Privacy Policy

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Touchstones is committed to protecting and respecting your privacy. This Privacy Notice tells you how Touchstones (“Touchstones”, “we”, “us”) processes your personal data when you visit, download, or contact Touchstones in relation to, Touchstones websites and apps that refer to this Privacy Notice (all "Touchstones Online Content").

This Privacy Notice also describes your personal data protection rights, including a right to object to some of the processing that Touchstones carries out. More information about your rights, and how to exercise them, is set out in the “Your Choices and Rights” section.

We may also provide you with additional information when we collect personal data, where we feel it would be helpful to provide relevant and timely information.

What Personal Data We Collect

We process the following types of personal data:

Contact information: such as your name, job title (for Business Accounts), address, phone, email, and other similar information.
Company information your company name
Technical details of your visit to the Touchstones Online Content: such as your IP address and operating system, browser type (for visits to our website), details of the device you are using (e.g. your device serial number, unique identification number, MAC address) and technical and event based data in relation to your usage of your device (e.g. internet and Bluetooth pairing and connectivity data and session duration).
Information to create a user profile: such as your username, password or PIN.
Product information: such as your product id and date and location of purchase.
Financial information: such as your bank account and payment details
Any other information you submit to us: such as signatures, photographs, opinions, your location, and your trips and any other information you provide, either via the Touchstones app or other platforms.

Why We Collect, Use and Store this Personal Data

We collect, use and store your personal data for the reasons set out below.

Where necessary for Touchstones’s legitimate interests, as listed below, and where our interests are not overridden by your data protection rights.
to deliver the Touchstones Online Content and related services to you;
to administer Touchstones Online Content resources;
to allow us to improve and optimise the Touchstones Online Content and Touchstones products and services;
to respond to your request or enquiry online by you completing a form, for example by you requesting a brochure, locating the nearest Touchstones dealership, or Touchstones product via our online forms.
to respond to your request or enquiry, for example by sending a brochure, locating the nearest Touchstones dealership, or arranging for a service of your Touchstones vehicle, or Touchstones product.
to notify dealers and Touchstones branches of any upcoming services, test drives or other appointments in relation to you or your Touchstones vehicle or Touchstones product;
to contact you for the above purposes (directly or through a Touchstones group company, a Touchstones authorised dealer, a relevant partner or agent) by post, telephone, e-mail, text or push notification;
to ask you to provide your opinion or participate in surveys products services, and dealerships;
to understand which parts of the Touchstones Online Content are popular/most used, or those which need changing/upgrading; and
to respond to user questions and complaints.
Where you have given consent.
For example, to provide you with direct marketing including information about goods and services which may be of interest to you by post, telephone, SMS, email and online.
We will always offer you the opportunity to withdraw from all marketing and also to unsubscribe from our Engine Room Newsletter.
Where necessary to perform any contract Touchstones has with you.
For example, to facilitate online payments and to deliver products and services.
Where necessary to comply with a legal obligation.
Where necessary to protect Touchstones’s legitimate interests and legal rights, and where our interests are not overridden by your data protection rights.
Protecting our legitimate business interests and legal rights. This includes, but is not limited to, use in connection with compliance, regulatory, auditing, legal claims (including disclosure of such information in connection with legal process or litigation) and other ethics and compliance reporting requirements.

On occasions Touchstones will also convert personal data into anonymous data and use it (normally on an aggregated statistical basis) for research and analysis to improve the Touchstones Online Content, analyse trends and, tailor products. Aggregated personal information does not personally identify you or any other use of the Touchstones Online Content.

How We Share Your Personal Data

Transfers within the Touchstones and Keravisie Group of Companies

We share your personal data with members of the Touchstones Group.

For the purposes mentioned above, your personal data will be processed in, or accessed from, members of the Touchstones Group of Companies situated in jurisdictions outside the European Economic Area ("EEA") that do not have equivalent data protection laws to those in the EEA. When we transfer your data within the Touchstones Group of Companies, we make use of standard contractual data protection clauses, which have been approved by the European Commission.

(a) Transfers to Touchstones authorised dealers and repairers

We share your personal data with Touchstones authorised dealers and repairers in the EEA. This data is shared so we can fulfil your test drive, service enquiries, and also share your ownership details with your sales or servicing dealers where you have requested assistance.

(b) Transfers to companies providing services under contract

Your personal data will be shared with companies providing services under contract to the Touchstones group of companies, such the companies set out below:

Website provider & hosting (current provider: adds2marketing, adds2mobile GCV, Wix)
e-Commerce Power Equipment Website provider (current provider: adds2marketing )
Live Chat Power Equipment Website provider (current provider: Wix )
Google analytics provided for website improvement and optimisation (Google LLC)
Email Broadcast
Event Management
Event tablet data collection
IT help desk provider (current provider: adds2marketing)
IT hosting (current provider: Wix)
IT maintenance provider (current provider: adds2marketing)
Data Management
Data analysis
Extended Guarantees & Service Plan providers
Warranty providers
Customer satisfaction surveys across our divisions
Customer Relations call services
Customer Relations call management
Registration Data for government use
Professional advisors
Dealer Awards Program

Transfers outside the EEA

Further to the above purposes, we will transfer your personal data to organisations outside of the EEA. When doing do, we may use standard contractual data protection clauses, which have been approved by the European Commission. We may also transfer your data to organisations in the US who participate in the EU-US Privacy Shield or which have corporate rules in place to protect your data, which have been approved by EU data protection authorities. For further information, including to obtain a copy of the documents used to protect your information, please contact us as described in the Contact Us section below.

