1. The Aston Martin Privacy Policy

a) Purpose of this privacy policy

Aston Martin Works Ltd (‘we’, ‘us’, ‘our’) respects your privacy and is committed to protecting the
personal data you provide to us. This privacy notice will let you know how we collect, process and manage your personal data which we have received through your use of our websites e.g. www.astonmartinworks.com, subdomains “the websites”), through your attendance at Aston Martin Works events, through your contact with Aston Martin Works, through our arrangements with third parties referred to below or through other channels organised by us regarding the promotion and sale of Aston Martin products and services. The privacy notice will also notify you of your privacy rights in relation to the personal data and how the law protects you.

It is important that you read this privacy policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

This privacy policy covers the following:

1. The Aston Martin privacy policy
2. Important Information and who we are
3. The data we collect about you
4. How your personal data is collected
5. How we use your personal data
6. Disclosures of your personal data
7. International transfers
8. Data security
9. Data retention
10. Your legal rights
11. Third party websites
12. Glossary

b) Changes to the privacy policy and your duty to inform us of changes

Please note that we may amend this policy from time to time and any updated policy will be posted on our website and, where appropriate, notified to you by e-mail. Please continue to review this policy whenever accessing our site.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

2. Important information and who we are

We are responsible for your personal data. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us by letter or email using the details below:

The Data Protection Officer
Aston Martin Works Ltd, Tickford Street, Newport Pagnell, Buckinghamshire, MK16 9AN, United Kingdom
E-Mail: [email protected]

You have the right to make a complaint at any time to the Information Commissioner’s Office in the United Kingdom, the British supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the Information Commissioner’s Office, and invite you to contact us in the first instance.

3. 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 has been removed (anonymous data).

a) Types of personal data

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Data includes first name, last name, title, date of birth and gender.
• Contact Data includes address and postcode, email address and mobile and telephone numbers.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased directly from Aston Martin (for example, limited edition vehicles).
• Technical Data includes (where you access the Aston Martin website) 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 the website.
• Aggregated Data is also collected, used and shared, such as statistical or demographic data. This
  information may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may anonymise and aggregate your Usage Data or Contact Data for market research or customer profiling purposes.
• Profile Data includes your personal and professional interests and preferences, any vehicles you may have purchased or events that you may have attended and your experiences of our products and services. Preferred language, dietary requirements and Job Title
• Usage Data includes information about how you use our site, products and services.
• Marketing and Communications Data includes your preferences in receiving direct marketing material from us and certain third parties and your communication preferences.

We do not collect any Special Categories of Personal Data about you (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.

4. How is your personal data collected?

We use different methods to collect data from and about you including through:

a) Direct interactions.

You may give us your Identity, Contact and Profile Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: express an interest in, order, purchase or use one of our products or services from Aston Martin Works Ltd;

• subscribe to our publications;
• attend an Aston Martin event;
• request marketing to be sent to you (by giving us your express consent via an opt-in notice);
• request customer support;

b) Automated technologies or interactions.

As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies.

c) Third parties.

We may also receive personal data about you from various third parties as set out below:

• Technical Data from analytics providers such as Google based outside the EU; and
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services.

5. How we use your personal data

a) General

We will only use your personal data when the law allows us to. We will never sell your data, will keep your details secure, and will never share them with third parties for marketing purposes without your express consent.

We will handle and process your data in accordance with the General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”) and applicable local data privacy regulations.

Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform a contract, we are about to enter into or have entered into with you, or to provide a service which you have requested;
• Where it is necessary for our legitimate interests, and where your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to us sending marketing communications to you via email. If at any time we do request your consent to the processing of your personal data, you have the right to withdraw such consent at any time.

b) Purposes for which we will use your personal data

We have 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 on to do so. We have also identified what our legitimate interests are where appropriate.

