Privacy policy

GDPR STATEMENT - SWLC Performance Ltd, are committed to protecting and respecting any personal information you share with us.

This statement describes what types of information we collect from you, how it is used by us, how we share it with others, how you can manage the information we hold and how you can contact us.

We will always give you the option not to receive marketing communications from us. We will never send you unsolicited ‘junk’ email or communications, or share your data with anyone else who might. We do not sell your information to third parties, but we do work closely with selected partners who help us to provide you with the information, products, parts and services that you request from us.

The contents of this statement may change from time to time so you may wish to check this page occasionally to ensure you are still happy to share your information with us. Where possible, we will also contact you directly to notify you of these changes.

What information do we collect?

We collect information about you when you engage with us, whether through direct contact at our service centre, our website and social media channels, promotional events or applications. We only collect information which is necessary, relevant and adequate for the purpose you are providing it for.

We collect information about you when you use our website, applications, visit our service centre and use our telephone customer services. We are committed to protecting and respecting any personal information you share with us.

This statement describes what types of information we collect from you, how it is used by us, how we share it with others, how you can manage the information we hold and how you can contact us.

We will always give you the option not to receive marketing communications from us. We will never send you unsolicited ‘junk’ email or communications, or share your data with anyone else who might. We do not sell your information to third parties, but we do work closely with selected partners who help us to provide you with the information, products, parts and services that you request from us.

The contents of this statement may change from time to time so you may wish to check this page occasionally to ensure you are still happy to share your information with us. Where possible, we will also contact you directly to notify you of these changes.

What information do we collect?

We collect information about you when you use our website, applications, visit our service centre and use our telephone customer services. We may also obtain information about you from credit references you provide us with and other sources mentioned below. Some of this information does not identify you personally, but provides us with information about how you use our services and engage with us (we use this information to improve our services and make them more useful to you). The information we collect includes some or all of the following:

• Name (title, first and last name);
• Address postcode, time at address (if private address is used as your business address);
• Up to 5 years historic address history (if private address is used as your business address);
• Photographic ID;
• Job title;
• Account Number (customer ID);
• Vehicle Registration;
• VIN;
• Email address;
• Telephone number and mobile number;
• The website address from which you accessed our website;
• Place of work;
• The pages you visited on our website and how long you visited us for;
• Your IP address;
• Cookie, pixels or beacon information (for more information please see our Cookies Policy. personal information within correspondence you send to us;
• Voice recordings of telephone conversations made to our service centre;
• Feedback collected via surveys;
• Debtor information;
• Payment history;
• Purchase information;
• Details of warranty or goodwill claims;

How do we use this information?

We will only process information that is necessary for the purpose for which it has been collected. You will always have the option not to receive marketing communications from us (and you can withdraw your consent or object at any time). We will never send you unsolicited ‘junk’ email or communications, or share your personal information with anyone else unless we have your consent.

There are various ways in which we use or process your personal information. We list these below:

Processing Activity Description

Account Application/Registration To review your account application, determine whether we will open an account with you; determine whether your account will be cash sales or credit account (based on information you give us and information we obtain from 3rd party sources) and manage your account

Market analysis and surveys To ask for feedback on products/parts purchased or services received

General Communications To contact you with general information such as changes to opening hours, service messages, or to advise you of the opening of new a centre or delivery/collection services

Marketing To send you information on our new products, prices, promotions or tailored marketing based on your products already purchased

Order Fulfilment To process your purchases and returns

Recovery of Debt To contact and liaise with you with regard any non-payment of invoices. If payment not made, your details (name, address, contact information, vehicle registration, VIN Number, information supplied on sales orders of reference for VIN and security parts) will be passed on to our debt recovery agent (see “How do we Share this Information” below)

Customer Service To contact you with rebate earning; price amendments (price match); parts warranty claims; goodwill payments, customer rewards programme information

Safety or Product Recall In the event we need to inform you of a product or safety recall

Consent Where you have provided your consent, we may use and process your information to:

1. Contact you from time to time about promotions, events, products, services or information which we think may be of interest to you (don’t worry, we won’t bombard you);
2. To share your personal information with our recommended third party partners, so that they can contact you with marketing information about their products and services (we will, of course, give you details about these third parties before you give your permission for us to send information to them). 

You can withdraw your consent at any time by contacting us at sales@thelotuscentre.com.

 Contractual performance We may use and process your personal information where this is necessary to perform a contract with you and to fulfil and complete your account registration, your orders, purchases and other transactions entered into with us. This will include:

1. To review your application and, if successful, make a decision as to how we will trade with you (e.g. cash sales, credit account, credit limit, discount applicable);
2. If successful, to create and register your account, so that you are able to purchase through us;
3. To manage your rebates.

