Política de privacidad - Triumph Renting

Welcome to Triumph's Privacy Policy. At Triumph, we take privacy very seriously and are committed to protecting your personal information.

Please read this privacy policy carefully, as it contains information about who we are and the reasons and methods we use to collect, store, and share your personal information on our websites and applications, including the My Triumph mobile application (the «App»). It also explains your rights regarding your personal information and how to contact us or supervisory authorities if you have a complaint.

This privacy policy is reviewed periodically and changes are posted on our website or sent via email.

This privacy policy was published on May 11, 2018 and last updated on June 29, 2022.

WHO WE ARE

This privacy policy is for and on behalf of Triumph Motorcycles Limited (identification number 01735844), located in the United Kingdom with registered office at Ashby Road, Measham, Swadlincote, Derbyshire, DE12 7JP, and its affiliated companies, collectively referred to as the "Triumph Group".

In this document, (a) "Affiliate" means any entity that directly controls, is controlled by, or is under common control with Triumph Motorcycles Limited; and (b) "Control" means the effective ownership of more than 50% of the issued share capital of a company or the legal ability to direct or cause the direction of the management and policies of the company, and the terms "control" and "controlled" should be understood in this way.

Triumph Motorcycles Limited is responsible for our websites and applications, and for the processing of personal data for the purposes set out in this privacy policy.

From time to time, a Triumph Group company in your territory may also become responsible for your personal data for the purposes stipulated in this privacy policy.

In this document, all references to Triumph, Triumph Motorcycles, Triumph Motorcycles Limited, "we", "our" or the company, includes Triumph Motorcycles Limited and its affiliates as defined above, as applicable.

CONTACT INFORMATION

If you have any questions about this privacy policy or our procedures in this area, please contact our Legal and Compliance team through the following channels:

Postal address:- Legal and Compliance Team, Triumph Motorcycles Limited, Normandy Way, Hinckley, Leicestershire, LE10 3BZ, United Kingdom

Email address:- TriumphDataProtection@Triumph.co.uk

DATA WE COLLECT ABOUT YOU

Personal data or personal information is any information about an individual that can be used to identify that individual. This does not include data from which the identity has been removed (anonymous data).

We have the ability to collect, use, store and transfer different types of personal data, grouped as follows:-

Identifying information:– Name, surname, username or similar identifier, date of birth and gender
Contact information:– Billing address, delivery address, email address, and phone numbers
Bank details:– Bank account number and payment card details
Transaction details:– Details about payments and collections from us and other details of products and services you may have purchased from us
Technical data:– IP address, login data, browser type and version, time zone and location, browser plugin type and version, operating system and platform, and other technical data about the devices used to access this website
Profile details:– Username, purchases or orders made, interests, preferences, years of motorcycle experience, vehicle identification details (including VIN), information about the motorcycle such as VIN, make and model, fuel consumption, engine details, range, mileage and date of next service, comments and responses to surveys and questionnaires
Usage data:– Information about how you use our website, our products and our services
Marketing and communications data:– preferences when receiving marketing communications sent by us or by third parties, as well as communication preferences.
Public data sources:– Information to facilitate the operation of the website, ensure that the owner's information matches that of the Ministry of Industry or the relevant authorities, and help with authentication or fraud detection
Location data:– Information about your current location, your planned, saved and completed trips, including route details, duration and distance traveled.

We also collect, use, and share aggregated data, such as statistical or demographic data, for any purpose. Aggregated data may be derived from your personal data, but for legal purposes, it is not considered personal data because it does not directly or indirectly reveal your identity. For example, we may use your aggregated data to calculate the percentage of users who access a certain part of our website. However, if we combine or link aggregated data with your personal data in a way that could directly or indirectly identify you, we will treat the combined data as personal data, which will be managed in accordance with this privacy policy.

