HWM Privacy Policy

Overview

HWM Sports Cars Limited (“HWM SC”) and HWM Works Limited (“HWM Works”) are committed to protecting the privacy of their customers and this is their privacy policy (the “Privacy Policy”). HWM SC and HWM Works are both registered in England with their registered office at Bridge Motor Works, New Zealand Avenue, Walton on Thames, Surrey KT12 1AT with numbers 336727 and 13574998 respectively. HWM SC trades as Aston Martin Walton on Thames and as HWM Aston Martin. HWM Works trades as HWM Works and HWM Sports Cars,. HWM SC, HWM Works and their trading businesses are collectively referred to as “HWM”, “we” or “us” in this Privacy Policy.

Maintaining the security of your data and ensuring that you are in control of how your data is handled is a priority at HWM. We are dedicated to ensuring that we are transparent about the data that we collect about you, how we use it and the conditions whereby we may disclose your data to others. We will ensure that your data is kept secure and that you are aware of the steps we have taken to ensure the security of your private information.

HWM adheres to the United Kingdom Data Protection Act 1998 and the General Data Protection Regulation 2016/679.

Contents

This Privacy Policy applies for all forms of contact with HWM (whether in person, by phone, email or online) and is organised in sections by topic as follows:

  • What personal data we collect and why.
  • How we may use your personal data.
  • How we may share your data with third parties.
  • How long we will keep your personal data.
  • Notes about our websites and cookies.
  • Keeping personal data current and your legal rights over it.
  • How to contact us.
  • Changes to our Privacy Policy.

What personal data we collect and why

We will only collect relevant data to enable us to carry out the service you have requested or accessed, below we have set out in more detail about the personal data we collect and why we collect it.

Selling your car

If you request a valuation for your current car we require your name, email address, telephone number and postcode (“your core contact details”) and your car details including registration number and mileage, so that we can send you your indicative valuation.

Enquiring about a car to buy

If you enquire about one of our cars we require your core contact details.If we do not have a car that suits your buying preferences at the time of your initial enquiry then, in pursuance of the legitimate interests of our business, we may contact you at a later date when we have a new or used vehicle that we reasonably consider might satisfy your expressed preferences.

Test Drive or Courtesy Car

If you book a test drive or take a courtesy car from our service department we require your core contact details and a copy of your driving licence and we will store a copy of your licence in case of any speeding, parking or other motoring offence that may occur.

Buying a car

If you decide to purchase a car from HWM, at the point of sale as well as your core contact details we will collect your full name, address, date of birth, driving licence details, payment details and, if applicable, details of the car you will be using as a part exchange.

Car Finance

If you require finance for your car purchase, we will require additional information including marital and housing status, number of dependents, previous address, occupation, employer, business address and bank details, in addition we will also require proof of address (i.e. utility bill) and any other relevant information. At the end of your finance agreement we will contact you to discuss your end of finance arrangements and where applicable arrange the required arrangements to fulfil the contract – for example end of finance term car return and appraisal.

Service and MOT Booking

To make an online car service or MOT booking via our websites or over the phone, we require your core contact details and car details. This information is required so that we can arrange your booking for you and send you your booking confirmation through your preferred contact method (email or SMS).

If you have purchased a car from HWM or you have previously had a service, our aftersales system will have stored your information, along with your service and MOT due date. We will send you our yearly service/MOT reminder as we feel it’s important for your safety to know when these events occur. You can object to receiving these reminders at any time.

Buying service plans, vehicle enhancements, parts, merchandise and accessories

If you enquire about any service plans, vehicle enhancements, parts, merchandise or accessories (“after-sales products”), we require your core contact details. If we do not have a product that suits your buying preferences at the time of your initial enquiry then, in pursuance of the legitimate interests of our business, we may contact you at a later date when we have a product for sale that we reasonably consider might satisfy your expressed preferences.If you proceed to purchase any after-sales products at the point of sale we will also require your address and payment details.

