Recognizing the importance of the protection of personal information in the advanced information and telecommunications society, Liaco Limited (“we”, “our”) complies with the Act on the Protection of Personal Information (“Act”) and other related laws and regulations and guidelines, etc. and will handle personal information lawfully and properly.
We will acquire any personal information by lawful and fair means.
Except as set forth in the Act, we will not provide personal data to a third party, without the prior consent of the owner of such personal data (“Owner”).
In order to carry out this Privacy Policy, we will formulate a Personal Information Protection Compliance Program (including this Privacy Policy, “Regulations for Protection of Personal Information” and other rules and regulations)(“Compliance Program”) and keep our officers and employees fully informed of, implement, maintain and continuously improve the Compliance Program.
Established on March 30, 2005
Final Revision on May 02, 2024
LIACO LIMITED
Liaco is a trading name of Liaco Limited and its subsidiaries (collectively referred to as “Liaco”, “we” or “us” in this notice).
Overview
Maintaining
the security of your data and ensuring that you are in control of how
your data is handled is a priority at Liaco. We are dedicated to
ensuring that we are transparent about the data that we collect about
you, how we use it and the conditions whereby we may disclose your data
to others. We will ensure that your data is kept secure and that you are
aware of the steps we have taken to ensure the security of your private
information.
Liaco
takes the security of your data very seriously and strictly adheres to
guidelines published in the Maltese Data Protection Act 1998 and the
General Data Protection Regulation 2016/679 which is applicable from
25th May 2018. Any questions relating to this notice and our privacy
practices should be sent to dataprotection@liaco.eu
This notice applies whether you visit one of our dealerships or our websites, and aims to provide you with information about:
Personal data we collect
We
will only collect relevant data to enable us to carry out the service
you have requested or accessed, below we have set out in more detail
about the personal data we collect and why we collect it. We review our
retention periods regularly and will only hold your data for as long as
it is necessary for the original purpose it was collected for, as
required by law or as set out in any relevant contract we have with you.
Service Booking
To
make an online vehicle service or VRT booking via www.liaco.eu or over
the phone, we require your name, contact information and vehicle
details. This information is required so that we can arrange your
booking for you at your chosen dealer and send you your booking
confirmation through your preferred contact method (email or SMS).
If
you have purchased a vehicle from Liaco or you have previously had a
service at one of our dealerships our aftersales system will have stored
your information, along with your service and VRT due date. We will
send you our yearly service/VRT reminder as we feel it will be in your
Legitimate Interest to know when these events occur. You can object to
receiving these reminders at any time.
As
an existing customer, should you choose to book your next service via
our service reminder we may use a cookie to pre-populate your details to
avoid you having to type in details on subsequent visits.
Vehicle Search
When
you search for a new or used vehicle on our website we may store
information on the vehicles you searched for and viewed in a cookie so
that we can provide personalised content, and suggest other vehicles you
may also be interested in.
Online Enquiry
If
you enquire about one of our vehicles we require your name, email
address and contact telephone number to able us to respond to your
enquiry.
Test Drive or Courtesy Car
If
you book a test drive or take a courtesy car from our service
department we require a copy of your driving licence, we will store a
copy of this in case of any speeding, parking or other motoring offence
that may occur.
Sell your car
If you request a valuation for your current vehicle
we require your vehicle details including registration number, mileage,
plus your name, email address and telephone number so that we can send
you your indicative valuation.
Vehicle Purchase
If
you decide to purchase a vehicle from Liaco, at the point of sale under
a Contractual Obligation we will collect your full name, address,
contact number, date of birth, driving licence details, payment details,
details of the vehicle you are buying and, if applicable, details of
the vehicle you will be using as a part exchange. Your details will not
be used for marketing purposes unless you provide consent for us to do
so. If you purchase a new vehicle we will be Contractually Obliged to
send your details to the manufacturer for warranty, registration and
recall purposes.
