About Parkway Volkswagen

We, Parkway Derby Limited (trading as Parkway Volkswagen) take information security and data protection seriously. We are committed to ensuring that your privacy is protected. This Privacy Policy describes how we use the personal data we collect from you, or that you provide, when you:

• Visit any of our websites or portals (the “Website”);
• View and enquire on vehicles in one of our showrooms or online;
• Purchase a vehicle, parts, accessories or a service plan from us;
• Have your vehicles serviced with us;
• Make an online booking with us;
• Or otherwise contact us.

Please read this Privacy Policy carefully before submitting any personal data to us.

Definitions

Information we collect

We collect Personal Data from you through the use of forms, which may be on paper or on our Website. There are various reasons that we need to collect Personal Data from you:

• Orders: So that we can fulfil any order for vehicles, parts, accessories or services that you place with us, we will need to collect your name, contact details (address, email address and telephone number) and payment details.
• Records: As part of our business, we maintain guarantee and service records for the vehicles and parts that we sell and/or service, and in keeping these records, we will need to identify you as the owner of that vehicle.
• Safety issues: Where the vehicle manufacturer notifies us of any safety issues which may affect your vehicle, we will contact you using the details held in our records.
• Services: Where you have a service plan or have otherwise asked us to do so, or where it is part of our contract with you, we will contact you using the details held in our records with information and/or reminders about servicing and MOTs for your vehicle.
• Enquiries: Where you contact us with an enquiry or request a brochure, we will respond to you using the contact details you have provided.
• Surveys: From time-to-time, to improve our customer service or for research purposes, we may ask you to complete a survey or similar. Any personal data that you provide when completing a survey will be retained for the purpose of that survey.
• Marketing: We may wish to tell you about other products and services we think may be of interest to you, or to share new and exclusive offers, news and events with you. We will only contact you with such marketing communications if you have provided your consent and given at least one preferred contact method, including direct mail, telephone, SMS or email.

We may also use Personal Data which you provide to us in any of the ways listed above and in the following ways:

• To deal with and/or respond to any enquiry or request made by you prior to entering into any contract or agreement with us or as a result of such contract or agreement;
• To carry out our obligations arising from any contracts entered into between you and us;
• To comply with a legal obligation to which we are subject;
• To notify you about any changes to our business or the products offered where it is in our legitimate interests to do so and where you have expressed an interest in the same previously or where such notification is required so as to allow us to perform any contractual agreement with you or where you have expressly opted in to receiving such communications.

Sharing your Personal Data

The information you share with us will only be disclosed to relevant employees to be used for the relevant purpose stated above. We will not otherwise disclose your personal data to any third party unless one of the following applies:

• Your Personal Data may be shared with other subsidiaries of the Company and Third Parties for the purposes set out above. Some Third Parties may be based outside the EEA, in countries that do not have the same standards of protection for personal information as the United Kingdom. We will, however, always comply with our obligations under the Data Protection Legislation before sending your Personal Data to such countries, to ensure sufficient protections are in place to safeguard your Personal Data;
• We, and/or Third Parties may contact you with information about products and services that we, or the Third Parties, think may be of interest to you, where you have given your consent to receive marketing communications from us and/or Third Parties;
• In order to deliver our services to you and, as necessary, we may use Third Party processors. Such processing is conducted under contract which contains the same protections for your Personal Data as are set out in this policy and we ensure that appropriate data protection and information security assurances are provided;
• Where it is necessary for the performance of our contract with you, including where we need to take steps to enforce any agreement which may be entered between us;
• Where we are under a legal duty to do so in order to comply with any legal obligation to which we are subject;
• To protect the rights, property or safety of our company, our staff and others;
• In the event that we sell or buy any business or assets in which case we may disclose your Personal Data to the prospective seller or buyer as part of the sale or purchase process and disclosure is required to allow that transaction to proceed; or
• If we or substantially all of our assets are acquired by a Third Party, in which case personal data that we hold about our customers will be one of the transferred assets.

Data retention

You can select your marketing preferences by ticking the relevant boxes on any form where we collect personal data from you. We will not contact you for marketing purposes unless you have given us your prior consent. If you have opted-in to receive marketing material from us, we will use your chosen contact methods to send this information.

If, at any time, you no longer wish to receive marketing information, please send a written request to customerservices@parkwayvolkswagen.co.uk or on all of our email marketing communication it will give you the option to opt-out of receiving further marketing communications.

Please note that you will still receive emails directly related to an enquiry you have made via our online enquiry portal or under any other contract you have with us.

