Throughout this policy, the words “we” and “us” refer to Hyundai Motor UK Ltd unless otherwise indicated.
The information we collect and when
We only collect information that we know we will genuinely use, and in accordance with applicable data protection legislation. We collect information voluntarily from you, as well as under statutory and contractual requirements, and also from authorised Hyundai retailers and repairers and from other third parties. The types of data we collect include:
- Full Name
- Telephone number(s)
- Email address
- Date of birth
- IP address
- Vehicle details (including a copy of your V5 certificate)
- Car insurance details, which may include health details
- Bank account details
- Car finance details
- Driving licence for test drives
- Passports for identity verification and where we offer travel abroad for any purpose
- Survey responses
- Geolocation data
- Death certificate (only processed in a deceased change of ownership scenario).
We will also access personal data held in the DVLA database of drivers to confirm the registered keeper of drivers in the event that a Hyundai vehicle is subject to a recall.
If you use our Tomorrow’s Journey extended test drive service, in addition to the above, we will also collect the following telematics information:
- Vehicle data including but not limited to geolocation data and maintenance data
If you use our MOCEAN subscription service, in addition to the above, we will also collect the following information:
- Employment details
- Income details
- Your photographic image to identify you against your driving licence
We also offer you the option to access our MOCEAN service with Google Sign in. Google Sign in is a service of Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. By using this Sign in with Google button on our Mobility Platform, you have the option to register or login using your Google user data. Google will share your name, email address, language preference, and profile picture with our Mobility Platform. Only if you give you consent in your Google Account prior to the registration and subject to a notice about the sharing of data by Google will HMUK receive your Google user data.
The Google sign in is managed by Google and more information about how your personal data is processed can be found here.
We will always let you know when there is a statutory or contractual requirement or obligation for you to provide us with your personal information for us to provide services and products to you. In all other circumstances, you are under no statutory or contractual requirement or obligation to provide us with your personal information.
The legal basis for processing your data is based either on your specific consent; performance of a contract; compliance with a legal obligation; or our legitimate interest that we will have stated at the point the information was initially provided. We will not store, process or transfer your data outside the parties detailed above unless we have an appropriate lawful reason to do so.
HMUK has a legitimate interest in processing personal data to provide products or services to our customers which include responding to queries, issues or complaints as well as conducting analysis to tailor our products and offering to our customers.
Keeping your information accurate
To keep the personal information we hold as accurate as possible in line with regulations, we may use third party sources of information to correct the information held on our databases, such as when you move house or when your postcode changes. The sources we employ include Mortascreen, The Bereavement Register (TBR), GAS Goneaway, National Change of Address (NCOA Track), Mailing Preference Service (MPS) and Mosaic for profiling.
We may, in further dealings with you, extend this information to include your purchases, services used, and subscriptions, records of conversations, and agreements and payment transactions.
How we use your information
We may use your personal information for a number of purposes including:
Providing customer services to you
- For example, contacting you to follow up on your enquiry, change of onership requests, replying to any questions, suggestions, issues or complaints you may have contacted us about.
Making available our products and services to you
- For example, processing your orders, taking payment from your or giving you a refund, managing product recalls and sending out service messages such as service and MOT reminders.
Personalising your buying experience
- For example, we may provide you with details of products that match another product which you may have purchased or enquired about previously.
- We may also use your information and monitor our social media channels to help us better understand you as a customer, including the products and services you consume, so we can serve you better.
- For example, to provide you with online advertising, promotions and update your preferences. More information on how Hyundai UK uses your information for marketing purposes can be found in the Marketing section.
Asking for your feedback
- For example, to collect feedback from you about our products, websites, mobile apps, and other services and activities, and for statistical analysis.
- We may also occasionally invite you to review a product or service you've bought or used from us. If we do, it's possible that we'll use independent research and feedback providers to act on our behalf.