 Legitimate Interests We may use and process your personal information as set out below where it is necessary for us to carry out activities for which it is in our legitimate interests as a business to do so.

 Processing necessary for us to support customers with sales and other enquiries

1. To respond to correspondence you send to us and fulfil the requests you make to us (for example: parts delivery, promotions requests or information about specific products);
2. To provide product support and services;
3. To correspond with you in relation to any service messages, such as changes to opening hours/delivery/collection services;
4. To deal with any parts/warranty claims;
5. To undertake credit reference checks;
6. To recover any debt owed by you to us (we will instruct our debt recovery agent to recover the debt on our behalf); and
7. To deal with any complaints, feedback or issues you may raise.

Processing necessary for us to respond to changing market conditions

1. To analyse, evaluate and improve our products and services so that your visit and use of the service centre or website or any related services, is more useful and enjoyable (we will generally use personal information amalgamated from many people so that the resulting information doesn’t identify you personally);
2. To undertake market analysis and research (including contacting you with surveys) so that we can better understand your needs and provide offers, products and services that we think you will be interested in.
3. For product development purposes (for example to improve our products and performance);
4. In some cases we may use automated methods to analyse, combine and evaluate information that you have provided to us. We collect and analyse this information in this way so that we can deliver the most appropriate customer experience to you by tailoring and making relevant all our service and communications.

Processing necessary for us to promote our business, brands and products and measure the reach and effectiveness of our campaigns

1. To contact you from time to time with marketing information (unless you object) if you have expressly indicated to us that you are acting on behalf of a business. In relation to any such information we send by email, post or SMS, we will include an option allowing you to object to receiving future messages;
2. To contact you with targeted advertising delivered online through social media and other platforms operated by other companies, unless you object. You may receive advertising based on information about you that we have provided to the platform or because, at our request, the platform has identified you as having similar attributes to the individuals whose details it has received from us. To find out more, please refer to the information provided in the help pages of the platforms on which you receive advertising from us;
3. To identify and record when you have received, opened or engaged with our website or electronic communications (please see our Cookie Policy for more information);
4. To administer competitions and promotions that you enter with us from time to time and to distribute prizes.

 Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively

1. To verify the accuracy of information that we hold about you and create a better understanding of you;
2. For network and information security purposes i.e. in order for us to take steps to protect your information against loss, damage, theft or unauthorised access;
3. 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);
4. To inform you of updates to our terms and conditions and policies.

Legal Obligation We may process your personal information to comply with our legal requirements (for example for warranty claims).

 Vital Interest Sometimes we will need to process your personal information to contact you if there is an urgent safety or product recall notice and we need to tell you about it.

 How do we share this information?

We do not sell your information to third parties, but we do work closely with third party suppliers who fulfil business activities for us (like credit reference agencies, debt recovery companies, direct marketing agencies)

We do not sell your information to third parties. However, we may from time to time disclose your information to the following categories of companies or organisations to which we pass the responsibility to handle services on our behalf: customer contact centres, direct marketing communications agencies and consultants, market research and market analytics service providers, credit reference agencies, debt recovery companies, software providers, our legal and other professional advisors

We will also share your information with our dealer/retailer network in situations where we need to pass your information to them in order to manage any request or warranty claim you have made to us.

We take steps to ensure that any third party partners who handle your information comply with data protection legislation and protect your information just as we do. We only disclose personal information that is necessary for them to provide the service that they are undertaking on our behalf. We will aim to anonymise your information or use aggregated none specific data sets where ever possible.

There are circumstances where we share your information in order to provide course and training information, fulfil orders, transactions, handle complaints or provide you with a service or information that you have requested. For example we will share information with our group companies where you make a complaint to us and later make the same or similar complaint to them. For more information, please see their privacy statement.

Transfers of your personal information outside of Europe

We do not transfer your personal information outside of Europe. If we do so in the future, we’ll let you know and take measures to protect your personal information.

All information you provide to us is stored on our secure servers which are located within the European Economic Area (EEA).

If at any time we transfer your personal information to, or store it in, countries located outside of the EEA (for example, as a result of changing our hosting services provider) We will ensure that appropriate safeguards are in place for that transfer and storage as required by applicable law. This is because some countries outside of the EEA do not have adequate data protection laws equivalent to those in the EEA. If we transfer your personal information to the United States of America, we will only send the personal information to companies that participate in the Privacy Shield framework (or such other framework that may replace it from time to time) or for which we have an alternative safeguard in place in accordance with applicable law. Where they apply to our data transfer activities, we may rely on adequacy decisions by the European Commission about certain countries for data transfers to countries outside the EEA.