Access to your Personal Data, and your other rights

You have the right to request a copy of the Personal Data the Company holds about you, at any time and at no cost to you. Should you wish to access, update or correct the Personal Data that we hold, please contact us by sending a written request to Customer Services.

If you wish to have your Personal Data deleted by the Company, please request this in writing to Customer Services. Your Personal Data will be removed within 30 days as long as it is not required for the completion of a contract with the Company or for any legal reason.

You also have the right to ask us not to process your Personal Data for any purpose. We will usually inform you (before collecting your Personal Data) if we intend to use your Personal Data for marketing purposes or if we intend to disclose your information to any Third Party for such purposes and will only process your data in this manner where we have a legitimate interest in doing so. You can exercise your right to prevent such processing by not ticking certain boxes on the forms we use to collect your data (where provided), or by withdrawing your consent at any time if you change your mind. You can also exercise that right and your right to object to any other processing at any time by sending a written request to Customer Services.

Finally, you also have the right to request that we supply your data to a Third Party as part of your right to data portability.

Data security

The security of your Personal Data is of the utmost importance to us. We are committed to providing appropriate security controls to protect your personal information against foreseeable hazards.

All information you provide to us is stored on our secure servers which are located in the United Kingdom only. Any payment transactions will be encrypted.

Please be aware that the transmission of data over the internet is not always completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the complete security of your data transmitted to us electronically; any transmission is at your own risk. Once we have received your Personal Data, we will use strict procedures and security features to restrict unauthorised access to your Personal Data.

Cookie usage

We use cookies to help improve our website and make your browsing experience more useful, relevant and tailored to you. Please see our Cookie Policy for more information.

Website links

We may add links to and from our Website to our partner networks, advertisers and affiliates from time to time. If you follow a link to any of these websites, please note that these websites will contain their own privacy policies. We do not accept any responsibility or liability for these policies. Please check these policies before you submit any Personal Data to these websites.

Changes to this Privacy Policy

We keep our Privacy Policy under regular review; the updates will appear on our Website. Please check it each time you visit this Website or provide us with any Personal Data.

We last updated this Privacy Policy on 6 March 2018.

Policy feedback

If you have any questions about this Privacy Policy or any Personal Data which we hold about you please contact Customer Services.

Job Applicant Privacy Notice

Data controller: Nicola Kroczak, Finance Director, Parkway Volkswagen Ltd, Locomotive Way, Pride Park, Derby, DE24 8PU

As part of any recruitment process, the organisation collects and processes personal data relating to job applicants. The organisation is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.

The organisation collects a range of information about you. This includes:

• your name, address and contact details, including email address and telephone number;
• details of your qualifications, skills, experience and employment history;
• information about your current level of remuneration, including benefit entitlements;
• whether or not you have a disability for which the organisation needs to make reasonable adjustments during the recruitment process;
• information about your entitlement to work in the UK; and
• equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief.

The organisation may collect this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment, including online tests.

Your information may be shared internally for the purposes of the recruitment exercise. This includes our Head of People and Performance, Managers within the business and Admin staff.

Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).

If your application for employment is unsuccessful, the organisation will hold your data on file for up to 1 month after the end of the relevant recruitment process. If you agree to allow the organisation to keep your personal data on file, the organisation will hold your data on file for a further 6 months for consideration for future employment opportunities. At the end of that period your data is deleted or destroyed.

Complaints

If you are unhappy with the way in which we have collected or processed your Personal Data or have any other complaint in relation to our handling of your Personal Data you can make a complaint to the Information Commissioner. Further information can be found on the Information Commissioner’s website at www.ico.org.uk or via their helpline on 0303 123 1113.

What are cookies?

Cookies are small text files containing a string of characters that can be placed on your computer or mobile device that uniquely identify your browser or device.

What are cookies used for?

Cookies allow a website or service to know if your computer or device has visited that website or service before. Cookies can then be used to help understand how the website or service is being used, help you navigate between pages efficiently, help remember your preferences, and generally improve your browsing experience. Cookies can also help ensure marketing you see online is more relevant to you and your interests.

What types of cookies does Parkway Derby Limited use?

There are generally four categories of cookies: ‘Strictly Necessary’, ‘Performance’, ‘Functionality’ and ‘Targeting’. Parkway Derby Limited only uses two types of cookie, being ‘Strictly Necessary’ and ‘Functionality’. You can find more about each cookie category below.

How long will cookies stay on my device?

