Welcome to the Bentley Motors Limited (“Bentley”) Bentley Collection website privacy policy.
Bentley respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
This privacy policy is provided in a layered format so you can click through to the specific areas set out below.
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:
If you use a digital device to activate or access Bentley services, we may collect information about your specific device. This could include:
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:
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:
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.
Purpose/Activity | Type of data | Lawful basis for processing, including basis of legitimate interest |
To manage our relationship with you which will include: | ||
To respond to any questions or complaints you may have regarding our products and services | (a) Identity (b) Contact (c) Concerns and complaints (d) Purchase history (e) Activity and interaction | (a) Necessary for our legitimate interests (to support customers with sales and other enquiries, to operate our business) (b) Performance of a contract with you |
To fulfil requests you make to us (for example: product information, , call back requests , brochure requests or information about specific products) | (a) Identity (b) Contact (c) Purchase history (d) Activity and interaction
| (a) Performance of a contract with you |
To notify you about changes to our terms or privacy policy | (a) Identity (b) Contact (c) Marketing and communications | (a) Necessary to comply with a legal obligation |
To register you as a new customer | (a) Identity (b) Contact (c) Purchase history (d) Marketing and communications (e) Activity and interaction (f) Profiling Retailer interaction history (g) Profiling, demographics and lifestyle | (a) Necessary for our legitimate interests (to support customers with sales and other enquiries, to operate our business) |
To verify the accuracy of information that we hold about you and create a better understanding of you as a customer | (a) Identity (b) Contact (c) Concerns and complaints (d) Product data (e) Purchase history (f) Marketing and communications (g) Activity and interaction (h) Profiling online Retailer interaction history (i) Profiling, demographics and lifestyle
| (a) Necessary for our legitimate interests (to support customers with sales and other enquiries, to operate our business) |
To personalise your experience of our services (for example: tailor offerings within the Bentley Network App or digital platforms based on your usage, profile and interactions) | (a) Identity (b) Contact (c) Product data (d) Purchase history (e) Marketing and communications (f) Activity and interaction (g) Profiling, demographics and lifestyle | (a) Necessary for our legitimate interests (to support customers with sales and other enquiries, to operate our business) |
To provide you with access to additional services, such as the Bentley Network app | (a) Identity (b) Contact (c) Purchase history (d) Marketing and communications (e) Activity and interaction (f) Proof of identity | (a) Necessary for our legitimate interests (to support customers with sales and other enquiries, to operate our business) |
To make suggestions, recommendations and market to you about goods or services that may be of interest to you, which will include: | ||
To send you details of products, services, exclusive events, special offers and rewards that we think will be of interest to you, unless you object | (a) Identity (b) Contact (c) Marketing and Communications (d) Activity and interaction (e) Purchase history (f) Usage and web activity tracking (g) Social media (h) Profiling, demographics and lifestyle | (a) Where you have provided your consent (b) Necessary for our legitimate interests (to tailor and provide relevant services and communications in the event that consent is not required) |
To measure or understand the effectiveness of the communications we serve to you to make them more relevant | (a) Identity (b) Contact (c) Marketing and Communications (d) Activity and interaction (e) Purchase history (f) Usage and web activity tracking (g) Social media (h) Profiling, demographics and lifestyle | (a) Necessary for our legitimate interests (to understanding customers’ and drivers’ needs and measure the reach and effectiveness of our campaigns) |
To contact you with targeted communications delivered online through social media and other platforms operated by other companies | (a) Identity (b) Contact (c) Marketing and Communications (d) Activity and interaction (e) Purchase history (f) Usage and web activity tracking (g) Social media (h) Profiling, demographics and lifestyle | (a) Where you have provided your consent (b) Necessary for our legitimate interests (to tailor and provide relevant services and communications in the event that consent is not required) |
To identify and record when you have received, opened or engaged with our website or electronic communications | (a) Identity (b) Contact (c) Marketing and Communications (d) Activity and interaction (e) Usage and web activity tracking (f) Social media | (a) Necessary for our legitimate interests (to understanding customers’ and drivers’ needs and measure the reach and effectiveness of our campaigns) |
To help us provide you with improved products and services, which will include: | ||
To undertake market analysis and research so that we can better understand you as a customer | (a) Identity (b) Contact (c) Concerns and complaints (d) Product data (e) Purchase history (f) Activity and interaction (g) Retailer Interaction History (h) Profiling, demographics and lifestyle | (a) Where you have provided your consent |
For product/ service development purposes (including contacting you with customer surveys), for example to improve product quality, performance and safety | (a) Identity (b) Contact (c) Concerns and complaints (d) Product data (e) Purchase history (f) Marketing and Communications (g) Activity and interaction (h) Profiling, demographics and lifestyle | (a) Necessary for our legitimate interests (to study how customers use our products/ services, to develop them, to grow our business and to inform our marketing strategy) |
To carry out data analytics to improve our website and applications, products/services, marketing, experiences and customer service centre | (a) Identity (b) Purchase history (c) Marketing and Communications (d) Activity and interaction (e) Profiling, demographics and lifestyle | (a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
