Privacy Policy and Data Protection
Motor Gap Ltd are committed to protecting and respecting your privacy
This privacy policy explains how we use any personal data we collect about you. This policy explains how you can access your personal data that we hold and how to raise a query or complaint about how we process your personal data.
The information you need to know about us
We are Motor Gap Ltd, we sell motoring related insurance and support products direct to the public. For the purpose of these sales, we act as both the data controller and a data processor.
Trading styles of Motor Gap Ltd are:
Direct Gap.co.uk
Direct Excess.co.uk
Motor Gap.co.uk
Motor Gap.com
Our Registered address:
Hawkstone House,
Valley Rd,
Hebden Bridge
HX7 7BL
Company number 7109212
The Information we collect - how we collect it - how we use it
This policy is applicable to the processing of personal information at all trading styles of Motor Gap Ltd. The purpose of this policy is to provide our current, former and potential customers information, products, and services that protect against financial loss or maintenance in the course of motor vehicle usage. These products and services include, Gap Insurance, Tyre Insurance, Scratch and Dent Insurance, Alloy Wheel Insurance and Excess Insurance Products. This policy is aimed at vehicle owners aged over the age of 18. We collect and use information about people who visit our website or contact us in other ways (as detailed below) this is carried out in accordance with data privacy laws.
Our Legal basis for processing your personal information
This privacy policy will explain how we may use the information that we obtain and how you can access the information being processed or retained. We make every effort to ensure that personal data is only used where consent is obtained in line with EU law. At the point of us requesting consent we will provide you with confirmation of the use of the data in connection with the consent request. You would therefore consent, or we would use your data in the following circumstances (on one of the following basis):
• Personal consented to the use of your data.
• Consent to enter into contract with you.
• Consent, we need to use it in order to comply with our legal obligations.
• The use is necessary for us to protect your vital interests.
• We need to use it to perform a task in the public interest.
• We use it to achieve a legitimate interest, and our reasons for using it outweigh
any prejudice to your data protection rights.
Generally, we will process data on the basis of personal, contractual consent, or legitimate interest. You may withdraw your consent at any time at privacy@directgap.co.uk further details are provided below. If we are processing on the basis of our need to achieve a legitimate interest, the nature of that interest is confirmed below.
What information do we collect?
If you use our enquiry form
We collect information via our enquiry forms, we collect your name, email address and telephone number and your contact email address. In some circumstances we collect business data that may be considered to be personal data such as the name of your business and the type or legal status of your business. We need to collect this for the legitimate business purpose of processing your enquiry (we collect both email and telephone contact details in case we cannot reach you using one of these).
The form automatically creates a digital file for you in our Customer Relationship Manager (CRM) software, which is hosted by our hosting provider Heart Internet. The digital file is stored indefinitely. We may use the data to contact you in the future where we have a legitimate interest in doing so. You may ask for it to be deleted in accordance with your rights which are confirmed in the Information Access section below which describes how you can manage your personal information.
If you use our contact form or live call back service
If you use the contact form service, we will collect your name and email address if you provide this and any other personal information that you volunteer to us. This is used for the legitimate business purpose of handling customer enquiries in real time and then following up with either an email message or live telephone call. The data is stored by us and the VoIP telephone provider Twilio or Yay.com in the EEA and sometimes the US. If the data is stored in the US it is done so under the EU-US privacy shield framework (which provides protections for an individual’s personal data when it is transferred from the EU to the US). The digital file is stored indefinitely. If you are new customer, the personal data you include in your chat may also be used to create a digital file for you in our Customer Relationship Manager (CRM) software (see the section above for further information on data held on our CRM system). Twilio & Yay.com are our voice over internet provider and retain digital copies telephone calls on our behalf Please see Twilio’s & Yay.com privacy policies for more information on how they use your data. https://www.twilio.com/legal/privacy & https://www.yay.com/about/privacy.
If you email us
Any email sent to us, including any attachments may be monitored by us for cybersecurity reasons. Email blocking software may also be used. Motor Gap Ltd has a legitimate business interest in using your email address, and any personal data included in your message, to resolve or respond to any issues raised. Your email will be handled in line with our policies, depending on the nature of your inquiry.