The length of time a cookie stays on your computer or mobile device depends on whether it is a ‘persistent’ or ‘session’ cookie. Session cookies will only stay on your mobile device until you stop browsing. Persistent cookies will stay on your computer or mobile device until they expire or they are deleted.

First and Third-Party cookies

First-party cookies are cookies that belong to Parkway Derby Limited’s Website. Third-party cookies are cookies that another party places on your device through our Service. Third-party cookies may be placed on your device by someone providing a service for Parkway Derby Limited’s Website, for example, to help us understand how our service is being used. Third-party cookies may also be placed on your device by our business partners so that they can use them to advertise products and services to you elsewhere on the Internet.

How to control and delete cookies

If you want to delete or disable your browser from receiving cookies, follow the instructions at:

• Microsoft Internet Explorer
• Microsoft Edge
• Google Chrome
• Apple Safari
• Mozilla Firefox
• Opera

Please note: If you set your browser to disable cookies, you may not be able to access certain parts of our Website and other parts of our Website may not work properly. You can find out more information on cookie settings at third-party sites, such as www.allaboutcookies.org.

Parkway Derby Limited is an Appointed Representative of Automotive Compliance Ltd who is authorised and regulated by the Financial Conduct Authority (FCA No. 497010). Automotive Compliance Ltd’s permissions as a Principal Firm allows Parkway Derby Limited to act as a credit broker, not a lender, for the introduction to a limited number of lenders, and to act as an agent on behalf of the insurer for insurance distribution activities only. We are a credit broker and not a lender. We can introduce you to a carefully selected panel of lenders, which includes manufacturer lenders linked directly to the franchises that we represent. We act on behalf of the lender for this introduction and not as your agent. We are not impartial, and we are not an independent financial advisor.

Our approach is to introduce you first to the manufacturer lender linked directly to the particular franchise you are purchasing your vehicle from, who are usually able to offer the best available package for you, taking into account both interest rates and other contributions. If they are unable to make you an offer of finance, we then seek to introduce you to whichever of the other lenders on our panel is able to make the next most suitable offer of finance for you. Our aim is to secure a suitable finance agreement for you that enables you to achieve your financial objectives.

If you purchase a vehicle, in the majority of cases, we will receive a commission from your lender for introducing you to them which is either a fixed fee, or a fixed percentage of the amount that you borrow. This may be linked to the vehicle model you purchase. Different lenders pay different commissions for such introductions, and manufacturer lenders linked directly to the franchises that we represent may also provide preferential rates to us for the funding of our vehicle stock and also provide financial support for our training and marketing. But any such amounts they and other lenders pay us will not affect the amounts you pay under your finance agreement; however, you will be contributing towards the commission paid to us with the interest collected on your repayments.

Before we propose you to a potential lender, we will inform you of the likely amount of commission we will receive and seek your consent to receive this commission. The exact amount of commission that we will receive will be confirmed prior to you signing your finance agreement. All finance applications are subject to status, terms and conditions apply, UK residents only, 18s or over. Guarantees may be required.

Introduction

This statement sets out Parkway Derby Limited’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed to ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to the actions and activities during the financial year 2024/2025.

As part of the Automotive Retail & Repair industry, the Company recognises that it has a responsibility to take a robust approach to slavery and human trafficking.

Organisation structure and supply chains

This statement covers the activities of Parkway Derby Limited:

Our supply chains include sourcing, sale and leasing motor vehicles (predominantly Volkswagen), parts, consumables and provision of services, repairs, including body and repair. Respecting human rights in the supply chain is ultimately our suppliers’ responsibility however we will ensure that our expectations concerning slavery and human trafficking are communicated to them.

Relevant policies

The Company operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

• Whistleblowing policy: The Company encourages all its workers, customers, and other business partners to report any concerns related to the direct activities, or the supply chains of, the Company. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The Company’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.
• Employee code of conduct: The Company’s code makes clear to employees the actions and behaviour expected of them when representing the Company. The Company strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
• Supplier code of conduct: The Company is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The Company works with suppliers to ensure that they meet the standards of the code and improve their workers’ working conditions. However, serious violations of the Company’s supplier code of conduct will lead to termination of the business relationship.
• Recruitment/agency workers policy: The Company uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.

Training

The Company requires all relevant staff within the Company to complete training on modern slavery.

The Company’s modern slavery training covers:

• Our business’s purchasing practices, which influence supply chain conditions and which should, therefore, be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below the country’s national minimum wage, or the provision of products by an unrealistic deadline;
• How to assess the risk of slavery and human trafficking about various aspects of the business, including resources and support available;
• How to identify the signs of slavery and human trafficking;
• What initial steps should be taken if slavery or human trafficking is suspected;
• How to escalate potential slavery or human trafficking issues to the relevant parties within the Company;
• What external help is available, for example through the Modern Slavery Helpline.

