to exercise this right, please contact us as set out below.

privacy.officer@hmmgcars.net

Data Protection Officer, Horizon Motor Co. Ltd, 397-399 Ringwood Road, Poole, Dorset BH12 4LT

We will retain a record of your personal information. This is done in order to provide you with a high quality and consistent service across our group. 

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:

  • the law requires us to hold your personal data for a longer period, or delete it sooner;
  • 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 in this paragraph, or because we are required under the law (see further Erasing your personal data or restricting its processing in paragraph 12) below;
  • and in limited cases, the law permits us to keep your personal information indefinitely provided we put certain protections in place.

‘Cookies’ are small pieces of information sent to your device and stored on its hard drive to allow our websites to recognise you when you visit. These help us understand how you use our websites so that we can customise our marketing for you. It may also save you from having to re-enter information when you return to our websites. We will, however, only ever use cookies when we have your permission to do so.

For more information on how IM Group use ‘cookies’ see our Cookie Policy by visiting our websites and clicking on the “Cookie Policy” link https://www.poolesubaru.co.uk/cookie-policy/

Our websites may contain links to other sites, including sites maintained by our partners or group 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.

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 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 your Data Subject Rights, you can email dataprotectionofficer@imgroup.co.uk. We may need to request specific information from you to help us confirm your identity and ensure your right to access the information or to exercise any of your other rights. This helps us to ensure that personal data is not disclosed to any person who has no right to receive it. Depending on the circumstances, we may be unable to comply with your request based on other lawful grounds.

 

If you have any concerns about our use of your personal information, you can make a complaint to us at privacy.officer@hmmgcars.net

Data Protection Officer, Horizon Motor Co. Ltd, 397-399 Ringwood Road, Poole, Dorset BH12 4LT

You can also complain to the ICO if you are unhappy with how we have used your data.

ICO website: https://www.ico.org.uk

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Horizon Motor Company Ltd. is authorised and regulated by the Financial Conduct Authority. FRN 309461. Magna Motor Co (Christchurch) Ltd., Magna Motor Co (Wessex) Ltd., and Magna Motor Co Ltd., are Appointed Representatives of Horizon Motor Company Ltd. We are a Credit Broker not a Lender and can introduce you to a limited number of lenders. We typically receive a fixed commission calculated by reference to the vehicle model or amount you borrow, for introducing you to a lender but this does not affect the interest charged on the agreement, all of which are set by the lender. Our manufacturer supporting finance companies also provide preferential rates to us for the funding of our vehicle stock and financial support for our training and marketing.