Privacy Policy
PRIVACY
POLICY
BTC
Solutions Limited trading as autoVHC is part of the Snap-on Incorporated group
of companies (Snap-on Group), which processes your information. BTC Solutions
is referred to as we in this privacy policy.
The protection of your personal information is an important
concern to which we pay special attention.
This
privacy policy answers frequently asked questions about the kinds of personal information
we collect from you and how it is used.
Please
note, the privacy practices set forth in this privacy policy are for BTC
solutions and autoVHC only. Other
companies within the Snap-on Group may have websites and products that collect
and use different personal information. Additionally, if you link to or
otherwise visit any other websites, please review the privacy policies posted
on those sites.
Should you have any questions or concerns
regarding this privacy policy, please contact the data protection manager at: DataProtectionManager@snapon.com.
1.
What
types of personal information do we gather?
We
may collect and process, and have collected and processed in the last 12
months, a range of personal information including:
·
Identifiers: Such as a
real name, alias, postal address, telephone number, online identifier, internet
protocol address, email address, account name, social security or National
Insurance number, drivers license number, passport number, other state or
national identification number(s), your signature, physical characteristics or
description, insurance policy number or other similar unique personal identifiers.
·
Commercial Information: Such as transaction and purchase information and history.
·
Financial
Information:
Such as your bank account number, credit card number,
debit card number or any other financial information.
·
Technical and
Usage Information: Such as login data, browser type and version, time zone setting
and location, browser plug-in types and versions, operating system and
platform, and information on other technology on the devices using our websites
or products; information about how you use our website, products and services,
such as browsing history, search history, or other information on interactions
with our websites, applications, products and services. For detailed
information on the tracking technologies we us on this website, see Link to Cookie Section
·
Sensory
information:
Such as audio, electronic, visual and similar information, such as call and
video recordings.
·
We do not intend to collect personal information of Children: We do not knowingly collect personal information from children under
16. Our website is not intended for
children under 16 years of age. If you are under 16, do not use or provide any
information on this website or through any of its features. If you believe we
might have any information from or about a child under 16, please contact us at
DataProtectionManager@snapon.com.
2.
What
are the sources of personal information we have gathered?
We collect personal information from a variety of sources,
including:
·
From
You. You
may directly give us personal information when you:
o
Apply for, purchase, register or
use our products and services;
o
Receive customer support;
o
Create an account on our website;
o
Subscribe to our publications;
o
Request marketing be sent to you;
o
Enter a competition, promotion or
survey;
o
Correspond with us in person at
trade shows, events, or otherwise;
o
Interact with us as a potential or
existing franchisee or as an employee of a franchisee;
o
Make a claim under a franchisee insurance
policy for which we provide claims administration services;
o
Give us feedback or provide us
other information when you contact us; or
·
From
your customer: This is
information about your customers or clients that you give to us by using the
autoVHC service, filling in forms on the site, or corresponding with us by
phone, email, in person or at trade shows or events or otherwise. This
primarily includes information you provide when you use the autoVHC service.
The information you give to us about your customers or clients includes for
example: name, address, telephone number, purchase information, email address,
VIN number, make and model of car, and registration or index number.
·
From
automated technologies or interactions. As
you interact with our website or application, we will automatically collect Technical
and Usage Information (more fully described in the What types of personal
information do we gather? Section.) We
collect this data by using cookies, server logs and other similar
technologies. For detailed information on the technologies we us on
this website, see Link to Cookie Section
·
From
third parties or publicly available sources.
We will receive personal information from various third parties that
confirmed they are authorized to share it with us or other public sources, such
as:
o
Consumer reporting agencies,
credit reference agencies and publicly available databases;
o
Auto repair shops and auto dealers
who use our products or services;
o
Our franchisees;
o
Insurance companies and brokers;
o
Other Snap-on Group companies that
you may interact with through other websites, products, services, or social
media pages;
o
Search information providers; or
o
Internet service providers
o
Data Analytics Providers
o
Operating systems and platforms
o
Social networks
o
We may also receive information
about you from an OEM you are doing business with when an OEM provides us
information about you, we ask the OEM to confirm that the information was
legally acquired by them, and that we have the right to obtain it from them and
use it.
3.
How is that personal information used by us?
We
may use your personal information in the following ways:
o
Register you as a new customer;
o
Process and deliver your order, manage
your subscriptions, or carry out our obligations arising from any other contracts
you enter into with us;
o
Manage payments, fees and charges
and collect and recover money owed to us;
o
Managing our relationship with you
by sending you renewal notices, notifying you of product or service
information, asking you to leave a review or take a survey, or enabling you to
partake in a prize draw or competition;
o
Fulfil your requests, answer your
questions, respond to your comments, and measure how effectively we address
your concerns;
o
Analyse and develop new products
and services, or make suggestions and recommendations to you about goods and
services that may be of interest to you;
o
Provide customer support; or
o
Fulfil any legal obligations we
may have.
