Mazda UK Privacy Policy

Key Summary

We process your personal information only for the following purposes: vehicle service reminders, customer and contract administration, warranty services, market research, providing updates on network dealer changes, responding to general enquiries and requests sent to us, product recalls, marketing analytics, personalised communications and direct marketing.

As part of our processing for these purposes, we share your information with suppliers who act on our behalf for services such as database management, IT support, website support and marketing services.

This Policy explains what data we process, why, how it is legal and your rights.

About Mazda UK and this Privacy Policy

This Privacy Policy is provided by Mazda Motors UK Limited ("Mazda UK", "we" or "us") who is a controller in respect of your personal data for the purposes of the General Data Protection Regulation (EU) 2016/679 and the UK Data Protection Act 2018 (collectively referred to as the "Data Protection Laws"). Keeping your data safe is important to Mazda UK and this Privacy Policy explains what personal data we process, why we hold the data, what legal basis we rely on and what your rights are. Please take time to read this carefully.

How to contact us

If you would like to amend your marketing preferences or any of your personal details, you can do this via the MyMazda app if you have registered for it, or alternatively via our Customer Relations Team using the details below. To get in touch with Mazda UK for any other queries, please use the following details:

Email: mmukassistance@mazdaeur.com

Address: Customer Relations Team, Mazda Motors UK Limited, Victory Way, Crossways Business Park, Dartford, Kent, DA2 6DT

Telephone: 03457 48 48 48

For any other matters in relation to data protection or personal data, please contact our Data Protection Officer as below:

Email: mazdaukdpo@mazdaeur.com

What information do we collect?

The personal information provided by you to us falls within the following categories for both car purchases and service visits:

• Contact details - Includes your full name, address, contact information including telephone and email address details.
• Customer services - We will also collect additional information about you and your vehicle when you contact our customer relations centre (including queries or complaints).
• Dealer information – We will collect information about the dealership you purchase your car from as well as the dealership who service your car (if different).
• Vehicle Information - Including VIN, registration number and registration date, make/ model, warranty repair information as well as security etching (unique security code etched onto the windows linking both you and your car to the International Security Register (ISR). In addition, for servicing only, we will collect service information such as date and time you used our services within our dealer network as well as latest mileage information which is used to help determine the optimum time for your next service. We will also collect technical vehicle information about how the engine and systems within the vehicle perform including on-board diagnostics data as well as, if relevant, the location of where the fault has occurred.
• Vehicle information for 112-Based Emergency Call System (where fitted) including VIN, Vehicle type (passenger vehicle), Vehicle engine type (e.g petrol/diesel/electric), Vehicle last three locations (The vehicle location data is constantly overwritten in the internal memory of the system. Should an emergency situation occur the vehicle will share its precise location by sending the last three known co-ordinates to the emergency services) and direction of travel, log file of the automatic activation of the system and its timestamp. Further details of what is collected can be found in your Owners Manual.
• Website, electronic communications and app device usage – We will collect information such as if you open or engage with our email communications or if you use the Mazda website platforms: mazda.co.uk, Mazda dealer websites, online brochures or if you have registered an account on the MyMazda ownership App. We will collect usage, browser and online behaviour information through cookies, your IP address, web beacons, cross-device / cross-context technology, registration based ID’s or other unique identifiers provided to us by customers as well as other storage/ tracking technologies such as web analytics services provided by Google Analytics. Information gathered includes pages visited, the country you access our site from, where you joined our site from, the path you take through our sites and where you leave, browser, plug-ins you have installed on your browser, browser language, JavaScript objects, type of device, and how long you visited for including collecting your mobile device location details (if permitted within the App settings). We will use cookies based on your consent for Marketing Cookies on our websites and these will be for Mazda UK as well as third parties such as Facebook. You can read more about the respective cookie policies and how to refuse the use of cookies on www.mazda.co.uk/cookies.
• Facebook – when you visit our Facebook fan page (https://www.facebook.com/MazdaUK/) your personal data can be processed for market research and advertising purposes: for example, when use profiles are constructed on the basis of interests identified through use behaviour and these profiles are utilised in placing advertisements. Usually, your data will be processed by cookies stored on your computer. This fan page is provided on the basis of our agreement with Facebook (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) on joint processing of personal data under GDPR Article 26 (“Page Insights Controller Addendum”). This agreement does not allow decisions concerning the processing of Insights Data to be made or implemented by us alone. Facebook takes primary responsibility under the GDPR for the processing of Insights Data and for compliance with all duties arising from the GDPR in respect of the processing of Insights Data.
• Email & Call Tracking, Call Recordings and Live Chat – We will collect any personal data provided to us as part of the live chat services and we will track emails, calls and record calls for quality and monitoring purposes.

How do we use your information and lawful basis for processing

We use your personal data for the following purposes, and we are allowed to do so, on certain legal bases which are outlined below.