Board approval

This statement has been approved by the Company’s board of directors, who will review and update it annually.

As an Appointed Representative (AR) of ACL, we are required to adhere to this document and adopt the policy statements it sets out, or to incorporate them into our own policy statements.

Overview

The Financial Conduct Authority’s (FCA) Treating Customers Fairly (TCF) initiative is primarily based on the obligation set out in Principle 6 requiring a Dealership to pay due regard to the interests of its customers and treat them fairly.

TCF is embedded throughout the FCA’s Handbook and as a responsible company you must ensure that all products or services you provide satisfy the FCA’s six core consumer outcomes, which are:

1. “Consumers can be confident they are dealing with Firms where TCF is central to the corporate culture”.
2. “Products and services marketed and sold in the retail market are designed to meet the needs of identified consumer groups and targeted accordingly”.
3. “Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale”.
4. “Where consumers receive advice, the advice is suitable and takes account of their circumstances”.
5. “Consumers are provided with products that perform as Dealerships have led them to expect and the associated service is both of an acceptable standard and as they have been led to expect”.
6. “Consumers do not face unreasonable post-sale barriers imposed by Firms to change product, switch provider, submit a claim or make a complaint”.

Code of Ethics

Our Dealership is committed to observing the highest standards of ethical behaviour and as such expects its staff to observe and abide by the following:

• Act honestly and fairly at all times in the best interests of each customer and ensure they are treated fairly;
• Operate with integrity when fulfilling the responsibilities of our appointment and seek to avoid any acts, omissions or business practices which damage the reputation of our firm, associates, and the financial services industry;
• Observe all applicable laws, regulations and professional conduct standards when carrying out financial services activities.

As an Appointed Representative (AR) of ACL, we are required to adhere to this document and adopt the policy statements it sets out, or to incorporate them into our own policy statements. To be used in conjunction with the ACL Vulnerable Customers Academy Module.

On September 25th, 2020, the FCA set out new best practice guidance for firms to do more to protect vulnerable consumers:

“Today’s guidance sets out what firms should do to ensure vulnerable consumers are being treated fairly. We know many more customers will be struggling with their finances as a result of the impact of coronavirus. Supporting vulnerable consumers is a key focus for the FCA, and the recent coronavirus crisis has only highlighted its importance” (Christopher Woolard, interim Chief Executive at the FCA).

FCA Definition

“A vulnerable customer is someone who, due to their personal circumstances, is especially susceptible to harm – particularly when a firm is not acting with appropriate levels of care” (FCA FG21/1 Updated February 2021).

Policy Guidelines

Ensuring consumers have an appropriate degree of protection is central to what the FCA does. This includes protecting vulnerable consumers.

“We want vulnerable consumers to experience outcomes as good as those for other consumers and receive consistently fair treatment. We have regard to the general principle that consumers should take responsibility for their choices and decisions.

However, there are very real factors that might limit their ability to do so, and characteristics of vulnerability may result in consumers having additional or different needs and may limit their ability or willingness to make decisions and choices or to represent their own interests.”

These consumers may be at greater risk of harm particularly if things go wrong.

The FCA expect firms to provide their customers with a level of care that is appropriate given the characteristics of the customers themselves.

ACL’s Vulnerable Customers policy is based on this paper and is designed to deliver both the purpose and spirit of this guidance.

At Parkway Volkswagen we pride ourselves on delivering first class customer satisfaction to all our customers, however we understand that every now and again we unfortunately don’t meet expectations. When this happens the first step to take is to get in contact with a member of our team.

General complaints

For complaints relating to non-regulated activities — anything concerning the dealership, sales or after sales — please contact us directly via email with the details and any supporting documentation. If you do not have an email account, you can telephone us or send a letter.

Our management team is committed to resolving any issues or problems you have, whatever they may be. Often problems are quickly resolved within 24 hours leaving customers happy with the service they received.

Complaints regarding FCA regulated activities

Regulated activities are Finance or Insurance. If your complaint relates to these then please contact Automotive Compliance directly.

Financial Ombudsman Service

If we cannot resolve your complaint within 8 weeks, you may refer your dispute to the Financial Ombudsman Service. This service is free to use. Their consumer helpline is available on 0800 023 4567 or 0300 123 9123 or you can visit their website at www.financial-ombudsman.org.uk.