How long do we keep your information for?

We will not hold your personal information in an identifiable format for any longer than is necessary. If you are a customer or otherwise have a relationship with us we will hold personal information about you for a longer period than if we have obtained your details in connection with a prospective relationship.

We do not retain personal information in an identifiable format for longer than is necessary.

If we have a relationship with you (e.g. you have an account with us), we hold your personal information for 6 years from the date our relationship ends. We hold your personal information for this period to establish, bring or defend legal claims. Our relationship may end for a number of reasons including where you no longer wish to purchase from us and want to deactivate your account.

If we have obtained your personal information to explore the possibility of having a relationship with you, we hold your personal information for 1 year from the date we collect that information, unless during that period we form a relationship with you e.g. you register an account with us. We hold your personal information for this period to give us an opportunity to form a relationship with you.

The only exceptions to the periods mentioned above are where:

• the law requires us to hold your personal information for a longer period, or delete it sooner;
• Where you have raised a complaint or concern regarding a product or service offered by us, in which case we will retain your information for a period of 6 years following the date of that complaint or query
• you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law (see further How can I manage the information we hold about you); or
• in limited cases, the law permits us to keep your personal information indefinitely provided we put certain protections in place.

How can you manage the information we hold about you

You have the right as an individual to access your personal information we hold about you and make corrections if necessary. You also have the right to withdraw any consent you have previously given us and ask us to erase information we hold about you. You can also object to us using your personal information (where we rely on our business interests to process and use your personal information).

You have a number of rights in relation to your personal information under data protection law. In relation to most rights, we will ask you for 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 any request.

You have the right to:

1. Ask for a copy of the information that we hold about you;
2. Correct and update your information;
3. Withdraw your consent (where we rely on it). Please see further How do we use this information;
4. Object to our use of your information (where we rely on our legitimate interests to use your personal information) provided we do not have any continuing lawful reason to continue to use and process the information. When we do rely on our legitimate interests to use your personal information for direct marketing, we will always comply with your right to object;
5. Erase your information (or restrict the use of it), provided we do not have any continuing lawful reason to continue to use and process that information;
6. Transfer your information in a structured data file (in a commonly used and machine readable format), where we rely on your consent to use and process your personal information or need to process it in connection with your contract.

You can exercise the above rights and/or manage your information by contacting us using the details below:

SWLC Performance Ltd, Tinhay Industrial Estate, Lifton, Devon PL16 0AH, United Kingdom. email: sales@swlcperformance.com

If you have any specific data protection concerns or a complaint, you can contact us at the address above.

If you are unhappy, you have the right to lodge a complaint with a data protection regulator in Europe, in particular in a country you work or live or where your legal rights have been infringed. The contact details for the Information Commissioner’s Office, the data protection regulator in the UK, are below:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Call: 0303 123 1113
Email: casework@ico.org.uk

The information we collect includes some or all of the following:

• Name (title, first and last name);
• Address postcode, time at address (if private address is used as your business address);
• Up to 3 years historic address history (if private address is used as your business address);
• Photographic ID;
• Job title;
• Account Number (customer ID);
• Vehicle Registration;
• VIN;
• Email address;
• Telephone number and mobile number;
• The website address from which you accessed our website;
• Place of work;
• The pages you visited on our website and how long you visited us for;
• Your IP address;
• Cookie, pixels or beacon information (for more information please see our Cookies Policy.
• Any personal information within correspondence you send to us;
• Voice recordings of telephone conversations made to our contact centres;
• Feedback collected via surveys;
• Debtor information;
• Payment history;
• Purchase information;
• Details of warranty or goodwill claims;

How do we use this information?

We will only process information that is necessary for the purpose for which it has been collected. You will always have the option not to receive marketing communications from us (and you can withdraw your consent or object at any time). We will never send you unsolicited ‘junk’ email or communications, or share your personal information with anyone else.