As a Triumph customer, we will not collect any personal information without your explicit consent. This includes details about your racial or ethnic background, religious or philosophical beliefs, sexual activity, sexual orientation, political opinions, trade union membership, health information, and genetic and biometric data. We also do not collect information about criminal convictions or offenses.

HOW WE COLLECT INFORMATION

To collect data about you, we use different methods, such as:-

Direct interactions with Triumph:- You can provide us with identity, contact, and financial information by completing online forms, by mail, by phone, when registering to use our apps, at our events, or at the Factory Visitor Experience. This includes the personal information you provide to us when:

Request information about our products or services;
Buy products from us through our online services;
Get in touch with us in any way;
Subscribe to our services or publications;
Register an account with us;
Request that we send you marketing material;
Participate in a raffle, promotion or survey;
Attend one of our events or conferences;
Share data with us through the social media features of our websites or applications;
Make a request, inquiry or complaint, and
Send us feedback or get in touch with us.

We may collect data from you and your motorcycle when you use any of our apps to connect your mobile device to a motorcycle via Bluetooth or otherwise.

Automated technologies or interactions:- When you interact with our website, we automatically collect technical data about your device, actions, and browsing patterns.

Each time you visit one of our websites or use our App, we will automatically collect personal data about your device (device type, browser type, operating system, etc.), information stored on your device, and details about your use of our websites and App.

This personal data is collected automatically through cookies, server logs, and other similar technologies. For more details, please see our Cookie Policy.

Triumph dealers or distributors:- Triumph dealers and distributors will share your personal data with us when you contact them, including those where you purchased Triumph products or services, made an inquiry, or submitted a complaint, request, or claim, such as a warranty claim. In that case, we will process your personal data as stipulated in this privacy policy.

Other companies and publicly accessible sources:- We may receive personal data about you from third parties and public sources such as those listed below:

Vehicle and identity-related data from independent third-party sources, such as the Ministry of Industry and the DGT in Spain, or the DVLA in the United Kingdom;
Advertising networks;
Data analytics providers, such as Google based outside the EU;
Data from your device to perform actions such as adjusting the screen size to your needs;
Credit reference agencies; and
Information search service providers

Consumer-generated sources:- Any content you create and share with us on third-party social media platforms, or upload to one of our apps or websites, including through third-party social media applications such as Facebook. For example: photos, videos, personal stories, and any other similar content.

Information on other social networks. Any information you share publicly or that is part of your profile on a third-party social network such as Facebook, and that you allow that social network to share with us. For example: your basic account information (name, email address, gender, birthday, current city, profile picture, user ID, friends list, etc.) and any other information or activity that you allow the third-party social network to share.

IF YOU DO NOT PROVIDE PERSONAL DATA

In situations where we are required to collect personal information by law or as a condition of a contract with you, and you fail to provide this information when requested, we may be unable to fulfill our part of the contract, such as when purchasing goods or services. In this case, we may have to cancel a product or service you have ordered, but if so, we will notify you promptly.

HOW WE USE YOUR PERSONAL DATA

Under current data protection legislation, we can only use your personal information if we have a legitimate reason to do so, that is, a legal basis for processing. Generally, Triumph will only use your data in the following circumstances:

When we need to fulfill the contract entered into or that we are going to enter into with you;
When necessary for our legitimate interests or those of a third-party company, and your interests and fundamental rights do not prevail over the first-mentioned interests; when we are required to comply with a legal requirement; and
Once you have given us your consent

PURPOSE OF YOUR PERSONAL DATA

Below is a table describing all the intended uses of your personal data and the legal bases on which we rely for these uses. Where applicable, we have also identified our legitimate interests in doing so.

Please note that depending on the specific purpose for which your data is being used, we may process your personal data on more than one legal basis. Please contact us if you require further details about the specific legal bases we rely on to process your personal data.

▀ The table below does not apply to special category data, which will only be processed with your explicit consent.