Vehicle Finance
If
you require finance for your vehicle purchase, we will require
additional information including marital and housing status, number of
dependents, previous address, occupation, employer, business address and
bank details, in addition we will also require proof of address (i.e.
utility bill) and any other relevant information. With your permission
this information will be passed to our selected finance partners..
In Dealership Visit
We
operate CCTV in all of our dealerships to monitor our premises,
therefore your image and vehicle registration may be captured and stored
for up to 12 months.
Competitions
If
you enter one of our competitions, we require your name, email address
and telephone number so that we can contact the winner. Competitions are
subject to terms and conditions.
Contact by phone
Should
you call one of our dealerships or should we contact you in response to
an enquiry, your phone call may be recorded and will be retained for a
maximum of 12 months. The recording will be used for quality and
training purposes only.
Retention
We
will retain your personal data for no longer than is necessary and
usually no longer than 7 years after your contract is over (unless
otherwise required)
Liaco
uses your personal data for electronic marketing purposes and we may
contact you to update you in accordance with your selected marketing
preferences.
You have the right to opt out of receiving promotion communication at any time by;
We
may use and process your personal information where it is necessary for
us to pursue our Legitimate Interest as a business for the following
purposes;
Automated Processing
When
visiting our website, we may collect data directly from you as set out
in this notice, as well as analysing your browsing and purchasing
activity, both online and in dealership, along with your previous
response to marketing communications. The results of this data
(collected by Cookies) allow us to ensure that we contact you with
information on products and offers that are relevant to you. To do so,
we use automated profiling software.
Liaco recommend that you accept cookies for the following reasons;
Website Banner Marketing
If
you visit our website, you may receive personalised banner
advertisements whilst browsing other websites including but not limited
to search engines and social networking. Any banner advertisement you
will see will relate to products you have viewed whilst browsing our
website on your computer or other devices.
These
advertisements are provided by Liaco using ‘Cookies’ placed on your
computer or other device. You can remove or disable cookies at any time –
see our cookies policy for more information.
Social Media
You
may receive advertising based on information about you that we have
provided to the social media platform or because, at our request, the
platform has identified you as having similar attributes to the
individuals whose details it receives from us.
For the Prevention of fraud and other criminal activities
To undertake credit checks for finance
To correspond and communicate with you
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 list in order
to be able to comply with your request.
For accuracy of data
In
order to keep our data up to data and accurate improvements made be
made to our database e.g. by consolidating records we hold about you.
General Administration
We
may need to process your data to manage your queries, complaints, or
claims and may result in us contacting you by the contact details you
have previously provided.
We may use and process your personal data where it is necessary for the performance of a contract with you or in order to take steps at your request before entering into a contract with you including for the following purposes;
We
may use your personal information to contact you if there are urgent
safety or product recall notices to communicate to you or where we
otherwise reasonably believe that the processing of your personal
information may prevent or reduce any potential harm to you.
We will use your personal data to comply with our Legal Obligations
Collection of general data and information
Our
website collects a series of general data. This general data and
information is stored in the server log files. General data includes (1)
the browser types and versions used, (2) the operating system used by
the accessing system, (3) the website from which an accessing system
reaches our website (so-called referrers), (4) the sub-websites, (5) the
date and time of access to the Internet site, (6) an Internet protocol
address (IP address), (7) the Internet service provider of the accessing
system, and (8) any other similar data and information that may be used
in the event of attacks on our information technology systems.
When
using general data and information, we do not draw any conclusions
about visitors. Rather, this information is needed to (1) deliver the
content of our website correctly, (2) optimise the content of our
website as well as its advertisement, (3) ensure the long-term viability
of our information technology systems and website technology, and (4)
provide law enforcement authorities with the information necessary for
criminal prosecution in case of a cyber-attack. Therefore, we only
analyse anonymously collected data and information statistically, with
the aim of increasing the data protection and data security of our
enterprise, and to ensure an optimal level of protection for the
personal data we process. The anonymous data of the server log files are
stored separately from all personal data provided by individuals.
