Data Privacy Policy

Policy Content areas:

• Purpose
• General Principles
• Specific conditions around personal data
• Website Privacy Policy
• Website Cookie Policy

Purpose

Your privacy is important to us. This Data Privacy Policy aims to explain how we collect, store, use and disclose your personal information whenever you use our products and services, our websites or interact with LetsTalkFleet Limited (LetsTalkFleet), including interactions with our websites www.LetsTalkFleet.co.uk, wwwLetsTalkLeasing.co.uk and www.MyCarLease.Club
This Data Privacy Policy also aims to spell out the conditions that govern how we process and protect that information.

General principles

LetsTalkFleet understands your concerns regarding the confidentiality of your personal information. Below we describe how we acquire and use that information and outline your rights
The following principles are central to how we process your personal information
• Transparency and fairness: When we collect and process your personal information, we inform you as to who collects and receives these data, and the reasons for this. When required by law, we always seek your prior consent (e.g. before collecting any sensitive information or sending any direct marketing material). We never use your personal information for purposes that are incompatible with the purposes outlined here.
• Legitimacy: LetsTalkFleet does not collect or process personal information without a lawful reason. We use your personal information only for appropriate business purposes (e.g. to provide services, manage relationships with customers, manage customer vehicle fleets, and perform accurate invoicing, or for marketing activities, profiling to better serve customers, to conduct satisfaction surveys or draft reports and comply with our legal obligations).
• Minimization: We only collect the personal information strictly necessary for data processing, as set out in this document. We collect sensitive information only where relevant. We take all reasonable measures to ensure that your personal data on record is accurate, complete and up to date.
• Privacy: We aim to ensure privacy when implementing personal data processing.

How long do we keep your personal information?

We retain your personal information only as long as you enjoy a business relationship with LetsTalkFleet, or the term applicable under local law since our last contact, or as required to comply with LetsTalkFleet legal obligations.
In case of litigation, we may keep your personal information until the end of such legal action, including any potential periods for appeal. We will then either delete or archive it according to the law in force.
In any event, your personal information will not be kept in a form that allows you to be identified for any longer than necessary by LetsTalkFleet for achieving the purposes for which it was collected or processed, or according to the relevant laws in force.
How do we ensure the security and integrity of your personal information?
We protect your data through technical and organizational security measures (including education and training of relevant personnel) against accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing.
Only those teams and employees who need to know your information within our company can access it. We make sure to implement administration rights and policies within our company, and we take all measures to ensure that employees, advisers and service providers keep your files confidential.

How can you express your preferences on the use of your personal information?

To exercise the rights set out in the following section at any time, please contact LetsTalkFleet’s Data Protection Officer: Steve Huddart via Complaints@LetsTalkFleet.co.uk, who will handle your request.
• Withdrawal. In cases where you have given your previous consent for your information to be processed, you can withdraw that consent any moment.
• Access. You can request access to your personal information we maintain about you. If you make such a request, we will provide you with all the information on the purposes of the processing, categories of data processed, categories of recipients, data retention term, your rights to rectify, delete or restrict the data accessed if applicable, etc.
• Portability. You can also obtain a copy of any personal information that we hold about you in our records in a format compatible and structure to allow you to exercise your right to data portability.
• Restriction. You can request a restriction in the following cases:
o for a period enabling LetsTalkFleet to verify the accuracy of your personal data in the event you contest the accuracy of your personal information;
o if the processing is unlawful and you wish to restrict your personal information rather than deleting it;
o if you wish LetsTalkFleet to keep your personal information because you need it for your defence in the context of legal claims;
o if you have objected to the processing but LetsTalkFleet needs to check whether it has legitimate grounds for such processing which may override your own rights.
• Rectification / Erasure. You may also request that we correct, amend, erase, any information which is incomplete, out of date or inaccurate, you can request the deletion of your personal information in the following cases:
o if your personal information is no longer necessary for the purpose of the data processing;
o if you have withdrawn your consent for data processing based exclusively on such consent;
o if you objected to the data processing;
o if the personal information must be erased to comply with a legal obligation applicable to LetsTalkFleet.
• Objection. You can also object to the processing of your personal information at any time when used for marketing purposes or profiling to send you targeted advertising or to object to the sharing of your data with third parties.
• Complaint. You also have the right to lodge a complaint with the competent supervisory authority.
You can also provide your instructions regarding the storage, deletion or disclosure of your personal information after your death. Such instructions may be general or specific.

Specific conditions around personal data

What activities and people are concerned by data collection?
This Policy applies to all sources of data collected and processed by LetsTalkFleet in the context of activities such as corporate car leasing, private car lease, sales locations, third-party sources, use of our websites or mobile applications, and all offline processing activities.
We may collect and process your personal information if you are among the following categories: drivers of leased cars, business-to-business customers’ contact, partners, dealers, geographical partners, prospects, fleet managers, shareholders, managers, etc.
Who controls the data?
LetsTalkFleet carry out the data processing activities described above. This section applies to the processing of your personal information by LetsTalkFleet as data controller.
How do we use your personal information?
LetsTalkFleet. uses your personal information to offer you better services.
Therefore, LetsTalkFleet. may use your personal information in the following cases:
(a) When necessary for contractual purposes
(i) on a general level LetsTalkFleet to manage the commercial relationship with you and your company, respond to estimate requests, open customer accounts, fulfil your orders for services and for related activities, manage events, send you communications related to your contract, respond to your inquiries and requests for verifications, provide customer service, account management, support and related training of our personnel involved in such activities, and to provide other services related to your account;
(ii) for the purposes of international customer relationship management LetsTalkFleet in the context of car leasing activities, to perform satisfaction and quality measurement, to consolidate quality information worldwide to create a global assessment of company quality, to provide management satisfaction surveys on products, services or contents, and to follow-up customer relation claims and after-sale service;
(iii) to provide drivers with car monitoring applications or provide managers with fleet management tools;
(iv) to report to clients on customer satisfaction survey results.
(b) With your informed knowledge and consent
(i) Customer satisfaction: based on targeted marketing tools and analysis, we may send you qualitative surveys for our products and services;
(i) Profiling: to improve our understanding of your interests and concerns: we may use your personal information to improve our website and services, to customize your experience with us and to tailor our marketing activities to fit your needs and interests.
(ii) to perform customer screening, credit check and "Know Your Client" processing
(iii) we use your personal information to maintain business records for legal, administrative and audit purposes. We also use information to meet legal, insurance and processing requirements.