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 details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register your interest in receiving details of Aston Martin products and services.	(a) Identity (b) Contact (c) Profile	Promote Aston Martin products and services. Respond to your request.
To manage our relationship with you which will include: (a) Direct marketing of materials regarding Aston Martin products and services.(b) Notifying you about changes to our terms, site or privacy policy. (c) Notifying your local dealer of your interest in driving or purchasing an Aston Martin vehicle or attending an Aston Martin event. (d) Providing you with customer support. (e) Notifying third parties of any personal data necessary for such companies to provide a service associated with your Aston Martin vehicle ownership (e.g. roadside assistance).	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To deliver relevant website content to you and measure or understand the effectiveness of such content.	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our site, purchase products, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our site, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products, to keep our site updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	Necessary for our legitimate interests (to develop our products/services and grow our business)
Necessary for our legitimate interests (to develop our products/services and grow our business)	(a) Identity (b) Contact (c) Transactional	Performance of a contract with you

c) Marketing and Customer Support

• We may use your Contact Data for us to contact you by email about Aston Martin products, services and events, including promotional and special offers, but only where you have given us your express consent to do so by means of a specific opt-in to direct marketing.
• We may share your personal data with the Aston Martin group in order that these parties may contact you by email to share Aston Martin news and to inform you about Aston Martin products, services, merchandise and accessories including promotions, but only where you have given us your express consent to do so by means of a specific opt-in.

(Aston Martin group means Aston Martin Lagonda Limited, Aston Martin Lagonda of Europe GmbH, Aston Martin Lagonda of North America Inc., Aston Martin Lagonda (China) Automobile Distribution Co. Ltd, Aston Martin Japan Limited, Aston Martin Asia Pacific PTE Limited and Aston Martin MENA
Limited).

Where you have purchased an Aston Martin vehicle, we will share with the following companies the personal data that such companies reasonably require in order to fulfil their services to you, associated with your vehicle ownership:

• Beehive – Customer Satisfaction Survey
• Car Care Plan – Extended Warranty Provider
• Allianz – Roadside Assistance Provider (UK & Europe)

c) Opting out

You can ask us or third parties to stop sending you marketing messages at any time by sending a request by post or email to the address or email address set out at the beginning of this privacy policy or by following the unsubscribe link on our marketing communications sent to you.

d) Cookies

Our site uses cookies to distinguish you from other users of our site. This helps us to provide you with a good experience when you browse our site and also allows us to improve our site. For detailed information on the cookies we use, the purposes for which we use them and how to manage them please see our Cookie Policy at https://global.astonmartin.com/en-gb/legal/cookies.

e) Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us by emailing data. [email protected] If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. Disclosures of your personal data

a) Service providers and sub-contractors

In order to process any requests you make regarding Aston Martin products and services, to host you at an Aston Martin event, or to provide you with customer support, we may need to share your
personal data with some of our service partners, suppliers and sub-contractors who are best placed to assist you and parties who manage particular Aston Martin events. We will only allow such parties to handle your personal data when we have confirmed that they apply appropriate data protection and security controls and we have in place with them contractual obligations relating to data protection and security which include a requirement that they may only use your data to provide services to us and to you, and for no other purposes.

b) Other third parties

Apart from the above parties, we will not disclose your personal data to any third party without your express consent, except that we may make such a disclosure to governmental bodies, regulators, law enforcement agencies, courts/tribunals and legal advisers or insurers where we are required to do so in order to: comply with our legal obligations; exercise and/enforce our legal rights; prevent, detect, investigate crime or prosecute offenders; or in order to protect our employees and customers. In each case any such disclosure will comply with the relevant laws.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

7. International transfers

For those customers and prospects who are resident in the European Union and Switzerland, the data that we collect from you will only be transferred to, and stored at, a destination within the European Union (EU). If we should need to transfer your data outside the European Union for a legitimate purpose we will seek your consent or else notify you of any legal basis for such transfer, consistent with the GDPR.

8. Data security

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. Your personal data is protected by technical security systems and additional authorization procedures, both during data transfer and when your data is filed and stored on our secure servers. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

9. For how long will you use my personal data?

We will only retain your personal data for as long as necessary to fulfil the purposes for which we have collected the data. Where personal data is held for marketing purposes and there is no sales history we will hold your personal data for no longer than two years from the date of your last interaction with us. Where you have purchased a product directly from Aston Martin we will keep your personal data for no longer than ten years from the date of your last interaction with us unless you contact us using the details provided.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

10. Legal Rights for Customers & Prospects based in the European Union

a) What are these?

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the
  processing of your personal data in the following scenarios:
  (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any 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 time you withdraw your consent. If you wish to exercise any of the rights set out above, please contact us using the contact methods and details set out the beginning of this privacy policy.

b) No fee usually required

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 may refuse to comply with your request in these circumstances.

c) What we may need from you

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). 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.

d) Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

11. Links to third party websites

Our site may, from time to time, contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

12. Glossary

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.