Purpose/Activity	Data type	Legal basis for processing, including the basis of legitimate interest
To provide you with the products you have purchasedWhen you buy products or services directly from us, including through our online services such as the website or app, we will process your personal data to provide you with those products and services, for example to deliver them to you and to process payment.	IdentityContactFinancialTransaction	Contractual compliance
Marketing activitiesWe may send you marketing communications by email, SMS, phone, or post. We may also share your data with our network of third-party companies to send electronic marketing communications, if you give us your consent to do so. We will also ensure compliance with current data protection regulations regarding the use of cookies in marketing.	IdentityContactTechnicalProfileUsageMarketing and communicationsPublic sourcesLocation data	Consent If you are an existing customer, legitimate interest for direct marketing purposes to develop our business activity.
Market analysis and analysisWe may contact you to identify you as a motorcycle owner and ask if you would like to participate in occasional market research. In this case, we have a legitimate interest in contacting you, and the decision to participate is entirely yours. We will use profiling, including segmentation tools, and conduct research and analysis to improve our marketing strategies, better understand our customers, make our website more user-friendly, and enhance the user experience across all areas of our business.	IdentityContactTechnicalProfileUsageMarketing and communicationsPublic sources	Legitimate interest consent for the purposes of market research and analysis, such as understanding how our customers use our products and how we can improve them and grow our business, to ensure that our marketing is attractive and well-targeted.
Website maintenance and operation / App usage When you use our website or apps, whether at home or at an event, we and our partner companies may process your data to facilitate these services. We may also use your personal data to manage our relationship with you, including notifying you of changes or updates to our online services. We may also want to improve our services to strengthen internal services and the customer experience.	IdentityContactTechnicalProfileUsage	Legitimate interest in ensuring that our websites and applications are secure and developing customer experiences related to the use of our website. Contractual compliance.
Personalization (offline and online). We will use your personal data to create profiles in order to (i) analyze preferences and habits, (ii) anticipate your needs based on our analysis of your profile, (iii) improve and personalize your user experience on our websites and apps, (iv) ensure that the content on our websites is optimized for you and your device, (v) provide you with targeted advertising and content (including via social media), (vi) allow you to participate in interactive activities if you wish, and (vii) personalize content to make it more relevant to you. Based on this type of information, we will also show you specific content and promotions from Triumph tailored to your interests.	IdentityTechnicalProfileUsageLocationData	Legitimate interest in finding out which of our products and services may interest you and offering them to you, as well as identifying types of consumers for new products or services
Social networks We use your personal data when you interact with third-party social media features, such as "Like," to deliver ads and maintain contact on third-party social networks. You can learn how these features work, the type of profile we obtain about you, and how to opt out by reviewing the privacy notices of the third-party social networks.	IdentityProfileAudiencesUsage	Legitimate interest in finding out which of our products and services may interest you and offering them to you, as well as identifying types of consumers for new products or services
Buy your motorcycle When you purchase a motorcycle from Triumph or one of the dealerships in our network, we will use your information to update our internal databases with details related to a specific motorcycle VIN. This allows us to provide you with up-to-date information about your motorcycle and potentially share details with independent companies to offer you exclusive deals, such as supplemental insurance policies and extended warranties.	IdentityContactProfileAudiencesTechnicalUsage	Legitimate interest in ensuring that our customers receive the best offers related to the purchase of their motorcycle, including warranty extensions when the current warranty has expired.
Warranty, claims and recalls When you submit a warranty claim to Triumph, we must process your personal information to register the claim and ensure your issue is resolved. We are legally required to process your information to ensure that, should a recall occur, we can contact the registered owner of the motorcycle and effectively notify them of the recall.	IdentityContact Profile	Legitimate interest in ensuring that warranty claims are administered and processed within a reasonable timeframe and that customers are informed of the stage their claim is at. Legal obligation. Contractual compliance.
Magazine articles, social media posts If you attend one of our events or visit the Visitor Experience Centre, we may take photos or videos that may appear on social media or in magazine articles. This data may be collected for a specific purpose, in which case we will request your consent, but it will typically be for recording an event to promote the Triumph brand and inform customers and those interested in the Triumph brand about our events and activities.	IdentityContactProfileAudiences	Legitimate interest in informing the public about our events and the general public about Triumph's activities in order to promote the brand and showcase the advances.
Use of our online servicesWhen you request a service from us, such as the map and GPS services available in our apps, we may use your personal data to provide that service. We will allow you to register an account with us. We will also allow you to connect our apps to other products, such as a Triumph motorcycle or accessory.	IdentityContactTechnical dataProfileUsageLocation data	Contractual compliance. Legitimate interest in providing you with a personal and relevant service.
Your requests When you fill out a form to make a request, for example to request a catalog, additional information or to book a test drive, we process your personal data to manage the request and ensure that it is handled correctly.	IdentityContact	Legitimate interest in ensuring that the customer's request is processed in the appropriate manner.
Legal and regulatory obligations When we have to manage legal and regulatory requests, such as the prevention or detection of crimes, or collaborate with regulatory bodies or security forces, such as the National Police, AEAT, DGT, etc., we are legally obliged to process and/or transfer your personal data.	IdentityContactProfileAudiencesTechnicalUsage	Legal obligation
Network and information security We may process your data to maintain our network and security. To do this, we take measures against loss, tampering, and theft, both electronically and physically. We may also engage independent companies that store information remotely to maintain our server locations worldwide.	IdentityContactProfileAudiencesTechnicalUsage	Legitimate interest in appropriately ensuring the security of the network and information.