Google Analytics

Where you consent to the use of Google Analytics for performance optimisation of your Touchstones app, Google may store or process your data in the US or any other country in which Google or its sub-processors maintain facilities. Where this is the case, we will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice).

Third party apps

Where you download a third party app from the Touchstones Online Content, your personal data will be transferred to that third party app provider directly as a separate data controller. Touchstones is not responsible for the processing of your personal data by such app providers. As such, you should take time to read and understand how your personal data will be used by app providers before you download their apps.

Transfers to third parties if we are under a duty to disclose your personal data in order to comply with a legal obligation or if we consider this is necessary for us to protect the rights, property or safety of Touchstones, our customers or others.
Transfers to government authorities and/or law enforcement officials if mandated by law or if required for the protection of our legitimate interests in compliance with applicable laws.
Transfers to prospective or actual buyers in the event that Touchstones, or any part of the Touchstones Group, sells any of its business or assets which includes personal data.
Transfers to third parties, where you have given specific consent:

o Insurance providers

o Independent Reviews across our divisions

Your Choices and Rights

(a) Your general Rights and Choices

You have the right to ask Touchstones for a copy of your personal data; to correct, delete or restrictprocessing of your personal data; and to obtain the personal data you provide in a structured, machine readable format.
You can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement).
Where we have asked for your consent, you may withdraw consent at any time. If you ask to withdraw your consent to Touchstones processing your data, this will not affect any processing which has already taken place at that time.

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep.

(b) Your Rights and Choices regarding Direct Marketing

Touchstones will give you the opportunity to opt-in (consent) to having your contact details used for direct marketing purposes at the time we ask you to submit your details.

If you do not want us to send you direct marketing, or to use your personal data for profiling related to direct marketing, or to pass your details on to third parties for marketing purposes, you can ask us not to do this, at any time, by:

Replying to a direct marketing email, by selecting the ‘unsubscribe’ button;
By changing privacy settings in an app (if applicable to the app);
By contacting us at info@touchstones.eu

You also have the right to complain to a supervisory authority for data protection. The supervisory authority could be in the place where you live, or where you work, or where a breach of data protection obligations has occurred.

Data Retention

We will retain your personal data only for as long as we need it for Touchstones's legitimate interest in accordance with applicable law, or perform a service at your request, or to meet a legal requirement. At the end of the retention period, we will take steps to delete your personal data or hold it in a form that no longer identifies you.

Fake emails using Touchstones's name

Touchstones is aware of fake emails, popularly called "phishing" emails which can contain notices such as job advertisements, job offers and competition award notifications. These emails use Touchstones’s name to pretend they are genuine and exist solely for the purpose of obtaining private information about consumers (e.g. credit card numbers or passwords). These emails have no connection with Touchstones and Touchstones does not use these methods for job advertising or for communicating with competition winners.

Unfortunately these fake emails are a growing fraud on the internet. This practice is carried out either by the sending of a bogus email directly to a victim, or by directing them to a website where personal information is requested.

Fake job offers tend to target overseas individuals, as they ask for money to be sent to them for BE visa purposes. Touchstones never requests payments details in association with any job applications or any communication related to them. If in any doubt about the validity of a recruitment offer, please contact Human Resources.

Recent email award notifications have purported to be from Touchstones. Touchstones never requests payment details in association with competition winners or any communication related to them.

Touchstones advises that if you receive an email using Touchstones’s name that asks for personal information or financial information and you have concerns about its authenticity, then please treat such emails with extreme caution.

Links to third party sites

Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and Group companies. Touchstones is not responsible for the content of any websites that are linked to its site. When entering a third party site, it is your responsibility to ensure that you read the privacy notice and legal terms & conditions that apply to that site

Updates to this Privacy Notice

This Privacy Notice may be updated periodically. We will update the date at the top of this Privacy Notice accordingly and encourage you to check for changes to this Privacy Notice, which will be available on the Touchstones Online Content. On some occasions, we may also actively advise you of specific data handling activities or significant changes to this Privacy Notice, as required by applicable law.

Touchstones is the data controller of Touchstones customer and prospect personal data, processed further to this Privacy Notice. Our data protection officer for Touchstones operations in Europe can be contacted at info@touchstones.eu. If you have any questions about this Privacy Notice, please contact us at Touchstones (BE).

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