Recording

We operate CCTV in our dealership to monitor our premises, therefore your image and car registration may be captured and stored for up to 30 days.Should you call one of our dealerships or should we contact you in response to an enquiry, your phone call may be recorded for quality and training purposes only and will be retained for a maximum of 6 months.

How we may use your personal data

Using your personal information in pursuance of the legitimate interests of our business

We may use and process your lawfully acquired personal information where it is necessary for us to pursue our legitimate interest as a business including for the following marketing purposes (“marketing purposes”):

  • to tell you about new or used vehicles which HWM has or will have available for sale and which we reasonably believe you may an interest in purchasing;
  • for service and MOT booking;
  • to tell you about after-sales products which we reasonably believe you may have an interest in purchasing;
  • to see if you may wish to sell your car to HWM;
  • to invite you to events hosted by HWM or third parties which we reasonably believe you may wish to attend; and
  • in connection with our advertising through social media (you may receive advertising based on information about you that we have provided to a social media platform or because, at our request, the platform has identified you as having similar attributes to the individuals whose details it receives from us).

We may also use and process your lawfully acquired personal information where it is necessary for us to pursue our legitimate interest as a business including for the following purposes (not being marketing purposes);

  • for safety recalls;
  • to undertake credit checks for finance;
  • for the prevention of fraud and other criminal activities;
  • to comply with your request in connection with the exercise of your rights (for example - where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression list in order to be able to comply with your request);
  • for accuracy of data (in order to keep our data up to data and accurate improvements made be made to our database e.g. by consolidating records we hold about you);
  • to defend claims relating to any product or service we have offered or provided to you; and
  • for general administration (we may need to process your data to manage your queries, complaints, or claims and may result in us contacting you by the contact details you have previously provided).

provided always that we will not process your data (including by contacting you) except (i) to the extent necessary for the relevant business purpose or (ii) if and to the extent that the legitimate interests of our business are overridden by your own interests, rights or freedoms.

Where required to perform a contract with you

We may use and process your personal data where it is necessary for the performance of a contract with you or in order to take steps at your request before entering into a contract with you including to fulfil your purchase order for a car and to exchange information for warranty/ aftersales to the relevant manufacturer of your car.

Where it is in your vital interest;

We may use your personal information to contact you if there are urgent safety or product recall notices to communicate to you or where we otherwise reasonably believe that the processing of your personal information may prevent or reduce any potential harm to you.

Where required to comply with our legal obligation;

We will use your personal data to comply with our legal obligation including: (i) to assist HMRC, the Police, the Driver and Car Licensing Agency (DVLA) or any other public authority or criminal investigation body; (ii) to identify you when you contact is; and (iii) to verify the accuracy of data that we hold about you.

How we may share your data with third parties

In order to make certain services available to you, we may disclose your personal information to third parties. We will only disclose the minimum amount of personal data in order to provide the service. We will not disclose such information unless we have a data sharing agreement in place with the relevant third-party supplier and have completed the necessary security checks to ensure that your data is kept safe once it is passed to them. Our third-party suppliers will only have the right to use your data for the purpose of fulfilling the service required of them, they will not have marketing rights over your data, unless you have specifically expressed third party consent.

Your data will be shared with third parties under the following circumstances;

  • If your enquiry leads to the purchase of a new car your information will be shared with the relevant manufacturer for warranty, registration and safety recall purposes. We will ask for your consent to pass your information to the manufacturer for marketing purposes. We recommend that you read the manufacturers privacy policy to see how they will use your data.
  • If your enquiry leads to the purchase of a car with a finance agreement, we will disclose your information to our selected finance partners. If you are accepted for finance, the finance company with become the data controller for your information and we recommend that you read their privacy policy to see how they will use your data.
  • If we provide you with a service plan quote we will disclose your information to our service plan partner, The Warranty Group. If you decide to purchase a service plan from us The Warranty Group will act as a data processor on our behalf. If you decide not to proceed with your service plan quote your details will be deleted from The Warranty Group within 4 weeks.
  • To ensure that the data we hold remains up to date our databases are regularly cleansed via Experian. If we are notified that you are no longer the registered owner of the car we once attributed to you, the car will be detached from your records.

