Privacy Policy

www.phoenixbespokekeys.com (the “Site”) is opend and operated by Phoenix Bespoke Group Ltd. Phoenix Bespoke Group Ltd is the data controller and can be contacted at:

Info@phoenixbespokekeys.com
+44())7500 831761
198 London Road, North End, Portsmouth, Hampshire, PO2 9JE, United Kingdom

Purpose
The purpose of this privacy policy (this “Privacy Policy”) is to inform users of our Site of the following:
1. The personal data we collect;
2. Use of collected data;
3. Who has access to the data collected;
4. The rights of Site users; and
5. The Site’s cookie Policy.

This Privacy Policy applies in addition to the Terms and Conditions of our Site.

GDPR
for users in the EU, we adhere to the Regulation (EU) 2016/679 of the European Parliament and the Council of 27 April 2016, known as the General Data Protection Regulation (the “GDPR”). For users in the UK, we adhere to the GDPR as enshrined in the Data Protection Act 2018.

We have not appointed a Data Protection Officer as we do not fall within the categories of controllers and processors required to appoint a Data Protection Officer under Article 37 of the GDPR.

Consent
By using our Site users agree that they consent to the conditions set out in this Privacy Policy.

When the legal basis for us processing your personal data is that you have provided your consent to that processing, you may withdraw your consent at any time. If you withdraw your consent, it will not take processing which we have completed before you withdrew your consent unlawful.

You can withdraw your consent by contacting us directly.

Legal Basis for Processing
We collect and process data about users in the EU only when we have a legal basis for doing so under Article 6 of the GDPR.

We rely on the following legal bases to collect and process the personal data of users in the EU:
1. Users have provided their consent to the processing of their data for one or more specific purposes;
2. Processing of user personal data is necessary for us or a third party to pursue a legitimate interest. Our legitimate interest is not overridden by the interests or fundamental rights and freedoms of users. Our legitimate interests are: Sale, Supply, Repair and Customisation of keys and automotive components and accessories;
3. Processing of user personal data is necessary for us to take, at the request of a user, steps before entering a contract or for the performance of a contract to which a user is a party. If the user does not provide the personal data necessary to perform a contract the consequences are as follows: We cannot accurately determine a price for shipping without the users address; We cannot identify a vehicles colour, or correctly identify the correct component to supply without the Vehicle Identification Number (VIN) or Vehicle Registration Number (VRN); and
4. Processing of personal data is necessary for us to comply with a legal obligation. If a user does not provide the personal data necessary for us to perform a legal obligation the consequences are as follows: We cannot supply new keys without proofs of identify and ownership; We cannot deliver orders placed without knowing the name and address to deliver them to; We cannot identify a vehicles colour, or correctly supply the correct component without the Vehicle Identification Number (VIN) or Vehicle Registration Number (VRN).

Personal Data We Collect
We only collect data that helps us achieve the purpose set out in this Privacy Policy. We will not collect any additional data beyond the data listed below without notifying you first.

Data Collected in a Non-Automatic Way
We may collect the following data when you perform certain functions on our Site:
1. First, Middle and Last Name;
2. Date of Birth (and age);
3. Sex;
4. Email Address;
5. Phone Number;
6. Address;
7. Your Vehicle Registration Number and Vehicle Identification Number (VIN).
8. Payment information; and
9. Auto fill data.

This data may be collected using the following methods:
1. Completing our contact form;
2. Placing an order; and
3. Directly by email, phone or other means of direct communication.

How We Use Personal Data
Data collected on our site will only be used for the purposes specified in this Privacy Policy or indicated on the relevant pages of our Site. We will not use your data beyond what we disclose in this Privacy Policy.

The data we collect when the user performs certain functions may be used for the following purposes:
1. To correctly identify a vehicles paint code or component required;
2. To accurately quote prices for the order and shipping;
3. To fulfil the order placed;
4. Communication; and
5. Verification of Identity to ensure only legitimate parties can order keys for vehicles.

Who We Share Personal Data With
Employees
We may disclose user data to any member of our organisation to reasonable needs to access user data to achieve the purposes set out in this Privacy Policy.

Third Parties
We may share user data with the following third parties:
1. Vehicle Manufacturer or Franchised Dealer

We may share the following user data with third parties:
1. Proofs of vehicle ownership and user ID

We may share user data with third parties for the following purposes:
1. To prove the user placing an order for keys which facilitate access to a vehicle is the registered owner/keeper of the vehicle, for security purposes.

Third parties will not be able to access user data beyond what is reasonably necessary to achieve the given purpose.

Other Disclosures
We will not sell or share your data with any third party, except in the following cases:
1. If the law requires it;
2. If it is required for any legal proceeding;
3. To prove or protection our legal rights; and
4. To buyers or potential buyers of this company in the event that we seek to sell the company.

If you follow hyperlinks from our Site to another Site, please note that we are not responsible for and have no control over their privacy polices and practices.

How Long We Store Personal Data
User data will be stored indefinitely or until you request it be deleted.

How We Protect Your Personal Data
In order to protect your security, we use the strongest available browser encryption and store all of our data in secure facilities. All data is only accessible by your employees. our employees are bound by strict confidentiality agreements and a breach of this agreement would result in the employees termination.

While we take all reasonable precautions to ensure that user data is secure and that users are protected, there is always a risk of harm. The Internet is as a whole insecure at times and therefore we cannot guarantee the security of users data beyond what is reasonable and practical.

Your Rights as a User
Under the GDPR, you have the following rights to:
1. Be informed;
2. Have access;
3. Rectification;
4. Erasure;
5. Restrict processing;
6. Data portability;
7. Objection.

Children
We do not knowingly collect or use data from anyone under 16 years of age. If we learn we have collected data from anyone under 16 years of age, the data will be deleted promptly. If someone under 16 years of have has provided us with personal data, their parent or guardian may contact us directly.

How to Access, Modify, Delete, or Challenge the Data Collected
if you would like to know if we have collected your personal data, how we have used it, if it has been disclosed to a third party and their identity, if you would like to have your data deleted of modified, or if you would like to exercise any other rights under the GDPR, please contact us directly using the following details:

info@phoenixbespokekeys.com
+44(0)7500 831761
198 London Road, North End, Portsmouth, Hampshire, PO2 9JE, United Kingdom

Do Not Track Notice
Do Not Track (“DNT”) is a privacy preference you can set in certain web browsers. We do not track the users of our Site over time and across third party websites and therefore do not respond to browser-initiated DNT signals. We are not responsible for and cannot guarantee how any third parties who interact with our Site and your data will respond to DNT signals.

Cookie Policy
A cookie is a small file, stored on a user’s hard drive by a website. Its purpose is to collect data relating to the user’s browsing habits. You can choose to be notified each time a cookie is transmitted. You can also choose to disable cookies entirely in your Internet browser, but this may decrease the quality of your user experience.

We do not use cookies on our Site.

Modifications
This Privacy Policy may be amended at any point to ensure we comply with all relevant laws or to reflect any changes in the way in which we collect data. The publication date at the bottom of this Privacy Policy clearly states when it was last updated.

Complaints
If you have any complaints, please contact us using the contact information above or using the contact us tab in our menu. We will endeavour to resolve your issues promptly and professionally. If you feel we have not done so, you may make a complaint directly to the Information Commissioners Office in the UK.

Publication Date: 12 May 2025