Policy date: 03/02/2023
Information about ETB Group – Exhausts Tyres Batteries (Worcester Ltd)
Who We Are
What is Personal Data?
Personal data is information that directly or indirectly identifies you as an individual, indirectly meaning when combined with other information, for example, your name, username, postal address, email address and phone number, a unique device identifier such as the IMEI or the MAC-address or the IP address.
How and why do we collect personal data?
a) Information that you give us
Through your use of the services, we may collect your personal data. In any case, you will be either asked to explicitly consent to collection and further processing of your personal data or be informed that such processing is based on another lawful basis. We will use your personal data for the purposes as described below or described when we are seeking your consent. We do not collect and process more or other types of personal data than necessary to fulfil the respective purposes. We will only use personal data as set forth in this Policy unless you have specifically provided your consent to another use of your personal data. If we intend to use your personal data for purposes other than which we originally collected them for, we will inform you in advance and, in cases where the processing is based on your consent, use your personal data for a different purpose only with your permission.
Where we rely on your consent to process your personal data, you will have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
Each registration form will indicate what kind of personal data we collect - various purposes may require collection of various personal data, for instance:
b) Information we get from your use of our services.
We are constantly seeking to improve your experience when you visit our websites or when you are interacting with us through other means.
Through your interaction with us and your use of the services, we may collect personal data. Personal data we collect may include but is not limited to:
Your activity on our website and mobile apps. This is data about your browsing activity (the pages you visited and the time of your visit, the preferred language, what items were clicked on a page, how much time you spent on a page, what items you place in your shopping basket in our webstore, what products and services you purchased, and how much was paid).
Device and browser information. This is technical data about the device or browser you use to access our website (e. g. IP address, HTTP headers and other internet transfer protocol signals, user-agent strings, device type, screen resolution, device geolocation, operating system version and device identifiers, such as Apple IDFA or Android Advertising ID).
Cookies, web beacons and similar technologies. Cookies are small, usually randomly encoded, text files placed on your computer or device that help your browser navigate through our website. Web beacons are tiny images or objects embedded in a web page or email and are usually invisible to you but allow us to verify whether you have viewed the web page. Web beacons generally function in combination with cookies, and we may use the two in the same manner. Please also refer to our Cookies Policy below for full details regarding cookies and web beacons used at our website, including their management, specific purposes, categories of data they help to store and periods they are active for.
What do we do with your personal data?
Depending on your use of the services, we may, for instance, collect and use your personal data for the purposes listed below (“the Purposes”) and we have identified the lawful basis relied upon to perform such processing:
• Registering you as a user of the services and providing you with the contracted services in the performance of a contract with you.
• Complying with laws and regulations.
• Pursuing our legitimate business interests.
• Communicating and responding to your requests and inquiries to us for the performance of a contract with you and necessary for our legitimate interests.
• Delivering functionality on our website and for its technical and functional management. This is necessary for our legitimate interests (to enable us to administer our business, and for the provision of administration and IT services).;
• Ensuring that the services’ content is presented to you in the most effective manner for you and your device. This is necessary for our legitimate interests (to develop our products/services and grow our business);
• Engaging in transactions with customers, suppliers, and business partners and to process orders for our products and services. This is necessary for the performance of our contract with you and necessary for our legitimate interests to ensure the continued running of our business.
• Processing and handling complaints or requests for our legitimate interests (to ensure we provide satisfactory services to customers);
• Researching and analysing the market as well as customers’ use of our products and services (e.g. sensor-based analytics of tyre and vehicle data; asking your opinion on our products and services or by asking you to complete a survey or questionnaire). This is necessary for our legitimate interests (to enable us to study how customers use our products and Services, to develop them and to grow our business.
• Helping us in evaluating, correcting, and improving our products and services. This is necessary for our legitimate interests (to develop our products/services and grow our business).
• Internal filing which is necessary for performance of a contract with you.
• Marketing our products and services or related products, including providing you with information from us (see section below on direct marketing). This is necessary for our legitimate interests (to develop our products/services and grow our business).
• Analysing, developing, improving, and optimizing the use, function and performance of our services. This activity is necessary for legitimate interests (to develop our services and grow our business).