How long we will keep your personal data

We review our retention periods regularly and will only hold your data for as long as it is necessary for the original purpose it was collected for, as required by law or as set out in any relevant contract we have with you. We delete data which is no longer necessary for the purpose it was collected for (“stale data”) on an annual basis.In assessing whether data is stale data we will assess:

  • the nature of your relationship with HWM; and
  • how recently there has been the kind of engagement (“active engagement”) between you and HWM (whether in person, by phone, email or online) which would cause us reasonably to conclude that you want HWM to keep holding your personal data to enable future active engagement.

In formulating these retention periods we have taken into account the fact that Aston Martin and Lagonda cars are high value cars built to last a long period of time, that buying decisions for those brands frequently have long gestation periods, that ownership periods for those brands are often very long and that brand engagement amongst our customers is unusually high.We have also taken into account that the age of our business (which was established in 1938), its family ownership and our low staff turnover all promote long-lasting customer relationships which we wish to both encourage and honour.

Our first step in dealing with stale data is to flag it so that it cannot be used for marketing purposes.The second step is to delete it altogether.Our retention periods are shown below.

Nature of Relationship with HWM

years after last active engagement when data will be disabled for marketing purposes

years after last active engagement when data will be removed for all purposes

Seller of a car to HWM

one

seven

Prospective purchaser of a car or after sales product to be supplied by HWM

two*

two*

Purchaser of any after-sales product from HWM

two

seven

Owner of a car supplied and/or serviced by HWM

five

seven

*except that if the prospective car is not available to order when data would normally be disabled or removed the two year period will restart from when the car first became available to order.

Notes about our websites and “cookies”

Cookies

Cookies are small files which help us to track and identify the preferences of visitors to our websites.We use cookies to enhance the experience for visitors to our websites.They enable us to deliver relevant content and to help visitors navigate the websites.The cookies that we use do not store any confidential information about you.

When visiting our websites, we may collect data directly from you as set out in this Privacy Policy, as well as analysing your browsing and purchasing activity, both online and in dealership, along with your previous response to marketing communications. For example, when you search for a new or used car on our websites we may store information on the cars you searched for and viewed in a cookie so that we can provide personalised content, and suggest other cars you may also be interested in. The results of this data (collected by cookies) allow us to ensure that we contact you with information on products and offers that are relevant to you. To do so, we may use automated profiling software.

HWM recommends that you accept cookies for the following reasons;

  • They enable us to customise elements of our websites for you to provide you with relevant content and offers based on your previous browsing history.
  • We are able to recognise how many users are accessing our websites so that we can ensure we have enough capacity and that our pages load within an acceptable time for visitors.
  • It helps us to identify errors with the websites and resolve them effectively.
  • They allow us to collect statistical, anonymous information about how our visitors browse our site so that we can improve customer experience.
  • It informs us which sections of our site are the most popular and how we can improve those that do not perform well.
  • The use of cookies allows to pre-populate your details on our websites to avoid you having to type in the same details again on subsequent visits to our websites.

Website Banner Marketing

If you visit our websites, you may receive personalised banner advertisements whilst browsing other websites including but not limited to search engines and social networks. Any banner advertisement you will see will relate to products you have viewed whilst browsing our websites on your computer or other devices.Such advertisements are generated by HWM using 'cookies' placed on your computer or other device.

Detailed information on data collected by our websites

Our websites collect a series of general data. This general data and information is stored in the server log files. General data includes (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our websites (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.

