WHO WE ARE
This policy is for and on behalf of Triumph Motorcycles Limited (Company Registration Number 01735844), in the UK, whose registered office is at Ashby Road, Measham, Swadlincote, Derbyshire, DE12 7JP, and its Affiliates (together known as the ‘Triumph Group’).
For the purpose of this policy; (a) “Affiliate” shall mean any entity that directly Controls, is Controlled by, or is under common Control with Triumph Motorcycles Limited, and (b) “Control” shall mean the beneficial ownership of more than 50% of the issued share capital of a company or the legal power to direct or cause the direction of the management of the company, and “Controls” and “Controlled” shall be interpreted accordingly.
All references in this policy to Triumph, Triumph Motorcycles, Triumph Motorcycles Limited, “we”, “us” or “our” and/or to the company (as relevant) shall include Triumph Motorcycles Limited and its Affiliates (as defined above), as relevant.
Postal Address: Legal and Compliance Team, Triumph Motorcycles Limited, Normandy Way, Hinckley, Leicestershire, LE10 3BZ, United Kingdom
Email Address: TriumphDataProtection@Triumph.co.uk
THE DATA WE COLLECT ABOUT YOU
Personal Data, or personal information means any information about an individual from which that person can be identified. It does not include data where the identity was removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we grouped together as follows:
- Identity Data: First name, maiden name, last name, username or similar identifier, date of birth and gender.
- Contact Data: Billing address, mailing address, email address and telephone numbers.
- Financial Data: Bank account and payment card details.
- Transaction Data: details about payments to and from you and other details of products and services you purchased from us.
- Technical Data: Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile Data: username, purchases or orders made by you, your interests, preferences, number of years riding, vehicle identification details (including VIN number), information about your motorcycle such as VIN number, motorcycle make and model, fuel consumption, engine details, range to empty, mileage and next service date, feedback and survey responses.
- Usage Data: information about how you use our website, products and services.
- Marketing and Communications Data: your preferences in receiving marketing from us and our third parties and your communication preferences.
- Public sources of data: information to support website functionality, ensure owner information is accurate with DVLA and to support authentication and/or fraud checks.
- Location data: information about your current location, your planned, saved and undertaken journeys including map of the journey, time taken, miles covered.
As a customer of Triumph we will not collect any special categories of information about you without your prior explicit consent (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.
HOW WE RECEIVE THIS INFORMATION
We use different methods to collect data from and about you including through:
Direct Interactions with Triumph: You may give us your identity, contact and financial data by filling in forms online, by mail, on the phone, by registering to use our apps or at our events or factory visitor experience. This includes personal information you provide to us when you:
- apply for our products or services;
- purchase products from us using our online services;
- otherwise contract with us;
- subscribe to our services or publications;
- register an account with us;
- request marketing material to be sent to you;
- enter a competition, promotion or survey;
- attend one of our events and/or conferences;
- share data with us via our websites’ or Apps’ social media functions;
- make a request, inquiry or complaint; and
- provide us with feedback or contact us.
Certain services available on our Apps, including map services, will make use of Location Data sent from your devices. You can turn off this functionality at any time by turning off the location services settings for our Apps on your device. If you use these services, we will process your Location Data for the purposes of providing those services to you and for the purposes of improving our location-based and road traffic-based products and services, including our mapping services. You may stop us collecting such data at any time by turning off the location services settings on your device.
Where you use any of our Apps to connect your mobile device to a motorcycle, via Bluetooth connectivity or otherwise, we may collect Profile Data about you and your motorcycle.
Automated Technologies or Interactions: As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns.
Each time you visit one of our websites or use our App we will automatically collect personal data about your device (including the type or device, type of browser, operating system), information stored on your device and details of your use of our websites or Apps.
Other Third Parties or Publicly Available Sources: We may receive personal data about you from various third parties and public sources as set out below:
- vehicle and identity related data from independent third party sources such as the DVLA in the United Kingdom;
- advertising networks;
- analytics providers (such as Google, based outside the EU);
- device data in order to carry out actions such as adapt screen size to your device;
- credit referencing agencies; and
- search information providers.