• Legitimate Interests – We are permitted to process your personal data below if it is based on our ‘legitimate interests’ i.e. we have good, sensible, practical reasons for processing your personal data which is in the interest of Mazda UK. To do so, we have considered the impact on your interests and rights and have placed appropriate safeguards to ensure that the intrusion to your privacy is reduced as much as possible.

Our legitimate interest in processing the personal data below for the purpose specified is to provide you with useful services and information. We only use your personal data for the purposes specified and process personal data that is necessary for these purposes:

• Warranty and Roadside Assistance Services - If you have purchased a new Mazda vehicle, you will receive a Mazda Welcome Pack including a Mazda Roadside Assistance card. When you are nearing the end of three years, the Mazda Roadside Assistance and warranty service provider will communicate with you to let you know the options available to you at the end of this period.
• Service history – Mazda UK provide a secure online database, where your entire vehicles’ service history (inspections and services) is stored and you will receive vehicle service reminders (based on mileage provided at each service) to ensure you are aware of when your vehicle is due its regular service.
• Security Etching – This is provided for new car owners only, to assist you by deterring vehicle theft and cloning as well as improving the chances of recovering stolen vehicles.
• Customer Requests – To fulfil requests you submit to us such as a test drive, service request, brochure request or other type of request submitted through Mazda web platforms or app and will be transferred to your selected Mazda dealer to fulfil the request.
• Vehicle and product quality support – To fulfil services relating to vehicle warranty, technical inspection and resolution support as well as to support product quality and development purposes.
• Customer Support – To fulfil finance contract administration reviews, your data will be transferred to your appointed dealer to provide support during your vehicle ownership. Mazda UK will use your data in order to provide customer support and administration to process any goodwill claims and to resolve any complaint or queries.
• Network Dealer changes - We will update you on changes to our dealer network, where relevant. Where a dealership ceases to operate as a Mazda dealership, your data will be transferred to the nearest dealership in order to provide the above customer support.

Our legitimate interest in processing the personal data below with its respective purposes is to provide effective customer relationship management:

• Dealership and Product Research – We will use your personal data to understand you better as a customer, find out what you think of our vehicle range as well as services delivered by the Mazda dealer network, support organisations, and services delivered to ensure we understand how to deliver an exceptional customer service and product range.
• Quality and Training – We will track, and record voice calls (inbound and outbound) for quality and training monitoring purposes into our dealer network as well as our Mazda UK Customer Relations Team, if you contact us via those channels.
• Marketing analytics and website improvements - We will use your data (which may not identify you directly) within analytics in order to help us monitor visitor numbers and engagement levels and to help us to improve website services.
• Spam prevention - We use the Google reCAPTCHA feature on our website and this is primarily used to distinguish whether an input is made by a natural person or if it is a bot. The service includes the sending of the IP address and possibly other data required by Google for the reCAPTCHA service to Google. Additional information about Google reCAPTCHA and Google's privacy policy can be found here.
• Facebook - Mazda UK’s Facebook fan page allows us to process users’ personal data in line with our legitimate interest in ensuring that our information offer and our communications with users are responsive to needs and target groups (legally based on GDPR Article 6, paragraph 1, point f). Whenever Facebook, as the platform provider, requests your consent to the processing of specific data, the data concerned shall be processed on the legal basis of GDPR Article 6, paragraph 1, point a. Mazda UK will access “Page Insights” which will enable us to access through Facebook various categories of statistical data relating to fan page use, such as the total number of page visits, “likes” data , page activities, post engagement, video views, post reach, comments, shared content, responses, gender breakdown, country and city origin, language, shop views and clicks, clicks on route planners and clicks on telephone numbers. We use this information to make our pages more attractive and responsive to your needs (e.g. by identifying the right time to release content).

Contractual

• Warranty and Roadside Assistance services: If you have purchased a new Mazda vehicle, Mazda UK will process your warranty related data (which includes Vehicle Information) in order to fulfil the warranty and free of charge roadside assistance for 3 years (from the original date of the registration of the vehicle).
• Mazda unlimited mileage warranty and pan-European roadside assistance: If you have purchased a used Mazda vehicle from a Mazda authorised dealership, we will process your warranty related data (which includes Vehicle Information) to provide you with 12 months of Mazda unlimited mileage warranty and 12 months pan-European roadside assistance.

Consent

• Marketing Communications - Where you have given us consent to do so, we will get in touch to provide you with information on relevant Mazda UK products and services as well as latest news such as all new models, promotions and events. You will always have the option to opt out of any further marketing communications. (See How you can amend your preferences later). We will also use the online data gathered to create profiles and to learn about your journey across the Mazda digital ecosystem including our website and app platforms. We will link the personal information you have shared with us via a form submission e.g. newsletter or test drive request to the browser information you linked to a device cookie or to existing tracking or profiling information to offer and improve the personalised experience within the marketing communications we provide. To learn more about the different IDs being set within the Oracle CX Marketing Platform and to review their privacy policy, please refer to the following link. We will use information gathered to support measurement services and targeted online adverts on Facebook or on other third party sites.
• Market Research – We will contact you from time to time to invite you to participate in market research studies such as mystery shopping or other types of research.