·
Monitoring
& Recording: to handle any calls, chats or other interactions with us,
including by the customer services team. Please be aware that it is our general practice to monitor and in some
cases record such interactions for staff training or quality assurance purposes
or to retain evidence of a particular transaction or interaction.
·
Protecting
our Rights and Property: to protect our rights or property or that of our business partners,
franchisees, dealers, suppliers, customers or others when we have reasonable grounds to believe that such rights or property have
been or could be affected; to recover debts; to prevent, detect, identify,
investigate, respond, and protect against potential or actual claims,
liabilities and prohibited behaviour or activities.
·
Information
for our Business Partners, Dealers and Franchisees: to administer
and develop our business relationship with you, the business partner, dealer or
franchisee you represent, including sharing information with our group, to
enter into or perform a transaction with you, to contact you as part of
satisfaction surveys or for market research purposes.
·
Marketing: to communicate about, and administer
participation in, special events, programs, surveys, contests, sweepstakes, and
other offers and promotions; to provide you with information about other goods
and services we offer, or offered by others, that are similar to those that you
have already purchased or enquired about and to send informational or promotional
email messages to you, which you may opt out of receiving as described below.
4.
On
what legal basis do we gather and use personal information of EU/EEA residents?
We gather and use your personal information for either (i) the
performance of a contract to which you are party or in order to take steps at
your request prior to entering into a contract, and/or (ii) for direct
marketing purposes, and/or (iii) our legitimate interests and in compliance
with your fundamental rights and freedoms and/or (iv) because of a legal
obligation, and/or (v) to protect your vital interests.
By visiting our website and/or providing your personal information
in order to use our product or services you are accepting and consenting to the
practices described in this policy.
5.
Is my personal information disclosed
to third parties?
We may
disclose Personal Information with the following categories of third parties:
·
Affiliates. We share with
our affiliates for the purposes described in this Privacy Policy.
·
Service Providers. We share
with our trusted third-party service providers, to facilitate services they
provide to us, such as internet services, website hosting, data analytics,
payment processing, order fulfilment, information technology and related
infrastructure provision, customer service, email delivery, marketing,
auditing, background checks, and other services.
·
Social Networks We share with social network platforms,
who use the data we share in accordance with their own privacy policies.
·
Business Partners. We share with our trusted business partners.
·
Franchisees. We share
information with our Franchisees.
·
Marketing Partners. We share with our marketing partners to
permit them to send you marketing communications, consistent with your choices.
·
Credit
Bureaus We share
information about your credit history with us with credit bureaus.
·
Legal Authorities. We share
with public and government authorities, including regulators and law
enforcement, to respond to requests, as well as to protect and defend legal
rights.
·
Other Parties in Litigation
We share information in the context of litigation discovery and in response to
subpoenas and court orders.
In the
preceding 12 months, we disclosed for our operational business purposes the
following categories of Personal
Information to the
following categories of third parties:
|
Categories
of Personal Information |
Disclosed
to Which Categories of Third Parties for Operational Business Purposes |
|
Identifiers |
None |
|
Commercial Information |
None |
|
Financial Information |
None |
|
Technical and Usage Information |
None |
|
Educational Information |
None |
|
Professional/Employment Related Information |
None |
|
Sensory Information |
None |
|
Geolocation Information |
None |
|
Inference Information |
None |
|
Protected Class Information |
None |
6.
How long will my personal information
be kept for?
We will
endeavour not to keep your personal information in
a form that allows you to be identified for any longer than is reasonably
necessary for achieving the permitted purposes. This means that information will
be destroyed or erased from our systems or anonymized when it has reached the
applicable retention period.
7.
Will my personal information be
transferred to other countries?
We are a global company and we may process, store and transfer
personal information we collect to a country outside your own, provided that
certain conditions as set out in the applicable legislation are complied with.
We are party to an information transfer agreement with the members
of the Snap-on Group and we will keep that document up to date with current law.
For more information on the safeguards in place, please contact DataProtectionManager@snapon.com.
8.
What security measures are in
place to protect my personal information?
We endeavour to protect the security of your personal information.
We will seek to maintain administrative, technical and physical safeguards to
protect against loss, misuse or unauthorized access, disclosure, alteration or
destruction of your personal information.
Unfortunately, the transmission of information via the internet is
not completely secure. Although we endeavour to protect your personal information,
we cannot guarantee the security of your personal information transmitted to us
or stored on our systems; any transmission is at your own risk. Once we have
received your personal information, we will use procedures and security
features to try to prevent unauthorised access. These procedures include
physical, electronic, and managerial procedures.