We use our customer relationship platform & Zen to process all inbound emails, all outbound emails are sent through our email exchange at Zen mail. Some inbound and outbound emails are stored on the CRM system hosted by Heart Internet. Zen mail store emails in in the EEA and sometimes the US. If the data is stored in the US it is done so under the EU-US privacy shield framework (which provides protections for an individual’s personal data when it is transferred from the EU to the US). The data is stored indefinitely.
Emails sent to named individuals within Motor Gap Ltd (e.g.tom@directgap.co.uk) will be stored on our systems indefinitely for the legitimate business purpose of resolving your enquiry and then checking how enquiries have been dealt with, however will not be processed for any other purposes.
If you visit any of our product websites, Motor Gap Ltd and Subsidiary Websites
All of our trading styles (as listed above) use a third-party service, Google Analytics, to collect standard internet log information (your IP address, browser, and type of device) and details of visitor behaviour patterns (where you joined our site from, the path you take through our site and where you leave). We do this for the legitimate business purpose of monitoring the number of visitors to the various parts of the site and engagement levels, which in turn enables us to make improvements. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website.
Motor Gap Ltd also uses cookies on its websites. You can read more about how we use cookies in our Cookie Policy. This Privacy Policy does not cover the links within this site linking to other websites. We encourage you to read the privacy statements on the other websites you visit.
Product Quotations Forms
Motor Gap Ltd and or any of our Trading Styles may generate product pricing information, repayment terms and policy details upon request of a website form or from a direct marketing contact.
The legal basis for contacting you will be under either personal consent or legitimate interests depending on the nature of how we first received your inquiry or personal data. This means that Motor Gap Ltd may use your personal data that we have collected according to this Privacy Policy to tell you about Motor Gap Ltd services and offers. A second copy of the original quotation may be sent 14 days after the communication, if no contact has been made with the data subject. This will reconfirm the information submitted, the full details of the quotation and expiry date of the quotation.
Whenever we collect your personal data, you have the right to amend or object to receiving these direct marketing communications at any time, by doing one of the following:
email us at privacy@directgap.co.uk and we will amend your preference for you;
Unsubscribe where provided on communications that we send you or when you take out a policy with us;
Write to us at Motor Gap Ltd, Hawkstone House, Valley Rd, Hebden Bridge, HX7 7BL
If you join our mailing lists
If you use our mailing lists, we will collect your name and email address if you provide this and any other personal information that you volunteer to us. This is used for the legitimate business purpose of providing the information you have requested.
The form automatically creates a digital file for you in our Customer Relationship Manager (CRM) software, which is hosted by our hosting provider Heart Internet. The digital file is stored for a period of up to six months from the last email sent to you from our mailing lists.
Policy Holders
Our legal basis for data processing will be the performance of that contract, and we hold the details of the people who have requested the product or service in order to provide it. The source of the personal data we hold will be from our data provider SEOPA, direct sales activity, or from the customer themselves.
Typically, the data we hold will include contact details (such as name, address, phone, email), data on the covered item (in the case of motor- related products details such as the make, model and registration number of the vehicle. We will also hold details of our customer’s interactions with us, such as contact with our Customer Service Team and/or claims history. We only use these details, so we can contact you about an enquiry you have made, to contact you if there is a problem with your claim, to provide the service you have requested and for other closely related purposes.
For example, we might use information about people who use our products and services to carry out a survey to find out if they are happy with the level of service they receive from us.
We may share data with other organisations to provide our customers with the service they have requested, such as passing on your name, contact number and vehicle’s make and model to a Motor Repairer when a vehicle goes in for a repair or when a claim is made. For insurance products, we will share your data with the insurer. The name of your insurer is stated in your policy document. When sharing your data, we will share the minimum amount of data with them.
We will store your personal information safely for the duration of the contract and then for a further three or six years (depending on your relationship with us), after the contract has been terminated. The data will then be destroyed. All personal information is accessed only by authorised members of the team on a need to know basis.
We will not share your personal data with third parties unless we have your permission or are required to do so by law.
