Privacy Policy

This privacy policy aims to give you information on how Bentley collects and processes your personal data through your interaction with Bentley and its websites and digital platforms, vehicles, products and services.  

To ensure that you are fully informed of how and why we are using your data, it is important that you read this privacy policy together with any other privacy policy we may provide on specific occasions when we are collecting or processing personal data about you. This privacy policy supplements our other privacy policies and is not intended to override them.

Data Controller

Bentley Motors Limited (“Bentley”, “we”, “us”) is a company registered in England and Wales (company registration number 0992897).

Contact details

Bentley’s Data Protection Officer (DPO) is responsible for overseeing questions in relation to this privacy policy and our privacy practices. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details below:

Full name of legal entity: Bentley Motors Limited

Email address: DPO@bentley.co.uk

Postal address: Data Protection Officer, Bentley Motors Limited, Pyms Lane, Crewe, Cheshire, CW1 3PL, United Kingdom

The Information Commissioner’s Office (ICO) regulates the processing of personal data in the United Kingdom and is the supervisory authority for data protection issues. You have the right to make a complaint at any time to the ICO (www.ico.org.uk). We would, however, welcome the opportunity to deal with your concerns in the first instance, and will work towards addressing issues or complaints that you may have.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 13th August 2019. We recommend that you check this privacy policy regularly to see if any updates or changes have been made.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third party links

Our websites and digital platforms may contain links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third party websites and are not responsible for the content of, security or privacy policy of such sites. We recommend that you check the privacy and security policies of each website or social media service that you visit and / or sign up to.

The Bentley Collection is the official giftware collection of Bentley Motors Limited and is made available by Dowlis Inspired Branding Limited (Company No. 01179852) of Unit 2 Woking 8, Forsyth Road, Woking, Surrey, GU21 5SB. Dowlis Inspired Branding Limited processes and despatches all orders made via the Bentley Collection website and has access to your personal information including name, shipping & billing address, email address, phone number and order details for the purposes of fulfilling your order, or regarding updates about any orders you have placed. A copy of the Dowlis Inspired Branding Limited privacy policy can be found here.

Our online store is hosted on Shopify Inc. It provides us with the online e-commerce platform that allows us to sell our products and services to you. Your data is stored through Shopify’s data storage, databases and the general Shopify application. It stores your data on a secure server behind a firewall. For more information, you may also want to read Shopify’s Terms of Service here or Privacy statement here.

The payment of any product or service on this website is processed by Shopify Payments. All information provided as part of the transaction process, including name, address and credit / debit card details, is collected and stored by them. A copy of the Shopify Payments privacy policy can be found here.

We use select app providers to improve the service offered on this website. Locksmith by Lightward uses information about you including IP address and country to ensure that this website is served only to visitors who are able to transact on this website and that all products shown are available in the visitors country. Currently, customers from China - Mainland, Hong Kong - China, Macau - China, Taiwan - China and Russia are unable to transact on this website. The Lightward privacy policy can be found here. The EasyAuth ‑ Social Login app by Nexus Media connects users with preferred social network provider to enable single sign-on. Nexus Media collect limited information including visits to the website including count of Visitors and visits, length of time spent on the website, pages clicked on or from where Visitors have come for website analysis and improvements and a copy of their privacy policy can be viewed here.

We use Hotjar  in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices (in particular device's IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy by clicking on this link.

 You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies on other websites by following this opt-out link.

Personal data, or personal information, means any information about a living individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity data (such as name, username or similar identifier, title, marital status, date of birth, gender)
• Contact information (such as billing and delivery address, telephone number/s, e-mail address)
• Interests / preferences (such as purchases or orders made by you, your interests, preferences, feedback and survey responses)
• Image / profile information (such as photographs or other user generated content such as materials you may submit for competitions, or personal interests that you may add to social media platforms)
• Transaction data (such as details of products and services you have purchased from us, as well as date and time of purchase)
• Usage data (such as information about how you use our websites, products and services)
• Marketing and communications data (such as your preferences in receiving marketing from us and our third parties, your communication preferences)

If you use a digital device to activate or access Bentley services, we may collect information about your specific device. This could include:

• Technical data (such as the IP address used to connect your computer to the internet, login information, browser type and version, time zone setting and location, browser plug in types and versions, operating system and platform)
• Location information (through for example, IP address, GPS)
• Information about your visit (such as URL clickstream to / through / from our website, products viewed or searched for, products added to your basket and any abandoned baskets, page response times, download errors, length of visit to certain pages, page interaction information, method used to browse away from the page, phone number used to call our customer services number)
• Information relating to e-mail communications (such as time / date stamp that the e-mail is opened, links accessed from the e-mail, unsubscribe preferences)

We also collect, use and share aggregated data such as statistical or demographic data. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Our websites and digital platforms are not intended for children and we do not knowingly collect data relating to children. In the event that we learn we have collected information from a child without verification of parental consent, we will delete that information.

If you fail to provide personal data

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 perform the contract we have or are trying to enter into with you (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 but we will notify you if this is the case at the time.

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your personal information by filling in forms or by corresponding with us by post, phone, email, SMS / MMS, direct messaging or otherwise. This includes data you provide when you:
• enquire about / purchase our products and services
• attend Bentley events, product shows or test drives
• create an account on or visit our website
• subscribe to our services or publications
• request marketing to be sent to you
• enter a competition, promotion or survey
• give us feedback or contact us
• Automated technologies or interactions. As you interact with our websites and digital services including social media platforms, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
• Information provided to us by our authorised online retailer, Dowlis Inspired Branding Limtied trading as the Bentley Collection responsible for the delivery of service.
• Information provided to us directly by your independent, Bentley authorised dealership (hereafter, “Bentley Retailer / Retailer”)
• Technical data from parties such as analytics providers and search information providers
• Advertising networks
• Identity and contact data from publicly available sources and data brokers
• Information which is freely available through public internet searches

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where processing your data is necessary for the performance of a contract we are about to enter into or have entered into with you
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service / product and overall experience. We make sure that we consider and balance any potential impact on you and your rights before we process your personal data for our legitimate interests
• Where we need to comply with a legal obligation

Generally we do not rely on consent as a lawful basis for processing your personal data. However we will get your consent where it is required before sending direct marketing communications to you. You have the right to withdraw consent to marketing at any time.

Purposes for which we will use your personal data

We have set out below a description of all the ways we may use your personal data. We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason that is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your data 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. You will receive marketing communications from us if you have requested information from us or purchased from us and you have consented to receiving that marketing, where consent is required.

Third party marketing

We will get your express opt-in consent before we share your personal data with any third party who may then contact you for their own marketing purposes.  

Opting out

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing communication sent to you. Alternatively you can contact us directly by calling +44(0)1270 444 450.

We may share your personal data with the parties set out below for the purposes set out in Section 4, ‘How we use your personal data’:

• Internal third parties (such as other companies within the Volkswagen Group)
• External third parties (such as our authorised online retailer, service providers acting on our behalf, professional advisers and other authorities/ regulatory bodies) as defined in section 1.
• Third parties, to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) (subject also to any relevant data localisation legislation). It may also be processed by staff operating outside of the EEA who works for us or for one of our suppliers, such as your local Bentley Retailer. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and provision of support services. We will take all reasonable steps necessary to ensure that your data is treated securely and in accordance with this privacy policy and current UK Data Protection Law unless otherwise stated.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by implementing at least one of the following safeguards:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission
• Where we use certain service providers, we may use specific model contracts approved by the European Commission which give personal data the same protection it has in Europe

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

We generally store and process your personal information for no longer than 6 years from the date of your last purchase from the Bentley Collection, or for no longer than 2 years if you have provided your details for another reason, such as account creation or marketing communications.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances we will anonymise your personal data (so that you are not identifiable and the data can no longer be associated with you) for research or statistical purposes. In this case we may use this information indefinitely without further notice to you.

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

• Request access to your personal data, commonly known as a "data subject access request". This enables you to receive a copy of the personal data we hold about you
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. In many instances you can amend the personal data directly
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request
• Object to processing of your personal data. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms in this instance
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • If you want us to establish the data's accuracy
  • Where our use of the data is unlawful but you do not want us to erase it
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it
• Request the transfer of your personal data to you or to a third party
• Withdraw consent at any time where we are relying on consent to process your personal data. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact our DPO:

DPO@bentley.co.uk

Fees

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.