Consumer Generated Sources: Any content that you create and then share with us on third party social networks or by uploading it to one of our websites or Apps, including the use of third party social network apps such as Facebook. Examples include photos, videos, personal stories, or other similar media or content.
Third Party Social Network Information. Any information that you share publicly on a third party social network or information that is part of your profile on a third party social network (such as Facebook) and that you allow the third party social network to share with us. Examples include your basic account information (e.g. name, email address, gender, birthday, current city, profile picture, user ID, list of friends, etc.) and any other additional information or activities that you permit the third party social network to share.
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 such as where you are buying goods and 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.
HOW WE USE YOUR PERSONAL DATA
Under applicable data protection law, we can only use your personal information if we have a proper reason for doing so (a legal basis for processing). Most commonly, Triumph will use your data in the following circumstances:
- where we need to perform the contract we are about to enter into or entered into with you;
where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
- Where we need to comply with a legal obligation; and
- where you have provided your consent.
For the purposes of clarity a legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely upon to do so. We also identified what our legitimate interests are where appropriate.
Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need more details about the specific legal ground we are relying upon to process your personal data.
▀ The table below does not apply to special category data which we will only process with your explicit consent.
Type of data
Lawful Basis for Processing including basis of Legitimate Interest
To Provide you with Products you Purchase
Where you purchase products or services directly from us, including using our online services, such as our website or App, we will process your personal data in order to provide you with those products and services, including for example, to process payment and to deliver those products or services to you.
We may send you marketing communications either by email, SMS, phone or mail.
We may also share your details for electronic marketing communications with our network of independent third parties, where you give consent for this to happen.
We will also ensure we comply with applicable data protection regulation in respect of cookies for marketing use.
Where you are an existing customer, Legitimate Interests for direct marketing purposes (to develop and grow our business).
Market Research and Analytics
It is possible we may contact you to identify if you are the current owner of a motorcycle and ask if you wish to participate in market research from time to time. In this instance and for the purposes of contacting you we would seek to rely on our legitimate interests and this is completely your decision if you wish to participate.
We will use profiling including segmentation tools and carry out research and analytics to assist and develop our marketing strategies, to understand our customers better, to support a more user friendly website and to better improve the customer experience across all business areas.
Legitimate Interests analytics and market research purposes (such as understanding how our customers use our products and how we can develop them and grow our business and ensuring that our marketing is targeted and relevant).
Maintaining and Supporting your Website/ App Use
Where you use our website and/or Apps either at home or at events we and our approved third parties may process your data to support these services.
We may also use your personal data to manage our relationship with you, including to notify you of changes or updates to our online services.
We also may want to improve our services to strengthen our internal processes and your experience as a customer.
Legitimate Interests in ensuring our websites and apps are effective and in developing the customer experiences in relation to the use of our website.
Personalization (Offline and Online).
We may use your Personal Data including for the purposes of profiling (i) to analyze your preferences and habits, (ii) to anticipate your needs based on our analysis of your profile, (iii) to improve and personalize your experience on our Websites and Apps; (iv) to ensure that content from our Websites and Apps is optimized for you and for your computer or device; (v) to provide you with targeted advertising and content (including via social media), (vi) to allow you to participate in interactive features, when you choose to do so; and (vii) to personalize our content so that it is relevant for you.
Based on this type of information, we also show you specific Triumph content or promotions that are tailored to your interests.
Legitimate Interests in working out which of our products and services may be of interest to you and telling you about them and for the purposes of identifying types of consumers for new products or services.
We use your Personal Data when you interact with third party social networking features, such as “Like” functions, to serve you with advertisements and engage with you on third party social networks. You can learn more about how these features work, the profile data that we obtain about you, and find out how to opt out by reviewing the privacy notices of the relevant third party social networks.
Legitimate Interests in working out which of our products and services may be of interest to you and telling you about them and for the purposes of identifying types of consumers for new products or services.