Policy Holders Direct Marketing
Motor Gap Ltd or any of our trading styles may contact you for the purposes of direct marketing.
The legal basis for contacting you will be under either consent or legitimate interests depending on the nature of how we first received your inquiry or personal data. This means that Motor Gap Ltd may use your personal data that we have collected according to this Privacy Policy to tell you about Motor Gap Ltd.’s or its subsidiaries services and offers.
Whenever we collect your personal data, you have the right to amend or object to receiving these direct marketing communications at any time, by doing one of the following:
email us at privacy@directgap.co.uk and we will amend your preference for you;
Unsubscribe where provided on communications that we send you or when you take out a policy with us;
Write to us at Motor Gap Ltd, Hawkstone House, Valley Rd, Hebden Bridge, HX7 7BL
Free Gap Insurance
Customers taking advantage of the Free 14 Day Gap Insurance policy will give consent to receive a full price Gap quotation on their vehicle either by text message, email or telephone.
This can be opted out of at any time either by emailing privacy@directgap.co.uk , replying STOP to a quotation email or text message or by informing any advisor of their free gap insurance policy number and their wish to remove consent.
Potential Customers
Motor Gap Ltd have a direct sales team who contact individuals to discuss the benefits of our products and services. We use third- party data providers to buy in marketing data such as SEOPA Ltd (SEOPA) trading as Quotezone who supply us with the data we need to make the call.
The legal basis for contacting you, will be under consent and our data provider SEOPA ensures all our data is opt-in for marketing purposes and that it is not TPS registered. Whenever we make contact, you will be given the opportunity to opt-out to receiving marketing from us.
We request from SEOPA the minimal data needed for us to make the call (such as a name, address and phone number and vehicle details). We also impose tight criteria to ensure our marketing activity is as focused and relevant as we can make it (for example only requesting opt-in data on individuals whose vehicles fall within a certain age and/or mileage limit) when making vehicle product related telesales calls.
We will store this information safely for the duration of the telesales campaign. All of our telesales campaign data is “one-time use” which means that if someone does not wish to take up a product or service with us, we will respect the customers wishes and will not attempt to contact them again at that time.
How we share your data with our third-party suppliers
• Zen e-mail for our email services
• Fasthost Internet Ltd who provide website hosting
• Heart Internet Ltd who provide CRM hosting
• Amazon Web Services who provide data storage hosting
• Microsoft UK who provide some of our office systems.
• Google.com (analytics) who prove website tracking and statistical services
In all cases, the servers where your personal data is stored and processed are located in the European Economic Area.
Sharing your data with 3rd parties
We employ other companies and individuals to perform functions on your behalf. Examples include processing direct debit details, storing of personal data and providing our customers with the service they have requested.
When processing payment card transactions, Motor Gap Ltd use third-party payment services companies such as Sage Pay, to ensure that all payments are safe, secure and protected against fraud. The third-party service providers may have access to the personal information required to perform their functions, but they will not use it for any other purpose and must process the personal information in accordance with this privacy notice and as permitted by applicable data protection laws.
Should you register for any Motor Gap Ltd event or download any 3rd party content, we may pass your contact information to 3rd parties who either a) are partners of the event in question or b) are providers of the content you have downloaded. In the process of registering for an event or accessing content, you will be reminded of the fact that your data will be shared with named 3rd parties and specific consent will be requested.
What we do with your information
We use your personal information to send you an email or communicate by text or telephone to communicate the product, service or report that you have requested. If you opt-in (Affirmative action) to join one of our mailing lists, we will use your personal data to operate your subscription to the mailing list you have chosen to join.
We will retain your personal data for up to six months after the last email sent to you from our mailing lists
How long do we keep your data for?
We keep your personal information in line with our data retention policy dependant on the medium by which the data was provided, the details for each is mentioned above. This means that we will remove data which we have collected directly from you from our systems if we haven’t had any direct contact with you in line with the stated period. (this period typifies the maximum length of time that a contract could be in negotiation with us).
For data provided to us by our clients, we are governed by their data retention rules as specified in their privacy notices.