Sharing Data with third parties
In order to
make certain services available to you, we may disclose your personal
information to third parties. We will only disclose the minimum amount
of personal data in order to provide the
service. We have data sharing agreements in place with each of our
third-party suppliers and have completed the necessary security checks
to ensure that your data is kept safe once it is passed to them. Our
third-party suppliers only have the rights to use your data for the
purpose of fulfilling the service required of them, they do not have
marketing rights over your data, unless you have specifically expressed
third party consent. Your data will be shared with third parties under
the following circumstances;
• If
your enquiry leads to the purchase of a new vehicle your information
will be shared with the relevant manufacturer for warranty, registration
and safety recall purposes. We will ask for your consent to pass your
information to the manufacturer for marketing purposes. We recommend
that you read the manufacturers privacy policy to see how they will use
your data.
• If
your enquiry leads to the purchase of a vehicle with a finance
agreement, we will disclose your information to our selected finance
partners. If you are accepted for finance, the finance company with
become the data controller for your information and we recommend that
you read their privacy policy to see how they will use your data.
Marketing
When
you provide us with your personal data we may ask you to set your
marketing preferences with us so that you can choose (if any) the
information you'd like to hear more about as set out in the 'When
Consent is required' section. This may be done by;
• Registering for offers via our website; or
• Visiting our dealership / contacting us via telephone
If
you opt-in to receive marketing from manufacturers, we recommend that
you read their privacy policy to see how they will use your data and how
to alter your marketing preferences with them should you wish to in the
future.
From
time to time, we may ask you to refresh your marketing preferences by
asking you to confirm that you consent to continue receiving marketing
information from us
Legal rights
Your Rights
You have a number of
rights in relation to your personal information under data protection
law. In relation to certain rights, we may ask you for your information
to confirm your identity and, where applicable, to help us search for
your personal information. Except in rare cases, we will respond to you
within 30 days after we have received this information or, where no such
information is required, after we have received your request.
Accessing your personal information
You
have the right to ask for a copy of the information we hold about you
by emailing or writing to us at the end of this notice. This will be
provided in a readable format (CSV or PDF) free of charge. We may not
provide you with a copy of your information if this concerns other
individuals or we have another lawful reason to withhold that
information.
Correcting and updating your personal information
The
accuracy of your information is important to us and we are working on
ways to make it easier for you to review and correct the information we
hold about you. In the meantime, if you change your name or
address/email address, or you discover that any of the other information
we hold about you is inaccurate or out of date, please let us know by
contacting us via the details at the end of this notice.
Withdrawing your consent
Where
we rely on your consent as the legal basis for processing your personal
information, as set out under ‘How we use your personal data’ section,
you may withdraw your consent at any time by contacting us using the
details at the end of this notice. If you would like to withdraw your
consent to receiving any direct marketing to which you previously
opted-in, you can also do this by selecting the ‘amend my preferences’
or ‘unsubscribe’ link located at the bottom of our emails. If you
withdraw your consent, our use of your personal information before you
withdraw is still lawful.
Objecting to our use of automated processing
You
may contest to a decision made about you based on automated processing
by contacting us on the details at the end of this notice.
Erasing your personal information or restricting its processing
In
certain circumstances, you may ask for your personal data to be removed
from our systems by emailing or writing to us at the address at the end
of this notice. Unless there is a reason that the law allows us to use
your personal information for longer, we will make reasonable efforts to
comply with your request.
You may also ask us to restrict processing your personal data in the following situations;
In
these situations, we may only process your personal information whilst
its processing is restricted if we have your consent or are legally
permitted to do so, for example for storage purposes, to protect the
rights of another individual or company in connection with legal
proceedings.
Contact us
Complaining to the Maltese data protection regulator;
You
have the right to complain to the Information Commissioners Officer
(ICO) if you are concerned about the way we have processed your personal
information. Please visit the ICO website for further details.
How to contact us
Please contact us if you have any questions about our privacy notice or information we hold about you:
By email: dataprotection@liaco.eu
Or write to us at: Data Protection Officer, Liaco Limited, Triq il-Mosta, Lija, LJA 9012.