There are various ways in which we use or process your personal information. We list these below:

Processing Activity Description

Account Application/Registration - To review your account application, determine whether we will open an account with you; determine whether your account will be cash sales or credit account (based on information you give us and information we obtain from 3rd party sources) and manage your account

Market analysis and surveys - To ask for feedback on products/parts purchased or services received

General Communications - To contact you with general information such as changes to opening hours, service messages, or to advise you of the opening of new services

Marketing - To send you information on our new products, prices, promotions or tailored marketing based on your products already purchased

Order Fulfilment - To process your purchases and returns

Recovery of Debt - To contact and liaise with you with regard any non-payment of invoices. If payment not made, your details (name, address, contact information, vehicle registration, VIN Number, information supplied on sales orders of reference for VIN and security parts) will be passed on to our debt recovery agent (see “How do we Share this Information” below)

Customer Service - To contact you with rebate earning; price amendments (price match); parts warranty claims; goodwill payments, customer rewards programme information

Safety or Product Recall - In the event we need to inform you of a product or safety recall

Consent  Where you have provided your consent, we may use and process your information to:

1. Contact you from time to time about promotions, events, products, services or information which we think may be of interest to you (don’t worry, we won’t bombard you);
2. To share your personal information with our recommended third party partners, so that they can contact you with marketing information about their products and services (we will, of course, give you details about these third parties before you give your permission for us to send information to them).

You can withdraw your consent at any time by contacting us at sales@thelotuscentre.com, in relation to any marketing messages you receive.

Contractual performance We may use and process your personal information where this is necessary to perform a contract with you and to fulfil and complete your account registration, your orders, purchases and other transactions entered into with us. This will include:

1. To review your application and, if successful, make a decision as to how we will trade with you (e.g. cash sales, credit account, credit limit, discount applicable);
2. If successful, to create and register your account, so that you are able to purchase through us;
3. To manage your rebates and rewards.

 Legitimate Interests We may use and process your personal information as set out below where it is necessary for us to carry out activities for which it is in our legitimate interests as a business to do so.

 Processing necessary for us to support customers with sales and other enquiries

1. To respond to correspondence you send to us and fulfil the requests you make to us (for example: parts delivery, promotions requests or information about specific products);
2. To provide product support and services;
3. To correspond with you in relation to any service messages, such as changes to opening hours/delivery services;
4. To deal with any parts/warranty claims;
5. To undertake credit reference checks (for example through Experian);
6. To recover any debt owed by you to us (we will instruct our debt recovery agent to recover the debt on our behalf); and
7. To deal with any complaints, feedback or issues you may raise.

Processing necessary for us to respond to changing market conditions

1. To analyse, evaluate and improve our products and services so that your visit and use of our service centre or website or any related services, is more useful and enjoyable (we will generally use personal information amalgamated from many people so that the resulting information doesn’t identify you personally);
2. To undertake market analysis and research (including contacting you with surveys) so that we can better understand your training needs and provide tailored offers, products and services that we think you will be interested in.
3. For product development purposes (for example to improve our products and performance);
4. In some cases we may use automated methods to analyse, combine and evaluate information that you have provided to us (including the sharing of your personal information within our group of companies (see details about our group companies for a full list). We collect and analyse this information in this way so that we can deliver the most appropriate and customer experience to you by tailoring and making relevant all our service and communications.

 Processing necessary for us to promote our business, brands and products and measure the reach and effectiveness of our campaigns

1. To contact you from time to time with marketing information (unless you object) if you have expressly indicated to us that you are acting on behalf of a business. In relation to any such information we send by email or SMS, we will include an option allowing you to object to receiving future messages by unsubscribing;
2. To contact you with targeted advertising delivered online through social media and other platforms operated by other companies, unless you object. You may receive advertising based on information about you that we have provided to the platform or because, at our request, the platform has identified you as having similar attributes to the individuals whose details it has received from us. To find out more, please refer to the information provided in the help pages of the platforms on which you receive advertising from us;
3. To identify and record when you have received, opened or engaged with our website or electronic communications (please see our Cookie Policy for more information);
4. To administer competitions and promotions that you enter with us from time to time and to distribute prizes.

 Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively

1. To verify the accuracy of information that we hold about you and create a better understanding of you;
2. For network and information security purposes i.e. in order for us to take steps to protect your information against loss, damage, theft or unauthorised access;
3. 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);
4. To inform you of updates to our terms and conditions and policies.

 Legal Obligation - We may process your personal information to comply with our legal requirements (for example for warranty claims.

 Vital Interest - Sometimes we will need to process your personal information to contact you if there is an urgent safety or product recall notice and we need to tell you about it.

 How do we share this information?

We do not sell your information to third parties, but we do work closely with third party suppliers who fulfil business activities for us (like credit reference agencies, debt recovery companies, management of customer rewards programme suppliers and market research firms.)

