EDGE Privacy Policy

1. About this privacy policy

This is Privacy Policy for EDGE, a Rewards and Recognition incentive programme through which we promote participation by Dealer Sales staff across the Peugeot, Citroen, DS and Autobank network in rewarding sales performance.

In order to provide you with access to EDGE, we need to use and store your information. Please read this Policy carefully to understand our views and practices regarding your personal information and how we will treat it. In addition to this Privacy Policy you need to review the Terms of Use as you will be bound by those terms when using EDGE.

For the purpose of data protection law, PSA Finance UK Ltd (“PSAF”) of 61 London Rd, Redhill, RH1 1QA is the controller of your personal information (this means they make decisions about how and why your information is used, and have a duty to ensure your rights are protected). If you have questions or concerns about this policy, you should contact PSA Finance UK Ltd by writing to our Data Protection Officer at 61 London Road, Redhill, Surrey RH1 1QA or by email to ukdataprotectionofficer@psa-finance.com.

EDGE and www.edge-psafinance.com (the “Website”) are both operated on our behalf by BI Worldwide Limited (BIW) of 1, Vantage Court, Newport Pagnell, Buckinghamshire MK16 9EZ. BIW is acting as a data processor for the purposes of data protection law (this means BIW will only use your information on PSAF’s instructions and in accordance with a written contract that ensures your rights are protected).

 

2. Information you provide

We will collect and use personal information that you provide to us in connection with EDGE. If you provide details of your activities in order to earn Reward Points, then we will collection information about those activities. We also collect information when you:

  • fill in forms, communicate with us by phone, e-mail or otherwise
  • register to use the EDGE or our website
  • enters details of activities completed in connection with EDGE
  • enter a competition, promotion or survey

The information we collect in this manner will usually include your name, address, e-mail address, and phone number. The EDGE programme is continually being improved and developed and as such further information may need to be collected from you from time to time. You will be notified of any further information required and the reason behind this when visiting the site. You will always retain the right not to have to provide any information requested from you.

We don’t normally ask for (or otherwise collect) sensitive personal information about you. In the unlikely event that we do, we’ll ensure that such information is kept private and secure.

 

3. Information we collect about you.

Your use of EDGE (and our Website) will generate information, some of which will relate to you. We may collect and analyse this information, including the following:

  • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet (an IP address is a unique number assigned to your computer when you are using your browser on the internet), your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform
  • information about your visit to EDGE website, including the full Uniform Resource Locators (URL) clickstream to, through and from the Website (including date and time), products you viewed or searched form, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number
  • information you input into EDGE or the Website may be used for features including chat rooms, messaging services, and community and event forums for collaboration, peer connection, games, and information exchange purposes. Depending upon the Programme, the personal data you choose to post, share, upload, or make available is public and visible to others who use the EDGE. You should never post of share any information that is confidential or is personal to you unless you accept that information may be available to others you should never share or post information about others unless you have permission to do so. We may use information you provide in community and event profiles and forums to personalise your experience and to make content and peer connection recommendations.

We may also combine your information with information about other people, which will then be aggregated and anonymised. The resulting information, which will not identify you specifically, can be used to help us analyse and improve EDGE. It may also help us improve our business and may be shared with our customers and suppliers to assist them.

 

4. Information we receive from other sources.

As a programme participant we will already hold some information about you, and we may combine that with information that we collect in connection with EDGE.

We work closely with third parties (including, other companies in our corporate group, business partners and sub-contractors in technical and delivery services, such as BIW who operate the Website). We share and receive information with these third parties where necessary in order to operate EDGE.

We may collect and process information concerning your employment and participation in EDGE including, without limitation, details in respect of your ID, training and performance histories, staff ID, job role, dealership and/or sales, and/or customer viewpoint performance.

 

5. How and why we use your information

We need to use your information to operate the EDGE and the Website. This includes using information to the extent required in order to:

  • allow you to participate in EDGE and assess your eligibility for and, if eligible, inform you about relevant incentives, programmes, products and/or services
  • operate EDGE and the Website (in order to this, we might need to share information with business partners and subcontractors, please section 6 for further details)
  • provide you with information about incentives, products, prizes content and services which we believe are relevant to you
  • ensure we provide you with content which is relevant and do so in an effective manner
  • As part of the EDGE we require BIW to provide us with reports to analyse the performance of the Programme. This analysis is used to ensure it is working for us and for you. In the course of providing this analysis, it may be necessary for your Personal Data to be analysed and reported back to us. Reports may be produced to show which areas of the Programme are more successful than others to ensure the continued improvement.
  • notify you about changes to the Website, EDGE or our services

Employment specific processing: Personal information processed in connection with EDGE which also relates to your employment (including information regarding the performance your duties as an employee) may be processed by us for employment related purposes. This information could form part of your personnel record as an employee, and could be considered when evaluating the performance of your work.

Technical information we collect about your use of the EDGE or the Website may be used for administrative purposes (e.g. maintaining the Website), research and analysis (e.g. to see how many visitors the Website has) and also for the security and maintenance of EDGE and the Website.