• Customer profiling and segmentation based on demographic, geographic and behavioural characteristics, in order to better understand the interests and preferences of our (potential) customers, and so communicate with them more effectively.
• Managing the security of websites, network, and system. This activity is necessary for our legitimate interests to improve and grow our business.
• Interacting with you on third party social media which is necessary for our legitimate interests to study how customers use our products/services, to develop them and grow our business.,
• Organizing contests, competitions and/or other promotional activities, which is necessary for our legitimate interests to grow our business, in some instances we may only do so following your consent.
• Recruitment (if you have provided us information in this regard) for performance of a contract with you and where necessary for our legitimate interests, for example, in order that we may assess your suitability to a role; and
• Notifying you about certain changes to our services which is necessary for our legitimate interests (to develop our products/services and grow our business. In some instances, we may rely on your consent to provide you with such updates to our services.
We shall not collect personal data that is not relevant for the purposes as set out above or otherwise notified to you when we seek your consent for the processing of your personal data, and data and shall not retain the data longer than necessary for those purposes or, as the case may be, for the period as determined in an agreement or by law.
This means that we may use your personal data:
• until you, as data subject, objects to such processing and the option to object will be provided in each communication.
• for our continued legitimate interests where this overrides your right to object to such processing
• as long as the legal obligation is in place - where we process your personal data based on the legal obligation.
• as long as the service and/or action requested by you is completed or you withdraw from the service/action - where we process data in connection with services, we render to you and we have no other purpose for keeping the data;
• until the consent for processing is withdrawn –where we rely only on your consent for processing your personal data and there is no legal interest for keeping your personal data (and the option to withdraw the consent will be provided in each communication).
In general, we will delete the personal data we collected from you if they are no longer necessary to achieve the purposes for which they were originally collected. However, we may be required to store your personal data for a longer period due to requirements by law.
The confidentiality and security of your personal data
All personal data we are collecting from you is stored within a secured infrastructure under our management, with support of external suppliers as described in section 5 of this Policy.
We take data security very seriously. We apply an appropriate level of security and have therefore implemented reasonable physical, electronic, and administrative procedures to safeguard the information we collect from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data transmitted, stored, or otherwise processed. Our information security policies and procedures are closely aligned with widely accepted international standards and are reviewed regularly and updated as necessary to meet our business needs, changes in technology, and regulatory requirements. Access to your personal data is granted only to those personnel, service providers or our affiliates with a business need-to-know or who require it in order to perform their duties.
Among other things, we optimize the security of your personal data by:
• using encryption where appropriate.
• using password protection.
• requesting contractual guaranties from third parties.
• limiting the access to your personal data according to the need-to-know principle (e.g., only employees who need your personal data for the Purposes as described above shall receive permission to access them); and
• by taking all reasonable precautionary measures to ensure that our employees and associates who have access to your personal data will be trained in data protection requirements and will process your personal data exclusively in accordance with this statement and our obligations under applicable privacy laws.
In the event of a data breach containing personal data, we will follow all applicable data breach notification laws.
To whom do we disclose your personal data?
We will disclose your personal data only for the purposes and to those third parties, as described below. We will take appropriate steps to ensure that your personal data are processed, secured, and transferred according to applicable law.
Within Bridgestone Group in Europe
We are part of a global organization (the “Bridgestone Group”), consisting of several companies in Europe and abroad. Your personal data may be transferred to one or more Bridgestone Group affiliated companies located in or outside Europe as needed for data processing and storage, providing you with access to our services, providing customer support, making decisions about service improvements, content development and for other Purposes as described in this Policy.
The above will be strictly connected with:
• any kind of service that is rendered by one Bridgestone company to another (under relevant processing agreement) or
• the fact that more than one Bridgestone entity decides on how your personal data is used (under relevant joint controllership agreement) or
• the fact that another Bridgestone entity becomes a separate controller of your data for a given Purpose (e.g., based on your specific consent).
External service providers
Where necessary, we will commission other companies and individuals to perform certain tasks contributing to our services on our behalf within the framework of data processing agreements. We may, for example, provide personal data to agents, contractors, or partners for data processing services or to send you information that you requested. We will only share or make accessible such information with external service providers to the extent required to process your requests. This information may not be used by them for any other purposes, in particular not for their own- or third-party purposes. Your personal data may be shared with a third party to capture your product reviews, for example when you buy goods and services from us, we may follow it up with an enquiry about your experience of the product to help us gauge customer satisfaction. You are not obligated to leave reviews and ratings, but this facility would enable you to get your views of the product across should you wish to do so.