When using general data and information, we do not draw any conclusions about visitors. Rather, this information is needed to (1) deliver the content of our websites correctly, (2) optimise the content of our websites as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, we only analyse anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by individuals.

Disabling cookies

You may wish to disable cookies when you visit our websites although disabling them may prevent you from using certain parts of our websites efficiently.

Keeping personal data current and your legal rights over it.

You have a number of rights in relation to your personal information under the data protection law. These are set out in this Privacy Policy. When you contact us about your personal data we may ask you for your information to confirm your identity and, where applicable, to help us search for your relevant personal data. Except in rare cases, we will respond to any contact made about your personal data within 30 days of the request or, if needed, the date on which further information we reasonably ask for is provided.

Accessing your personal information

You have the right to ask for a copy of the information we hold about you by emailing or writing to us using the contact details given at the end of this Privacy Policy. This will be provided in a readable format (CSV) free of charge. We may not provide you with a copy of your information if this concerns other individuals or we have another lawful reason to withhold that information.

Correcting and updating your personal information

The accuracy of your information is important to us and we are working on ways to make it easier for you to review and correct the information we hold about you. In the meantime, if you change your name or address/email address, or you discover that any of the other information we hold about you is inaccurate or out of date, please let us know by contacting us via the contact details at the end of this Privacy Policy.

Setting marketing preferences

When you provide us with your personal data we may ask you to set your marketing preferences with us so that you can choose (if any) the information you'd like to hear more about. This may be done by;

  • registering for offers via our website; or
  • visiting our dealership / contacting us via telephone.

If you opt-in to receive marketing from manufacturers, we recommend that you read their privacy policy to see how they will use your data and how to alter your marketing preferences with them should you wish to in the future.

From time to time, we may ask you to refresh your marketing preferences by asking you to confirm that you consent to continue receiving marketing information from us.

Objecting to our use of automated processing

You may contest to a decision made about you based on automated processing by contacting us on the details at the end of this Privacy Policy.

Withdrawing your consent

Where we rely on your consent as the legal basis for processing your personal information, as set out under ‘How we may use your personal data’ section, you may withdraw your consent at any time by contacting us by:

  • Contacting HWM via the contact details set out in this Privacy Policy;
  • Texting STOP in response to a text message.

If you would like to withdraw your consent to receiving any direct marketing to which you previously opted-in, you can also do this by selecting any ‘amend my preferences’ or similar link located at the bottom of our emails.

If you withdraw your consent, our use of your personal information before you withdraw is still lawful.

Erasing your personal information or restricting its processing

In certain circumstances, you may ask for your personal data to be removed from our systems by emailing or writing to us at the address at the end of this Privacy Policy. Unless there is a reason that the law allows us to use your personal information for longer, we will make reasonable efforts to comply with your request.

You may also ask us to restrict processing your personal data in the following situations;

  • Where you believe it is unlawful for us to do so,
  • You have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings.

In these situations, we may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company in connection with legal proceedings.

Transferring your personal information;

Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with your contract, as set out under section ‘How we may use your personal data’ you may ask us to provide you with a copy of that information in a structured data file. We will provide this to you electronically in a CSV file.

We may not provide you / transfer you a copy of your data if this concerns other individuals or we have another lawful reason to withhold that information.

Complaining to the UK data protection regulator;

You have the right to complain to the Information Commissioners Officer (“ICO”) if you are concerned about the way we have processed your personal information. Please visit the ICO website for further details.

How to contact us

Please contact us if you have any questions about our Privacy Policy or information we hold about you:

  • By email: data@hwm.co.uk
  • Or write to us at: Company Secretary, HWM Ltd, Bridge Motor Works, New Zealand Avenue, Walton on Thames, Surrey KT12 1AT

Changes to our Privacy Policy

Any changes we make to this Privacy Policy in the future will be published on our websites and may also be notified to you by email in the case of a material change.

This Privacy Policy was last updated: 18th February 2026.