9.
How
do I update or access my personal information?
We
ask that you keep your information as up-to-date as possible so you may get the
maximum benefit from us.
If you have an account with us then you can
access and correct personal data that we keep in your online account by going
to the Login page and entering your user id and password. For other questions
related to updating or changing your account information or if any errors in
your personal data cannot be corrected by accessing your information via the
Login page, please contact support@autovhc.com
10.
What
specific rights do I have in relation to my personal information based on my
residency?
·
European Union and European Economic Area Residents. Depending on the circumstances, the General Data Protection
Regulation GDPR may provide you the right to:
o
request access to any personal information
we hold about you;
o
object to the processing of your information
for direct-marketing purposes;
o
ask to have inaccurate information held
about you amended or updated;
o
ask to have your information erased or to
restrict processing in certain limited situations;
o
request the porting of your personal information
to another organization in control of your personal information; and/or
o
object to any decision that significantly
affects you being taken solely by a computer or other automated process.
If you are
a resident of the European Union or European Economic Area that wishes to make
a formal request for information we hold about you, you can contact us, at <support@autovhc.com>. We will respond to your request consistent with the
GDPR.
·
California Residents: The California Consumer Privacy Act (CCPA) provides California
residents specific rights regarding their personal information. You have the
right to be free from unlawful discrimination for exercising your rights under
the CCPA. This section describes your CCPA rights and explains how to exercise
those rights.
o
Access to Specific Information and Data Portability: You have the right to request that we disclose
certain information to you about our collection and use of your personal information
over the past 12 months, including the following:
§ The categories of personal information we collected
about you.
§ The categories of sources for the personal information
we collected about you.
§ Our business or commercial purpose for collecting that
personal information.
§ The categories of Personal Information about you that
we shared or disclosed, and, for each, the categories of third parties with
whom we shared or to whom we disclosed such Personal Information.
§ The specific pieces of personal information we
collected about you (also called a data portability request).
o
Deletion Request Rights: You have the
right to request that we delete any of your personal information that we
collected from you and retained, subject to certain exceptions. Once we receive
and confirm your verifiable consumer request we will delete (and direct our service
providers to delete) your personal information from our records, unless an
exception applies. We do not provide
these deletion rights for B2B personal information. We may deny your deletion
request if retaining the information is necessary for us or our service
provider(s) to:
§ Complete the transaction for which we collected the
personal information, provide a good or service that you requested, take
actions reasonably anticipated within the context of our ongoing business
relationship with you, fulfill the terms of a written warranty or product
recall conducted in accordance with federal law, or otherwise perform our
contract with you.
§ Detect security incidents, protect against malicious,
deceptive, fraudulent, or illegal activity, or prosecute those responsible for
such activities.
§ Debug products to identify and repair errors that
impair existing intended functionality.
§ Exercise free speech, ensure the right of another
consumer to exercise their free speech rights, or exercise another right
provided for by law.
§ Comply with the California Electronic Communications
Privacy Act (Cal. Penal Code § 1546 et. seq.).
§ Engage in public or peer-reviewed scientific,
historical, or statistical research in the public interest that adheres to all
other applicable ethics and privacy laws, when the informations deletion may
likely render impossible or seriously impair the researchs achievement, if you
previously provided informed consent.
§ Enable solely internal uses that are reasonably
aligned with consumer expectations based on your relationship with us.
§ Comply with a legal obligation.
§ Make other internal and lawful uses of that
information that are compatible with the context in which you provided it.
o
Exercising Access, Data Portability, and Deletion
Rights.
§ To exercise the rights described above, please submit
a verifiable consumer request to us by either:
·
Contacting our data protection
manager at DataProtectionManager@snapon.com.
§ We will verify and respond to your Request
to Know or Request to Delete consistent with applicable law, taking into
account the type and sensitivity of the Personal Information subject to the
request. We may need to request
additional Personal Information from you, such as [your name, email address,
and vehicle details, in order to verify your identity and protect against
fraudulent requests. If you maintain a
password-protected account with us, we may verify your identity through our
existing authentication practices for your account and require you to
re-authenticate yourself before disclosing or deleting your Personal
Information. If you make a Request to
Delete, we may ask you to confirm your request before we delete your Personal
Information.
§ If you are the authorized agent of a
consumer, making a Request to Know or a Request to Delete on behalf of the
consumer, we will ask you for:
·
proof
of your registration with the California Secretary of State to conduct business
in California; and
·
proof that the consumer has authorized you to
make a Request to Know or a Request to Delete on the consumers behalf. This must be a permission signed by the
consumer. Signed means that the permission has either been physically signed
or provided electronically in accordance with the Uniform Electronic
Transactions Act, Civil Code 1633.7 et
seq.