WHO WE SHARE YOUR PERSONAL INFORMATION WITH

We may routinely share your personal data with certain organizations for the reasons outlined in the table above:

External companies that we use to provide and distribute our products and services, for example to offer financing, insurance, roadside assistance, payment service providers, warranty extensions, website services, etc.;
Marketing and research agencies that perform tasks based on our instructions, such as a specific marketing campaign or market research surveys;
Event companies that organize and manage sponsored events;
Information technology (IT) providers that provide us with systems and services for customer service;
Card payment service providers that manage payment platforms;
Logistics and delivery companies that transport our products to you;
Web and mobile application development companies, with the purpose of enabling (including design and creation), maintaining and managing our websites and our app
Third-party marketing companies, including email service providers.
Web hosting companies, including cloud hosting companies that host our systems, databases, websites and the App.
Service providers that offer our online services, such as Google, which provides the map function of our App*.
Other external companies that we may designate for internal business administration purposes, exclusively for the purposes indicated in the table above.

*Please note that the use of the map feature in our app is subject to Google's Privacy Policy, available at https://www.google.com/policies/privacy/.

We require all third-party data processors to respect the security of your personal data and to handle and process it in accordance with the law. Therefore, we only allow these third-party companies to process your personal data as data controllers on our behalf when we are satisfied with the measures they take to protect your information.

In addition, we impose contractual obligations (such as data processing agreements) on the external companies responsible for data processing with which we work to ensure that they process and protect data in accordance with the law by applying appropriate technical and organizational measures.

INTERNATIONAL TRANSFERS OF INFORMATION

In some cases, it may be necessary to share your personal data outside the European Economic Area (EEA), for example:

With our subsidiaries located outside the EEA;
With distributors or dealers located outside the EEA;
With service providers located outside the EEA;
If you are located outside the EEA; and
If the services we provide have an international aspect.

Each time we transfer your personal data outside the EEA, we ensure that a certain level of protection (as defined by law) is achieved by making sure that at least one of the following points applies:-

We only transfer your personal data to countries considered by the European Commission to provide an adequate level of protection for your personal data;
When we use certain service providers located outside the EEA, we may add contractual clauses approved by the European Commission that give personal data the same protection as in Europe;
When we use US-based providers, we may transfer data to them if they are part of the Privacy Shield framework, which requires them to provide adequate protection for data transferred between Europe and the US; and
We can rely on one of the derogation clauses for specific situations set out in Article 49 of the GDPR.