We use personal information in the manner set out above because we need to in order to:

  • pursue our legitimate interests in operating the EDGE and providing incentives to individuals (provided this isn’t be overridden by your rights)
  • enter into, or perform, a contract with you
  • comply with a legal duty
  • protect your vital interests

We may also use information with your consent, but we will make it clear when we do this. In any event, your information will only be used for the purpose(s) we collected it for (or else for a closely related purpose, such as record keeping).

If you enrol on the Website and participate in EDGE we may send you work e-mails about EDGE, its features and services from time to time. These e-mails will only be directly related to EDGE and your participation in it.

 

6. Disclosure of Your Information

We respect the privacy of your information and won’t share it with third parties, except in a few cases where necessary for the purposes set out above. The recipients of your information may include:

  • other companies within our corporate group
  • your employer dealer (and its management staff)
  • suppliers and sub-contractors
  • providers of analytics services, who help us improve and optimise the Website.

Where we share personal information with a third party, we will take steps to ensure that your data is properly protected.

One of the subcontractors we share information with is BI Worldwide Limited (BIW), which administers EDGE and operates the Website for us. Any information you provide via the Website will be processed by BIW on our behalf, but there will be a contract in place to ensure your information and rights are protected.

In addition to the situations above, we may share information if the need arises because:

  • we are involved in a takeover or merger with another business (and, in these situations, data about EDGE and its participants may be one of the assets which is transferred)
  • we are under a legal duty to disclose your information (for example, we are required by law enforcement or a court order)
  • the sharing is required in order for us or a third party (including BIW) to enforce a contract (including the terms of EDGE)
  • to protect the rights, property, or safety of PSA Finance UK Ltd, the participants of EDGE, or others.
 

7. Where We Store Your Personal Data

We normally only store personal information within the European Economic Area (EEA). In the event that we do have to transfer your personal information outside of the EEA then we will take steps to make sure adequate levels of privacy protection, in line with UK data protection law, are in place. These safeguards will usually be contractual and/or the result of a European Union decision which allows the transfer (for example, a US organisation which is certified under the EU-US Privacy Shield framework).

All information you provide to us is stored on our secure servers. Where you have been provided with (or where you have chosen) a password which enables you to access the Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure and even the best policy cannot protect your online privacy and security in all circumstances. We will do our best to protect your personal data however, we cannot guarantee the security of your data transmitted to the Website. Any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

 

8. How long we store your information for

We only store personal information so long as it is required for the purpose(s) we it collected for (or for a related compatible purpose, such as keeping a record of a transaction). We regularly review what data we have and delete that which is no longer necessary. In certain situations you have the right to request that your data be deleted (the right to be forgotten), please see section 10 for further details.

 

9. Cookies

A cookie, also known as an HTTP cookie, web cookie, or browser cookie, is a small piece of data sent from a website and stored in a users' web browser while a user is browsing a website.

The Website uses cookies to distinguish you from other users of the Website and to deliver to you your individual view of EDGE. This helps us to provide you with a good experience when you browse the Website and also allows us to improve the Website. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy.

 

10. Your Rights

We respect your right to access and control your information. Part of this is making sure you understand your legal rights, which are as follows:

  • the right of access to your personal data, we will happily respond to requests for information and, where applicable, will correct, amend or delete your personal data. These requests are subject to any relevant legal requirements and exemptions, including identity verification procedures. Before providing data to you, we will ask for proof of identity and sufficient information about your interaction with us so that we can locate any relevant data;
  • the right to have certain information provided to you in a portable electronic format, or transmitted to another data controller, where technically feasible;
  • the right to have inaccurate data rectified, please remember that you can update your account information by using the “Contact Us” option on the EDGE;
  • the right to object to your data being used for our or a third party’s legitimate interests, or for direct marketing purposes;
  • the right not to be subject to automated decision making and profiling;
  • the right to restrict how your personal information is used;
  • the right to be forgotten, which allows you to have your data erased in certain circumstances, we will always consider all requests in accordance with the ICO guidance and relevant laws and will always balance your interests with the following areas where it is necessary to retain your data:
    • to exercise the right of freedom of expression and information;
    • to comply with a legal obligation for the performance of a public interest task or exercise of official authority.
    • the exercise or defence of legal claims

If you would like further information on your rights or wish to exercise them, please write to our Data Protection Officer at PSA Finance UK Ltd, 61 London Road, Redhill, Surrey RH1 1QA or email ukdataprotectionofficer@psa-finance.com with details of your request.

Please keep in mind that there are exceptions to the rights above and, though we will always try to respond to your satisfaction, there may be situations where we are unable to do so (for example, because the information no longer exists or there is an exception which applies to your request).

If you are not happy with our response, or you believe that your data protection or privacy rights have been infringed, you should contact the UK Information Commissioner's Office, which oversees data protection compliance in the UK. Details of how to do this can be found at www.ico.org.uk.

 

11. Changes to Our Privacy Policy

Any changes we may make to this Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to this Privacy Policy.

 

12. Contact

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to our Data Protection Officer at PSA Finance UK Ltd, 61 London Road, Redhill, Surrey RH1 1QA or email ukdataprotectionofficer@psa-finance.com