Our external service providers are contractually bound to respect the confidentiality of your personal data.
In connection with any reorganization, restructuring, merger or sale, or other transfer of assets (collectively "Business Transfer"), we will transfer information, including personal information, in a reasonable scale and as necessary for the Business Transfer, and provided that the receiving party agrees to respect your personal data in a manner that is consistent with applicable data protection laws. We will continue to ensure the confidentiality of any personal data and give affected users notice before personal data become subject to a different privacy statement.
We will only disclose your personal data to public bodies where this is required by law. We will for example respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence.
On other legal grounds
Further, we may disclose your personal data in order to protect our legitimate interests or if it is required or permitted by law or if you give your explicit consent for such transfer of your personal data.
International transfers of personal data
Under specific circumstances, it will also be necessary for us to transfer your personal data to countries outside the UK and the European Union/European Economic Area (EEA) (“Third Countries"). Transfers to Third Countries may refer to all processing activities described in this Policy. This Policy shall apply also if we transfer personal data to Third Countries, in which a different level of data protection applies than in your country of residence.
Whenever we transfer your personal data out of the UK or the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or
Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
While using our services, you may be asked to indicate whether you wish to receive certain marketing information by phone, text message and/or, email. If you do so, you thereby agree that we may use your personal data to provide you with information about its products, promotional activities, and special offers as well as with any other information about our products or services. At any given time, you may change your preferences regarding Direct Marketing by using the opt-out option contained in every direct marketing mailing, contacting us in accordance with section 132 below or, if applicable, by adapting your account information.
User rights with regard to personal data
As a data subject you have specific legal rights relating to the personal data we collect from you. This applies to all processing activities stipulated in this Policy. We will respect your individual rights and will deal with your concerns adequately. The following list contains information on your legal rights which arise from applicable data protection laws:
Right to rectification: you may obtain from us rectification of personal data concerning yYou. We make reasonable efforts to keep personal data in our possession or control which are used on an ongoing basis, accurate, complete, current and relevant, based on the most recent information available to us. In appropriate cases, we provide self-service internet portals where users have the possibility to review and rectify their personal data.
Right to restriction: you may obtain from us the restriction of processing of your personal data, if:
• You contest the accuracy of your personal data for the period we need to verify the accuracy.,
• the processing is unlawful, and you request the restriction of processing rather than erasure of your personal data.,
• we do no longer need your personal data, but you need us to retain your personal data to exercise or defend legal claims., or
• you object to the processing while we verify whether our legitimate grounds override yours.
Right to access: you may ask for information regarding personal data that we hold about you, including information as to which categories of personal data we have in our possession or control, what they are being used for, where we collected them (, if not from you directly), and to whom they have been disclosed, if applicable. You may obtain from us one copy, free of charge, of personal data we hold about you. We reserve the right to charge a reasonable administrative fee for each further copy you may request.
Right to portability: At your request, we will transfer your personal data to another controller, where technically feasible, provided that the processing is based on your consent or necessary for the performance of a contract. Rather than receiving a copy of your personal data you may request that we transfer the data to another controller, specified by you, directly.
Right to erasure: you may obtain from us erasure of your personal data, where:
• the personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed.
• You have a right to object further processing of your personal data (see below) and execute this right object to the processing.
• the personal data has been unlawfully processed, unless the processing is necessary.
• for compliance with a legal obligation which requires processing from us.
• in particular for statutory data retention requirements.
• for the establishment, exercise, or defence of legal claims.
Right to object: you may at any time object to the processing of your personal data due to your particular situation, provided that the processing is not based on your consent but on our legitimate interests or those of a third party. In this event we shall no longer process your personal data, unless we can demonstrate compelling legitimate grounds and an overriding interest for the processing or for the establishment, exercise, or defence of legal claims. If you object to the processing, please specify whether you wish for us to erase of your personal data or the restriction of its processing by us.