We do not sell your information to third parties. However, we may from time to time disclose your information to the following categories of companies or organisations to which we pass the responsibility to handle services on our behalf: customer contact centres, direct marketing communications agencies and consultants, market research and market analytics service providers, credit reference agencies, debt recovery companies, customer rewards programme suppliers, software providers, our legal and other professional advisors

We will also share your information with our dealer/retailer network in situations where we need to pass your information to them in order to manage any request or warranty claim you have made to us.

We take steps to ensure that any third party partners who handle your information comply with data protection legislation and protect your information just as we do. We only disclose personal information that is necessary for them to provide the service that they are undertaking on our behalf. We will aim to anonymise your information or use aggregated none specific data sets where ever possible.

There are circumstances where we share your information with our parent (or other companies within our Group) in order to provide course and training information, fulfil orders, transactions, handle complaints or provide you with a service or information that you have requested. For example we will share information with our group companies where you make a complaint to us and later make the same or similar complaint to them. For more information, please see their privacy statement.

 Transfers of your personal information outside of Europe

We do not transfer your personal information outside of Europe. If we do so in the future, we’ll let you know and take measures to protect your personal information.

All information you provide to us is stored on our secure servers which are located within the European Economic Area (EEA).

If at any time we transfer your personal information to, or store it in, countries located outside of the EEA (for example, as a result of changing our hosting services provider) We will ensure that appropriate safeguards are in place for that transfer and storage as required by applicable law. This is because some countries outside of the EEA do not have adequate data protection laws equivalent to those in the EEA. If we transfer your personal information to the United States of America, we will only send the personal information to companies that participate in the Privacy Shield framework (or such other framework that may replace it from time to time) or for which we have an alternative safeguard in place in accordance with applicable law. Where they apply to our data transfer activities, we may rely on adequacy decisions by the European Commission about certain countries for data transfers to countries outside the EEA.

How long do we keep your information for?

We will not hold your personal information in an identifiable format for any longer than is necessary. If you are a customer or otherwise have a relationship with us we will hold personal information about you for a longer period than if we have obtained your details in connection with a prospective relationship.

We do not retain personal information in an identifiable format for longer than is necessary.

If we have a relationship with you (e.g. you have an account with us), we hold your personal information for 6 years from the date our relationship ends. We hold your personal information for this period to establish, bring or defend legal claims. Our relationship may end for a number of reasons including where you no longer wish to purchase from us and want to deactivate your account.

If we have obtained your personal information to explore the possibility of having a relationship with you, we hold your personal information for 1 year from the date we collect that information, unless during that period we form a relationship with you e.g. you register an account with us. We hold your personal information for this period to give us an opportunity to form a relationship with you.

The only exceptions to the periods mentioned above are where:

• the law requires us to hold your personal information for a longer period, or delete it sooner;
• Where you have raised a complaint or concern regarding a product or service offered by us, in which case we will retain your information for a period of 6 years following the date of that complaint or query
• you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law (see further How can I manage the information we hold about you); or
• in limited cases, the law permits us to keep your personal information indefinitely provided we put certain protections in place.

 How can you manage the information we hold about you

You have the right as an individual to access your personal information we hold about you and make corrections if necessary. You also have the right to withdraw any consent you have previously given us and ask us to erase information we hold about you. You can also object to us using your personal information (where we rely on our business interests to process and use your personal information).

You have a number of rights in relation to your personal information under data protection law. In relation to most rights, we will ask you for 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 any request.

You have the right to:

1. Ask for a copy of the information that we hold about you;
2. Correct and update your information;
3. Withdraw your consent (where we rely on it). Please see further How do we use this information;
4. Object to our use of your information (where we rely on our legitimate interests to use your personal information) provided we do not have any continuing lawful reason to continue to use and process the information. When we do rely on our legitimate interests to use your personal information for direct marketing, we will always comply with your right to object;
5. Erase your information (or restrict the use of it), provided we do not have any continuing lawful reason to continue to use and process that information;
6. Transfer your information in a structured data file (in a commonly used and machine readable format), where we rely on your consent to use and process your personal information or need to process it in connection with your contract.

You can exercise the above rights and/or manage your information by contacting us using the details below:

 SWLC Performance Ltd, Tinhay Industrial Estate, Lifton, Devon PL16 0AH, United Kingdom. email: sales@swlcperformance.com

If you have any specific data protection concerns or a complaint, you can contact us at the address above.

If you are unhappy, you have the right to lodge a complaint with a data protection regulator in Europe, in particular in a country you work or live or where your legal rights have been infringed. The contact details for the Information Commissioner’s Office, the data protection regulator in the UK, are below:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Call: 0303 123 1113
Email: casework@ico.org.uk