Legal Obligation

• Registration of your vehicle – Your data will be inputted into the Registration system in order to register your car with the DVLA.
• Recalls – If we are legally required to carry out products recalls, we and your appointed dealership will use your contact details to contact you to inform you of any relevant recalls.
• Requests from authorities - We will share your personal data with the police, other law enforcement or regulators where we are required by law to do so.

Vital Interests

• 112 Based Emergency Calls – The system will send an automatic emergency message to an emergency call centre in case of a crash of the vehicle, where a decision is made on the appropriate response to the alert (fire brigade, police or ambulance call centre).

Who will handle your data?

We will never sell your information to third parties and will only provide your data to the third parties as detailed above to fulfil the relevant services. Mazda UK uses the following Mazda entities as processors to provide certain services and have access to your personal data in the process:

Mazda UK will ensure that all processors (e.g. IT hosting, database management, customer contact providers, security etching, finance and contract administration, warranty and roadside assistance providers, marketing fulfilment, Mazda dealers) who are handling your data, comply with the Data Protection Laws and that data is only stored within the EEA, where possible. Mazda UK has agreed for your data to be transferred to countries outside of the EEA to fulfil specific processing. To comply with the Data Protection Laws, all our processors are required to provide evidence that they have appropriate levels of technical and operational security measures in place to protect your data, and we have a process in place to ensure these processors comply with their obligations.

Data processed whilst visiting our Facebook fan page may be processed outside the EU. Facebook, Inc., as a Privacy-Shield certified US provider involved in processing your data, has agreed to comply with EU data protection standards:

Privacy Shield (version: 02/11/2018).

How long do we keep your information for?

Where we are storing website data against unique ID’s, as this data is processed in a way that does not identify you as an individual, this data will be kept indefinitely for historical reporting purposes. Where we are storing cookie data linked to personal information, we will store this cookie for 2 years unless you delete it from your browser settings or if you opt out from all marketing cookies on our website.

Call tracking and recordings are kept for no longer than 6 months and for the live chat service we will collect any personal information that you provide as part of the live chat and it will be stored for up to 6 months to enable us to fulfil your enquiry We will retain your personal data for as long as you own a Mazda car and up to 7 years from when we are aware that you no longer own your car, to ensure we are able to deal with any queries you may have on your Mazda or to support any product recall and legal claims process. We may hold this data for a longer period, if we are legally required to do so.

Vehicle information retained for 112-Based Emergency Call System is kept for a maximum of 13 hours from the moment an Emergency call system was initiated.

How you can amend your marketing preferences

If you do wish to stop receiving communications from Mazda UK, you can do this in the following ways:

• Unsubscribe easily from any marketing email by clicking the unsubscribe link within the email.
• Opt out of any marketing communication channels. Please contact the Mazda Customer Relations team via mmukassistance@mazdaeur.com or call the team on 03457 48 48 48 so your preferences can be updated.
• My Mazda App – if you are registered for the My Mazda app you can also change any of your details or amend your marketing preferences within the app.
• Facebook - Should you wish to exercise your rights as a data subject or request information, please note that the most effective way to do so is through Facebook directly. For further information on the processing and use of your data, together with your relevant rights and how you can use settings and objections (opt-outs) to protect your privacy, please refer to the Facebook data privacy statement and Information about Page Insights data here. You can read more about Facebook Opt-outs here or via http://www.youronlinechoices.com

Your Rights

Under the Data Protection Laws you have the following rights in relation to your personal data:

• Right to object to processing of your personal data
• Right to request a copy of your personal data and information on how we process it
• Right to request to move, copy or transfer your personal data (data portability)
• Right for your personal data to be erased
• Right for your personal data to be corrected in a timely manner
• Right to ask us to stop contacting you with direct marketing
• Right to restrict your personal data being processed

To exercise your rights please contact the Mazda UK Data Protection Officer using the contact details provided in the section headed "How to Contact Us". We will ask you for information to confirm your identity and we will then respond to your request within 30 days from when we have received your request.

As a UK Company, MMUK's local supervisory authority is the UK Information Commissioner's Office (ICO). Please visit the ICO website (www.ico.org.uk) for more details. You have a right to complain to the ICO if you believe your personal data has or is being used in a way that you believe does not comply with the Data Protection Laws.

Change to this Privacy Policy

The Privacy Policy will be provided to you at the dealership and can be found on our website at www.mazda.co.uk/privacy-policy or a copy can be provided to you by getting in touch with us, see section headed "How to contact us". We may change this Privacy Policy from time to time and we will alert you when changes are made.

Please view our Cookie Policy here.

VERSION 5 - MAZDA UK PRIVACY POLICY 16 OCTOBER 2020