Right to lodge a complaint: In case of an alleged infringement of applicable privacy laws, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Right to withdraw consent: where we are relying on consent to process your personal data. However, this will not affect the lawfulness of nay processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the you withdraw your consent.
We will try to fulfil your request for Personal Data within 30 days. However, the period may be extended due to specific reasons relating to the specific legal right or the complexity of your request.
In certain situations, we may not be able to give you access to all or some of your personal data due to statutory provisions. If we deny your request for access, we will advise you of the reason for the refusal.
In some cases, we may not be able to clearly identify you based on the information which you have provided in your request. In such cases, where we cannot identify you as a data subject, we are not able to comply with your request to execute your legal rights as described in this section, unless you provide additional information enabling your identification. In order to exercise your legal rights, please contact us using one of the methods prescribed below.
Our services may, from time to time, contain hyperlinks to websites which are not controlled by us. Although we will do our utmost to make sure that the hyperlinks on the Website lead exclusively to websites which share our safety and confidentiality standards, we are not responsible for the protection or confidentiality of any data you may submit on such other websites. Before submitting information on such sites, we recommend that you read their privacy and other statements in that regard.
Individuals under the age of 16 should not provide us with their personal data without the consent and supervision of their parent or guardian. Without such permission, we do not wish to save personal data from such individuals, nor process or forward such data to any third parties. If we become aware that personal data from under aged persons were inadvertently collected, we will delete such data without undue delay.
We will not process special categories of personal data concerning you ("sensitive data"). Sensitive data refer to personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, health or a natural person's sex life or sexual orientation.
Changes to this Policy
We reserve the right, at our discretion, to modify our privacy practices and update and make changes to this Policy at any time. For this reason, we encourage you to refer to this Policy on an ongoing basis. This Policy is current as of the "last revised” date which appears at the top of this page. We will treat your personal data in a manner consistent with the Policy under which they were collected, unless we have your consent to treat them differently.
Email us using the contacts form on our web sites choosing either your local store or ‘Head Office’ from the drop-down menu https://www.etbtyres.co.uk/contact/
Write to us at our Head Office: Unit 15b Blackpole Trading Estate East, Blackpole Road, Worcester, WR3 8SG
To reach your local centre please see “Depot Locator” on our web sites for full address and phone numbers. Please note ETB Group reserve the right to record telephone calls to our company for training purposes and to ensure the best quality customer service.
The cookies we use on our website are broadly grouped into the following categories:
Essential – Some of the cookies on our website are essential for us to be able to provide you with a service you have requested. An example of this would be a cookie used to enable you to log into your account on the website or which allows communication between your browser and the website. You may not be able to use our website without these cookies.
Analytics – ETB Group sites use analytics cookies to helps us understand how users engage with our website. An example is counting the number of different people coming to our website or using a particular feature, rather than the total number of times the site or feature is used. Without this cookie, if you visited the website once each week for three weeksweeks, we would count you as three separate users. We would find it difficult to analyse how well our website was performing and improve it without these cookies.
How can I reject or opt out of receiving cookies?
Please note that we can't always control third party cookies stored on your machine from our website and where this is the case you will need to visit the relevant third party's website directly to manage cookies stored on your machine by them. Please see our "Third Party Cookies" section below.
If you want to reject cookies, we use from this website you will need to:
delete the cookies from your browser. Most browsers also allow you to prevent all or some cookies being stored on your machine in the future. For more information on how to delete or disable cookies from your browser please use the "help" function within your browser or alternatively visit www.allaboutcookies.org By deleting our cookie preference cookie, the next time, you visit this website the cookie message bar will appear again inviting you to again reconsider your preferences; and/or if you only want to reject some or all of the third-party cookies you will need to visit the relevant third party's website directly to manage cookies stored on your machine by them. Please see our "Third Party Cookies" section below
Please be aware that disabling cookies may impact the functionality of this website.
Third party cookies:
Some of the cookies described in the "What Cookies are used on this Website" section above are stored on your machine by third parties when you use our website. We have no control over these cookies or how the third parties use them. They are used to allow that third party to provide a service to us, for example analytics. For more information on these cookies and how to disable them, please see:
If you want to know more about how cookies work and how to manage or delete them, visit the World Wide Web Consortium’s website.
We may update this policy from time to time so you may want to check it each time your visit our website.