§ If an authorized agent has not provided
us with a power of attorney from the consumer pursuant to Probate Code sections
4000-4465, we may also:
·
require
the consumer to provide you with a written permission signed by the consumer to
make the request on the consumers behalf,
·
verify
the identity of the consumer as we would if the consumer were making the
request personally, and
·
obtain
verification from the consumer that they provided the authorized agent
permission to make the request.
o
Other notices for California residents:
§ California Do Not Track Disclosure. We do not track our customers over time and
across third party websites to provide targeted advertising and therefore
generally do not respond to Do Not Track (DNT) signals.
§ Pursuant
the CCPA, California residents have the right to opt-out of the sale of their
personal information.
§ WE HAVE
NOT SOLD PERSONAL INFORMATION FOR PURPOSES OF THE CCPA.
§ If you are a resident of California, under 18, and a
registered user of our websites, you may ask us to remove content or
information that you have posted by writing to our Data Protection Manager at DataProtectionManager@snapon.com. Please note that your request does not ensure
complete or comprehensive removal of the content or information, as, for
example, some of your content may have been reposted by another user.
·
Nevada Residents: Nevada residents may request that website operators not sell consumers
Covered Information as defined by Nevada law. WE HAVE NOT SOLD COVERED INFORMATION FOR PURPOSES OF NEVADA LAW. If you are a Nevada resident that would like
to make a further inquiry regarding the selling your Covered Information,
please contact DataProtectionManager@snapon.com.
11.
How
do I opt out of being contacted for promotional purposes?
You have the right to ask us not to send you marketing communications.
We will usually inform you (before collecting the personal information) if we
intend to use your personal information for such purposes or if we intend to
disclose your information to any third party for such purposes. You can
exercise your right to prevent such processing by checking certain boxes on the
forms we use to collect personal information. You can also exercise the right to
prevent such processing at any time by:
12.
How
do we use cookies?
·
What
are cookies: Cookies are small text files that
are placed on your computer by websites that you visit, and are widely used to
make websites work, or work more efficiently.
·
How
do I change my cookie settings:
o
Most browsers automatically accept
cookies. However, you can prevent cookies from being stored on your computer or
device by setting your browser to not accept cookies. The exact instructions
for this can be found in the manual for your browser. You can delete cookies
already on your computer or device at any time. If you choose to set your
browser settings so cookies are not accepted, then you can still visit our
website, apps and online services, however doing so may affect your use of some
parts of our web services, apps and online services and reduce availability of
the services provided by our website, apps and online services.
o
To opt out of being tracked by
Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.
·
How
does this website use cookies: The table below explains the
cookies we use and why.
|
Cookie Type |
Cookie
Purpose |
Retention
Period |
|
|
_ga |
Statistical |
Registers a unique ID that is used to
generate statistical data on how visitors use the website |
2 years |
|
_gat |
Statistical |
Used by Google Analytics |
1 day |
|
_gid |
Statistical |
Registers a unique ID that is used to
generate statistical data on how visitors use the website |
1 day |
|
NID |
Marketing |
Registers a unique ID that identifies
users device |
6 months |
|
r/collect |
Marketing |
Used by Google Analytics to track a
users device |
Session |
|
Vuid |
Marketing |
Collects data on users interactions
with Vimeo content on the site |
2 years |
Except for essential cookies, all cookies will expire as shown
above.
13.
Who
should I contact with concerns or questions about this Privacy Policy or applicable
data protection legislation?
If you have concerns or questions about
this Privacy Policy or you believe that the applicable
data protection legislation or this policy has not been followed,
then you should raise the matter with our Data Protection Manager at DataProtectionManager@snapon.com.
If you are a citizen of the European Union
or European Economic Area, you may make a complaint at any time to the
applicable supervisory authority for data protection issues. We have appointed a data protection manager
who is responsible for addressing any reported data protection issues related
to GDPR, and we would like the opportunity to respond to your concerns before
you approach a supervisory authority so please feel free to contact the data
protection manager at DataProtectionManager@snapon.com.
14.
Modifications
to this Privacy Statement
We
reserve the right to modify this Privacy Policy at any time and without prior
notice, subject to applicable legal requirements to notify you or obtain your
consent. We will post any changes on our website so please check regularly for
the most recent version of our Privacy Policy. This version is dated August
2020.
15.
Links
This
site contains links to other sites. Please be aware that we are not responsible
for the content or privacy practices of those sites, and our Privacy Policy
does not apply to information collected from you by those sites. We encourage
you to read the privacy statements of each site that collects information from
you. When you are leaving our site via a link to interact with a site that is
not governed by our Privacy Policy, a new browser window will open. If your
interaction with our site will require sending your information to a
third-party site that is not governed by our privacy policy, We will clearly
inform you before your information is sent.