Images and/ or videos may be captured and used to gain insight in order to make recommendations to the business for future product development and strategy | (a) Identity (b) Photographs, videos, voice recordings | (a) Necessary for our legitimate interests (to operate our business) |
To process and deliver your requests, which will include: | ||
Fulfilment of requests placed by you or on your behalf | (a) Identity (b) Contact (c) Activity and interaction (d) Product data (e) Business Relationship/ Association (f) Purchase history | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to operate our business) |
To perform a contract with you and to fulfil and complete your orders, purchases and other transactions entered into with us (or one of our selected partners) | (a) Identity (b) Contact (c) Activity and interaction (d) Product data (e) Business Relationship/ Association (f) Purchase history (g) Usage and web activity tracking | (a) Performance of a contract with you |
To provide you with service information, warranty information, reminders and updates in relation to the products and services you’ve ordered from us | (a) Identity (b) Contact (c) Activity and interaction (d) Product data (e) Marketing and Communications (f) Purchase history | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to operate our business) |
Manage payment, fees and charges | (a) Identity (b) Contact (c) Purchase history | (a) Performance of a contract with you |
To determine your eligibility for our products and services / whether they’re available in your area | (a) Identity (b) Business Relationship/ Association (c) Profiling, demographics and lifestyle (d) Purchase history | (a) Necessary for our legitimate interests (to operate our business) |
Complying with laws and regulations that apply to us, which will include: | ||
To meet our contractual requirements with third parties (for example to provide ownership information to vehicle warranty underwriters) | (a) Identity (b) Contact (c) Product data (d) Purchase history (e) Proof of identification (f) Marketing and Communications (g) Retailer Interaction History (h) Activity and interaction | (a) Performance of a contract with other organisations |
To contact you if there is an urgent safety or product recall notice and we need to tell you about it | (a) Identity (b) Contact (c) Product data (d) Purchase history (e) Retailer Interaction History | (a) Necessary to comply with a legal obligation |
To demonstrate compliance with anti-money laundering rules | (a) Identity (b) Contact (c) Purchase history (d) Proof of identification (e) Retailer Interaction History | (a) Necessary to comply with a legal obligation |
To monitor any other regulatory requirements linked with treating customers fairly and processing records properly | (a) Identity (b) Purchase history (c) Proof of identification (d) Marketing and Communications (e) Retailer Interaction History (f) Activity and interaction | (a) Necessary to comply with a legal obligation |
To help authorities with any security, crime or anti-terrorism enquiries | (a) Identity (b) Contact (c) Product data (d) Purchase history (e) Proof of identification (f) Retailer Interaction History (g) Activity and interaction | (a) Necessary to comply with a legal obligation |
To inform you of updates to our terms and conditions and policies | (a) Identity (b) Contact (c) Marketing and Communications | (a) Necessary to comply with a legal obligation |
Responding to courts and enforcement authorities | (a) Identity (b) Contact (c) Product data (d) Purchase history (e) Proof of identification (f) Marketing and Communications (g) Retailer Interaction History (h) Activity and interaction | (a) Necessary to comply with a legal obligation |
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) | (a) Identity (b) Contact (c) Product data (d) Purchase history (e) Marketing and Communications (f) Retailer Interaction History (g) Activity and interaction | (a) Necessary to comply with a legal obligation |
To administer and protect our business and this website, which will include: | ||
Troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data | (a) Identity (b) Contact (c) Business Relationship/ Association | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation (c) Performance of a contract with you |
To enable you to partake in a prize draw, competition or complete a survey: | ||
To enable you to partake in a prize draw, competition or complete a survey | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
To generate product exposure and develop marketing material: | ||
Profiling and analysis, conducted for strategic brand development | (a) Identity (b) Contact (c) Profiling, demographics and lifestyle (d) Social media (e) Purchase history | (a) Necessary for our legitimate interests (to operate our business and create products/service marketing material to grow our business) |
Profiling and identifying influencers, Royals and VIPs | (a) Identity (b) Contact (c) Profiling, demographics and lifestyle (d) Social media (e) Purchase history | (a) Necessary for our legitimate interests (to operate our business and create products/service marketing material to grow our business) |
Cultivating relationships with influencers | (a) Identity (b) Contact (c) Profiling, demographics and lifestyle (d) Social media (e) Usage and web activity tracking (f) Purchase history | (a) Necessary for our legitimate interests (to operate our business and create products/service marketing material to grow our business) |
To capture images and/ or videos for marketing and promotion in all and any media, including Bentley’s printed publications, presentations, promotional materials, in the advertising of Bentley’s goods or services or on the Bentley website or within video montages, training materials, newsletters and on Retailer Marketing News Online, unless you object | (a) Identity (b) Contact (c) Social media | (a) Necessary for our legitimate interests (to create products/service marketing material and grow our business) |
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’:
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 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:
If you wish to exercise any of the rights set out above, please contact our DPO:
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.