Your Motorcycle Purchase
Where you purchase a motorcycle from Triumph or one of our dealers (as part of our dealer network) we will use your information to update our internal databases for information relating a motorcycle VIN number.
In doing so, we are able to provide you with up-to-date information relating to your motorcycle where we may share details with third parties to provide you with exclusive offers such as additional insurance policies and extended warranty.
Legitimate interests in ensuring our customers receive the best offers relating to their motorcycle purchase including extended warranties where current warranty has expired.
Warranty, Claims and Recalls
When you make a warranty claim from Triumph we will be required to process your personal information in order to log the claim and ensure your issues are rectified.
We are legally obliged to process your information to ensure where a product safety recall is required we are able to contact the registered owner of a motorcycle and effectively communicate this service.
Legitimate Interests to ensure warranty claims are administered and actioned in appropriate time and that customers are updated regularly with regard to the stage of their claim.
Magazine Articles, Social Media Posts
When you attend one of our events or the factory visitor experience center, on occasion we may take pictures and/or recordings which we may publish online via social media and/or magazine articles.
This data may be captured for a specific purpose in which case we will ask for your consent however normally it may be just part of recording an event to further the Triumph brand and inform customers and other individuals interested in the Triumph brand about our events, developments and activity.
Legitimate Interests to inform the public about our events and the general public about activity at Triumph in order to promote the Triumph brand and showcase development.
Using Our Online Services
Where you request a service from us such as the mapping and GPS services available on our apps, we may use your personal data in order to provide that service to you.
We may allow you to register an account with us.
We may also allow you to connect our Apps to other products such as a Triumph Motorcycle or accessory.
Legitimate interests in order to provide you with a relevant service, personal to you.
When you fill out forms for the purposes of a request for example, where you request a brochure, further information or a test ride, we process your personal data in order to manage such request and ensure it is actioned accordingly.
Legitimate Interests in ensuring the customer’s request is actioned accordingly.
Legal and Regulatory Obligations
Where we need to manage legal and regulatory requests such as the prevention/ detection of crime and liaising with regulatory bodies and/or law enforcement agencies such as the Police, HMRC, DVLA, etc. we have a legal obligation to process and/or transfer your personal data.
Network and Information Security
We may process data in order to maintain our network and security. In doing we take steps against loss, damage and theft, both electronically and physically. We may also engage with third parties who may remotely store information for the purposes of maintaining appropriate server locations globally.
Legitimate Interests as appropriate for ensuring network and information security.
WHO WE SHARE YOUR PERSONAL INFORMATION WITH
We may routinely share your personal information with the following for the purposes set out in the table above:
- third parties who we use to help provide and deliver our products and/or services for example, to offer finance, insurance, road side assistance, payment services providers, extended warranties, website services, etc.;
- marketing and research agencies who carry out work based on our express instructions such as a specific marketing campaign and/or market research surveys;
- event companies who run and manage sponsored events;
- IT providers who provide us systems and services for customer support;
- Card Payment Services providers who operate payment platforms;
- logistics and courier companies who transport our products to you;
- website and mobile application development companies, for the purposes of providing (including developing and building), supporting and managing our websites and our App;
- third party marketing companies, including email service providers;
- IT hosting companies, including cloud hosting companies, who host our systems, database, website and our App;
- service providers, who provide our online services, such as Google, who provides the map tool on our App*; and
- other third parties we may appoint from time to time in order for the purposes of internal business administration only for the purposes set out in the table above.
We require all of our third party processors to respect the security of your personal data and both treat and process it in accordance with the law. In doing so, we will only allow third parties to process your personal data as data processors on our behalf where we are satisfied they take appropriate measures to protect your information.
Additionally, we impose contractual obligations (such as a data processing agreement) on our third party processors to ensure they process and secure your data lawfully with the appropriate technical and organizational measures in place.
We may also share your personal data with:
- law firms who may provide legal advice to us (e.g. where there is a customer dispute)
- Tax authorities (such as HMRC in the UK) and customs authorities.