MEASURES WE TAKE TO KEEP YOUR DATA SAFE

We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized manner, or from being altered or deleted. Furthermore, we limit access to your personal data to those employees, agents, external contractors, and other third-party companies who have a legitimate need to know. These companies will process your personal data only in accordance with our instructions and are bound by a duty of confidentiality.

Unfortunately, the transmission of information over the internet is not always completely secure, even though we take reasonable precautions. While we will take reasonable measures to protect your personal data, we cannot guarantee the security of data transmitted over the internet. All such transmissions, including those made through our websites or applications, are at the customer's own risk. When we receive your information, we will store it in a secure environment protected by a combination of physical and technical measures, such as encryption technologies and authentication systems, to prevent any loss, misuse, disclosure, destruction, theft, or unauthorized access.

We have taken steps to address any suspected personal data breaches and will notify you appropriately, as well as any authorities required by law.

HOW LONG DO WE USE AND RETAIN YOUR PERSONAL DATA?

We will retain your information for as long as reasonably necessary to achieve the purposes for which it was collected, including compliance with all applicable legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period if a complaint has been filed or if we reasonably believe there is a possibility of litigation arising from our relationship with you.

To determine the appropriate retention period for personal data, we take into account the amount, nature and sensitivity of the personal data, the potential for harm if the data is misused or disclosed, the reason we process your data, whether those reasons can be met by other means, and legal, regulatory, tax, accounting and other requirements.

YOUR RIGHTS

In certain circumstances, data protection legislation grants you certain rights regarding your personal data. These are as follows:

Right to access your personal data;
Right to request the correction of your personal data;
Right to erase your personal data;
Right to object to the processing of your personal data;
Right to request the restriction of processing of your data; and
Right to request the transfer of your data (data portability).

If you wish to exercise any of the above rights, please send us a message to TriumphDataProtection@triumph.co.uk or write to us at Legal and Compliance Team, Triumph Motorcycles Limited, Normandy Way, Hinckley, Leicestershire, LE10 3BZ, United Kingdom.

You will not have to pay anything to access your personal data or to exercise any of these rights. However, we may charge a reasonable fee if your request is unfounded, repetitive, or excessive. Alternatively, in such circumstances, we may refuse to comply with your request.

We may request specific information from you to confirm your identity and ensure that your right to access your personal data or any of the aforementioned rights is exercised correctly. This is a security measure to guarantee that we do not disclose personal data to anyone who is not entitled to receive it. We may also contact you to request further information regarding your request in order to expedite our response.

We will try to respond to all legitimate requests within one calendar month. Occasionally, it may take us longer than a month to respond if your request is particularly complex or you have made more than one request. In such cases, we will notify you and keep you informed.

If you wish to limit the processing of your personal data for email newsletters, maintenance messages, or general marketing, you can use the unsubscribe option at the bottom of all our marketing communications. Unsubscribe requests may take up to seven (7) business days to take effect.

HOW TO FILE A COMPLAINT

If you are not satisfied and have a complaint related to data protection, please contact us directly by sending a message to TriumphDataProtection@triumph.co.uk or by writing to us at Legal and Compliance Team, Triumph Motorcycles Limited, Normandy Way, Hinckley, Leicestershire, LE10 3BZ, United Kingdom.

If our response does not satisfy you, you have the right to lodge a complaint with a supervisory authority, in particular in the European Union member state where you work, have your habitual residence, or where the alleged data protection infringement occurred. The supervisory authority in Spain is the Spanish Data Protection Agency (Agencia Española de Protección de Datos), which can be contacted at https://ico.org.uk/concerns/ or by calling +44 0303 123 1113.