In certain circumstances, we have a statutory obligation to keep your personal information for a set period of time for example financial information (normally 6-7 years) for financial auditing purposes
Links to other websites
We link our website directly to other sites. This privacy notice does not cover the links within our site linking to other websites and organisations. We encourage you to read the privacy statements on the other websites you visit.
Sale of business
In the event that this business is sold or integrated with another business your details may be disclosed to our advisers and any prospective purchasers' advisers and will be passed on to the new owners of the business. It is therefore intended that any consents given above or on the relevant pages will benefit any purchaser of our business.
Your use of our services
Please be sure you are aware of these policy terms while you use our site. should our terms change these will be shown on this page, and we may place notices on other pages of the web site, so that you may be aware of the information we collect and how we use it at all times.
Access: Under data privacy laws, you have rights to request access to your personal data.
How to keep your personal information up-to-date
It’s important for both you and us that your personal information is correct. If you believe this not to be the case and you are registered on this website, then please log-in and update your details in the “my login” section. If you do not have a website account with us then please e-mail the amended details to privacy@directgap.co.uk and we will contact you to verify your identity.
How you can find out about the information we hold about you
You have the right to request a copy of the information that we hold about you.
If you would like a copy of some or all of your personal information, please email or write to us using the contact details in this policy.
We will get in contact to verify your identity and If we do hold information about you we will give you a description of it and:
- tell you why we are holding it
- tell you who it could be shared with
- let you have a concise and clear copy of the information
Our legal basis for processing your personal information
The basis of our processing will be under the basis of “Personal Consent”, “Contractual Obligation” or “Legitimate Business Interest” dependant on the consent requested or service for which we you have requested that we are holding your data for. In simpler words we need and use your personal information for providing the services you have requested or have contracted us with.
However, when we are communicating with you regarding products and services you may be interested in receiving from us or our clients in the future, our basis for processing is our legitimate interest. As we are communicating with you in the context of your motoring product needs and not in relation to your private life. We believe this to be reasonable and fair behaviour in the context of our audience. Of course, you will always have the opportunity to object as detailed below.
Is your data used for any automated decision making?
We do not process personal data for the purpose of automated decision making
Will your information be transferred outside the European Union?
From time to time our suppliers may store and process your data in the United States.
When this occurs, your personal data is safeguarded by our policy of using suppliers who hold a current Privacy Shield Certification for their US- based operations.
Data Security
We employ a number of organisational and technical measures to protect the personal data that we hold. We have physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personally identifiable customer information.
Our security procedures mean, that occasionally we may request proof of identity before we disclose any personal information to you. We review and amend these practices regularly to ensure we meet our data protection obligations.
Asking us to suppress or remove your personal information
Should you wish to not receive information from us in future then you can quickly action this by clicking the unsubscribe link you will find on our marketing e-mails or by sending your details to privacy@directgap.co.uk and we will quickly suppress your data.
Should you further wish for us to remove your information entirely (and assuming we have no other obligation to keep it) then please let us know and we will do this – but we would encourage you to let us use it for suppression purposes only.
Alternatively, you can write to us at:
Data Protection Officer
Motor Gap Ltd,
Hawkstone House,
Valley Rd,
Hebden Bridge
HX7 7BL
What to do if you have a complaint
Motor Gap Ltd tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints very seriously. We encourage you to give any feedback on how we might improve our processes and procedures and will immediately review matters that you may consider to be misleading, unfair or inappropriate.
If you have a complaint, please contact our Data Protection Officer at privacy@directgap.co.uk who will deal with your request promptly.
Or write to the data protection officer at the address above.
Please address your correspondence to James Cartwright who is the company data protection officer.
If you are still not satisfied with the way your complaint was handled, you can refer your complaint to UK Information Commissioner’s Office. https://ico.org.uk/concerns/
Or write to : ICO, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
Motor Gap Ltd are registered with the information Commissioner’s Office, ICO Registration Number: Z2254221
* Our privacy policy which describes our services and the details of our processes and suppliers may be changed without notice, and consequently the details may change at any time in the future. You should visit this page regularly to check for changes.