Our website links to third party payment providers who will process payments made on our website.
INTERNATIONAL TRANSFERS OF INFORMATION
It may be necessary on certain occasions to share your personal information outside of the European Economic Area (“EEA”) such as:
- with our subsidiary offices located outside the EEA;
- with distributors or dealers located outside the EEA;
- with service providers located outside the EEA;
- if you are based outside the EEA; and
- where there is an international dimension to the services we are providing to you.
Whenever we do transfer your personal data outside of the EEA, we ensure a degree of protection (as stipulated by law) is afforded to it by ensuring at least one of the following is implemented:
- we will only transfer your personal data to countries who by the European Commission are deemed to provide an adequate level of protection for your personal data;
- where we use certain service providers located outside the EEA, we may use specific contractual clauses approved by the European Commission which give personal data the same protection it has in Europe;
- where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield Framework which requires them to provide adequate protection to data transferred between Europe and the US; and
- we may rely on one of the derogations for specific situations as set out in Article 49 GDPR.
If you would like further information about data transferred outside the EEA, please contact the Triumph Legal and Compliance team using the details at the beginning of this notice.
WHAT WE DO TO KEEP YOUR DATA SECURE
We have appropriate security measures in place to prevent your personal data from being accidentally lost, used or accessed in an unauthorized 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.
Unfortunately, the transmission of information via the internet is not always completely secure despite our reasonable efforts. While we will reasonably protect your personal data, we do not guarantee the security of your data transmitted over the internet; any such transmission, including via our websites or Apps, is at your own risk and when we receive your information it will be kept in a secure environment protected by a combination of physical and technical measures such as encryption technologies or authentication systems to prevent any loss, misuse, alteration, disclosure, destruction, theft or unauthorized access.
We have in place procedures to deal with any suspected personal data breach and will notify you accordingly as well as notifying any applicable regulator where we are legally required to do so.
HOW LONG DO WE USE AND KEEP YOUR PERSONAL DATA
We will only retain your personal information 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 compliant or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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 unauthorized 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.
Under certain circumstances, you have rights under the data protection laws in connection with your personal data. These are the following:
- right of access to your personal data;
- right to request correction of your personal data;
- right of erasure of your personal data;
- right to object to the processing of your personal data;
- right to request the restriction of processing of your personal data; and
- right to request transfer of your personal data (data portability).
If you wish to exercise any of the rights above please email TriumphDataProtection@triumph.co.uk or write to us at Legal and Compliance Team, Triumph Motorcycles Limited, Normandy Way, Hinckley, Leicestershire, LE10 3BZ, United Kingdom.
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.
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) is actioned accordingly. 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.
We try to respond to all legitimate requests within one calendar month. Occasionally, it could take us longer than a month if your request is particularly complex or you make a number of requests. In this case, we will notify you and keep you updated.
In the event you wish to restrict the processing of your personal data for the purposes of (where applicable) email newsletters, service emails and/or general marketing you may use the ‘unsubscribe option’ at the bottom of any of our marketing communications to you. It may take seven (7) working days for your unsubscribe request to be fulfilled.
HOW TO COMPLAIN
If you are not happy and have a data protection related complaint, please contact us directly by emailing TriumphDataProtection@triumph.co.uk or by writing to us at Legal and Compliance Team, Triumph Motorcycles Limited, Normandy Way, Hinckley, Leicestershire, LE10 3BZ, United Kingdom.
If you remain unsatisfied with our response you have the right to lodge a complaint with a supervisory authority, in particular in the European Union state where you work, normally live or where any alleged infringement of applicable data protection law occurred. The supervisory authority in the UK is the Information Commissioners Office who may be contacted at https://ico.org.uk/concerns/ or by telephone on +44 0303 123 1113.
LINKS TO OTHER WEBSITES
Our website or Apps may contain links to other websites or apps run by other organizations which we do not control. This policy does not apply to those other websites or apps and therefore we encourage you to read their privacy policies prior to using their services.