LINKS TO OTHER WEBSITES

Our website or apps may contain links to other websites or apps operated by organizations that are not under our control. This privacy policy does not apply to those websites and apps, and we therefore recommend that you read their respective privacy policies before using their services.

We want to make it clear that we are not responsible for the privacy policies and practices of other websites and applications, even if you access them using the links we provide, and that we provide links to other websites and applications for informational purposes only. We specifically disclaim responsibility for the content, privacy practices, and terms of use and do not endorse, represent, or warrant in any way the accuracy, content, or completeness of such websites.

Warning: This privacy policy does not include the Triumph Motorcycles Repair and Maintenance Information (RMI) website. The RMI website has its own privacy policy, which we encourage you to read before accessing the website.

COOKIES

Our websites and applications may use cookies or similar technologies. You can configure your browser to reject some or all browsing cookies, or to alert you when websites attempt to install a cookie on your system or access one that is already installed. If you disable or reject cookies, please note that some sections of our websites or applications may not function correctly or may become inaccessible. For more information about the cookies we use, please see our cookie policy, available at https://www.triumphmotorcycles.es/cookies.

SURVEY PRIZE DRAW

The promoter of this draw is Triumph Motorcycles Ltd
This prize draw is open to individuals aged 18 and over who fully complete the survey. The prize draw is not open to employees of the promoter or Triumph Motorcycles.
To participate in the Prize Draw, you must complete the survey. No purchase is necessary.
Only one entry per person is allowed. Multiple submissions of the same survey or from the same person will not result in additional entries to the drawing.
The promoter accepts no responsibility for tickets that are lost, delayed, sent incorrectly, incomplete, or cannot be delivered or registered for any technical or other reason. The ticket delivery receipt is not proof of receipt by the promoter.
The prize draw closes on the date and time indicated in the survey invitation email. Entries received after this date will not be considered. The draw will take place on the date specified in the survey invitation.
One winner will be selected by random drawing from the entries received in accordance with these Terms and Conditions. The drawing will be conducted using a random computer process administered by the promoter and supervised by an independent member of the promoter's staff. The drawing will take place on the date specified in the survey invitation.
The winner will receive the prize described in the survey invitation.
The promoter accepts no responsibility for any costs associated with the prize that are not specifically included in the prize.
The winner will be notified by email on the day of the draw. If a winner does not respond to the promoter within 90 days of being notified, the prize will be forfeited and Triumph will have the right to select another winner in accordance with the process described above. If a winner declines their prize, or if the entry is invalid or violates these Terms and Conditions, the prize will be forfeited and the promoter will have the right to select another winner.
The prize will be sent to the winner via email.
The prize cannot be exchanged, is not transferable, and no cash alternative is offered.
The promoter will use and protect any personal data you provide as described in its Privacy Policy and in accordance with data protection legislation. By entering the Prize Draw, you consent to the collection, retention, use, and distribution of your personal information for the purpose of processing and contacting you regarding your entry into the Prize Draw.
The Promoter and its agencies and associated companies do not accept responsibility for any damage, loss, liability, injury or disappointment suffered by you as a result of entering this Prize Draw or accepting the prize, except for any liability that cannot be excluded by law (including personal injury, death and fraud), in which case that liability is limited to the minimum amount permitted by law.
If for any reason any aspect of this promotion cannot be carried out as planned, including due to computer virus infection, network failures, errors, tampering, unauthorized intervention, fraud, technical failures, or any cause beyond the Promoter's control that corrupts or affects the administration, security, fairness, integrity, or proper conduct of this promotion, the Promoter may, at its sole discretion, cancel, terminate, modify, or suspend the promotion or invalidate any affected entry, as necessary.
By entering the prize draw, participants are deemed to have accepted and agreed to be bound by these terms and conditions. The promoter reserves the right to refuse entry or refuse to award the prize to anyone who violates these terms and conditions.