For security and legal reasons
- For example, responding to Data Subject Access Requests (DSARs) requires the processing of your data in order to provide you with the requested data and, and to allow us to meet our legal obligations or to enforce other obligations.
Maintaining Hyundai UK’s records
- For example, contacting you to enable Hyundai UK to maintain the accuracy of our records.
If you use our Tomorrow’s Journey extended test drive service, we may use your information for the following purposes in addition to the above:
- To monitor vehicle maintenance and, if necessary, vehicle recovery
If you use our MOCEAN subscription service, we may use your information for the following purposes in addition to the above:
- To confirm that you meet the eligibility criteria to apply for MOCEAN Subscription;
- To process your application for the service;
- To obtain a credit score on you;
- To store your selection of the preferred MOCEAN Subscription package (the desired date of your subscription, the specific vehicle (model, segment, powertrain, etc.) and your mileage calculation;
- To contact and support you with your application and performance of MOCEAN subscription, if requested;
- To upload information and evidence of your driving licence for the purpose of validation of your identity and your driving licence. For more details, please refer to the consent when uploading your driving licence;
- To check, validate, and approve your requested MOCEAN Subscription package, including your acceptance of our General Terms & Conditions as well as your Specific Terms & Conditions;
- To contact you in order to arrange the date, time and location for handover and/or turnover of the vehicle. Please note, depending on the purpose of the communication, we will contact you via email as well as via SMS;
- To verify your personal data and identity during the handover of the vehicle at the delivery or pick-up;
- To inspect, maintain, record and proceed with the conditions and potential damages of the vehicle upon the handover and turnover; and
- For administrative purposes with insurance partners.
Who we might share your information with
We may share your personal data with organisations who carry out activities on our behalf in the following circumstances:
- Our network of authorised Hyundai retailers and repairers for the purposes of providing services and vehicles to our customers and prospects;
- Hyundai Capital UK Ltd, which provides financial products to purchase Hyundai vehicles;
- Our parent Company, Hyundai Motors Europe In Germany as well their parent company, Hyundai Motor Corporation in South Korea;
- Tomorrow’s Journey, a third party who provides the technology platform for our extended test drive service;
- Third party insurance providers to provide insurance quotes for a Hyundai vehicle;
- Breakdown providers who provide services under contract to Hyundai;
- Third party managed contact centres;
- Debt collection agencies, where a debt is owed and remains unpaid with us;
- Third parties such as market research companies, marketing agencies and lead generation companies and well as other third parties who provide us with personal data; and
- Third party payment handling services to securely process customer payments on behalf of HMUK.
If you use our MOCEAN subscription service, in addition to the above, we may also share your personal data with organisations who carry out activities on our behalf in the following circumstances:
- The DVLA to validate your entitlement to drive and obtain conviction data for insurance purposes as well as to decide whether you are eligible for the subscription service;
- Local Councils as well as other parking providers where an infringement may have occurred;
- The Police where there is an allegation of a road traffic offence; and
- TransUnion Information Group, who are a credit reference agency that we use for the purpose of determining a credit score, which goes toward deciding whether we offer you the subscription service. An overview of the way that TransUnion and other credit reference agencies collect, use and share personal data is available here.
- Casi AS, who provide the technology platform through which our subscription services are offered.
We may also share your information with other organisations in the following circumstances:
- If the law or a public authority says we must share the personal data;
- If we need to share personal data in order to establish, exercise or defend our legal rights (this includes providing personal data to others for the purposes of preventing fraud and reducing credit risk); or
- From time to time, we may employ the services of other parties for dealing with certain processes necessary for the operation of our website. However, all the information we share will be collected and anonymised, so neither you nor any of your devices can be identified from it.
We will send you relevant offers and news about our products and services in a number of ways, including by email and SMS, but only if you have previously consented to receive these marketing communications. When you register with us, we will ask if you would like to receive marketing communications, and you can change your marketing choices at any time, either online, over the phone or in writing.
If you wish to amend your marketing preferences, you can do so by visiting the preference centre on our website, or alternatively by calling us on 0800 981 981. You can also unsubscribe from specific communications, for example, email or SMS.
Automated decision making and profiling
If you use our MOCEAN subscription service, we will use automated decision making to help us understand if you meet our financial and eligibility criteria for the service. The automated decision making uses personal information which you provide to us and third party information, such as your credit score which is provided by TransUnion.
We may also use personal information which you provide to us or which we have collected from your interactions with us to personalise and improve your Hyundai experience.
Hyundai UK and Social Media
When using our websites or mobile applications, you may be able to share information through social networks like Facebook and Twitter. For example, you may ‘like’, ‘share’ or review our services. When doing this, your personal information may be visible to the providers of those social networks and/or their other users. Please remember that it is your responsibility to set appropriate privacy settings on your social network accounts so you are comfortable with how your information is used and shared on them.
How long we keep your information for
We retain a record of your personal information in order to provide you with a high quality and consistent service. We will always retain your personal information in accordance with applicable data protection legislation, and never retain your information for longer than is necessary unless otherwise required by law. For customers, your data will be stored for a period of 6 years after the end of any warranty period, at which point if we not heard from you we will cease processing the data; For MOCEAN subscribers, your data will be stored for a period of three years after your subscription service ends; For newsletter subscribers, we will continue to process your data until you unsubscribe from our newsletter; For any lapsed customers, we will process your data for 6 years after you no longer own the vehicle unless we have had heard from you during that time; and For prospects, if we do not hear from you for 6 years and 3 months after our initial contact with you we will cease processing your data.
Data security is of great importance to Hyundai. To protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure your collected data.
We take technical and organisational security measures to protect your information including:
- Limiting access to our buildings to those that we believe are entitled to be there (by use of passes, key card access and other related technologies);
- Implementing access controls to our information technology;
- Using appropriate procedures and technical security measures (including strict encryption, anonymisation and archiving techniques) to safeguard your information across all our computer systems, networks, websites, mobile apps, offices and stores;
- Never asking you for your passwords; and
- Advising you never to enter your account number or password into an email or after following a link from an email.
Your rights over your information
Right to access your personal information
You have the right in many circumstances to access the personal information that we hold about you by making a request. This is sometimes termed a ‘Subject Access Request’.
Right to correct your personal information
If any of the personal information we hold about you is inaccurate or out of date, you may ask us to correct it.
Right to stop or limit our processing of your data
You have the right to object to us processing your personal information if we are not entitled to use it anymore, if you would no longer like us to process your information for direct marketing purposes or if we are using your personal information for automated decision-making purposes. You may also have the right to have its processing restricted in certain circumstances.
Right to erasure
You have the right to have your personal information erased by Hyundai in specific circumstances.
Right to portability
You have the right to ask us to share your personal information to another organisation.
If you would like to exercise any of your rights, please contact us as set out below in the ‘How to contact us’ section. For all rights, we will ask for proof of your identity and sufficient information about your interactions with us that we can locate your personal information and take action as requested.
For more information about your privacy rights
The Information Commissioner's Office (“ICO”) regulates data protection and privacy matters in the UK. They make a lot of information accessible to consumers on their website and they ensure that the registered details of all data controllers such as ourselves are available publicly. You can access them here.
You can make a complaint to the ICO at any time about the way we use your information. However, we hope that you would consider raising any issue or complaint you have with us first. Your satisfaction is extremely important to us, and we will always do our very best to solve any problems you may have.
How to contact us
If you would like to exercise one of your rights as set out above, or you have a question or a complaint about this policy or the way in which your personal information is processed, please contact us by one of the following means:
By email: firstname.lastname@example.org
By post: Birchwood Building, Springfield Drive, Leatherhead, Surrey KT22 7LP.
This policy was last updated on 28 July 2021.