What type of personal information do we collect?

We collect the following types of personal information:
• Identification and Contact information, such as your name, last name, city, telephone/mobile number or email address;
• Professional information, such as your job title or professional address;
• Financial/Credit information, such as your Credit Acceptance Date or contract information;
• Private details: such as your gender, date of birth, nationality, language(s), or personal preferences (habits, favourite car, etc.);
• Your voice when you call LetsTalkFleet customer services since your call may be recorded;
• Driver data, such as the number/copy of the driver's license, or the employee code driver;
We may also collect information about you indirectly from our business partners or social media platforms.
We collect your personal information either directly from you (e.g., if you create an account on one of our sites or make a purchase), or passively (e.g., when using tracking tools like browser cookies), or from third parties (e.g. through social media platforms).

Vehicle Operations

When your company uses car leasing services with us, we may collect information about the vehicle (such as the vehicle registration plate, or the vehicle last revision) and the driver's behaviour (such as the average speed), to provide the car leasing services in accordance with the contract and invoice you or your company.
Who do we share your personal information with?
We understand that you do not want us to provide your personal information directly to third parties for their own marketing purposes without your consent. However, we occasionally need to use partners or processors to provide you with the requested services and a better experience, for the purposes described above. We therefore limit our sharing of your personal information on a need-to-know basis as follows:
• with internal business departments
• with our service providers, such as data hosting service providers, call centres, data administrators, located in the UK or within the European Economic Area and instructed to only use your personal information in accordance with our instructions.
• where needed to affect the sale or transfer of business assets, in connection with a bankruptcy proceeding, to enforce our rights, protect our property, or protect the rights, property or safety of others, or as needed support external auditing, compliance and corporate governance functions.
• when required to do so by law, such as in response to a subpoena, including to law enforcement agencies and courts in the countries where we operate.
Please note that we may also use and disclose personal information about you that is not personally identifiable i.e. personal information in an aggregate form that no longer identifies you.
How long do we keep the personal information?
We retain your personal information collected for the purposes and under the conditions described above and for a duration limited to what is strictly necessary.
What happens when we change this Data Privacy Policy?
Our Data Privacy Policy may change from time to time to reflect changes in the way we process your personal information. However, these changes will remain fully compliant with applicable law. We encourage you to periodically review this page for the latest information on our privacy practices. We will notify you of any material changes as required by law.

Right to complain

If you have a complaint about any aspect of data protection or if you feel your privacy has been breached by us, we would like to hear from you. To help us investigate and resolve your concerns as quickly as possible, please contact our Data Protection Officer:

LetsTalkFleet Limited

The Salford Community Stadium, Greater Manchester, M30 7EY

By Phone: 0330 056 3335

By Email: complaints@letstalkfleet.co.uk

If you are unhappy with the final response you have received from LetsTalkFleet, you have the right to complain to the supervisory authority, the Information Commissioner’s Office (ICO). You can call the ICO on 0303 123 1113 or by visiting their website: https://ico.org.uk/.

Website Privacy policy

1. Introduction
1.1 We are committed to safeguarding the privacy of our website visitors; in this policy we explain how we will treat your personal information.
1.2 By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy
2. Collecting personal information
2.1 We may collect, store and use the following kinds of personal information:
(a) information about your computer and about your visits to and use of this website (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths);
(b) information that you provide to us when registering with our website or for the purpose of subscribing to our email notifications and/or newsletters (including your name and email address);
(c) information contained in or relating to any communication that you send to us or send through our website (including the communication content and metadata associated with the communication); and
(d) any other personal information that you choose to send to us.
2.2 Before you disclose to us the personal information of another person, you must obtain that person's consent to both the disclosure and the processing of that personal information in accordance with this policy.
3. Using personal information
3.1 Personal information submitted to us through our website will be used for the purposes specified in this policy or on the relevant pages of the website.
3.2 We may use your personal information to:
(a) administer our website and business;
(b) send you email notifications that you have specifically requested;
(c) send you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter);
(d) send you marketing communications relating to our business which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications);
(e) verify compliance with the terms and conditions governing the use of our website.
3.3 We will not supply your personal information to any third party for the purpose of their or any other third party's direct marketing.
4. Disclosing personal information
4.1 We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy.
4.2 We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.
4.3 We may disclose your personal information:
(a) to the extent that we are required to do so by law;
(b) in connection with any ongoing or prospective legal proceedings;
(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
(d) to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and
5. Retaining personal information
5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.
5.2 Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3 Notwithstanding the other provisions of this Section 5, we will retain documents (including electronic documents) containing personal data:
(a) to the extent that we are required to do so by law;
(b) if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
6. Security of personal information
6.1 We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
6.2 We will store all the personal information you provide on our secure (password- and firewall-protected) servers.
6.4 You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
7. Amendments
7.1 We may update this policy from time to time by publishing a new version on our website.
7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
7.3 We may notify you of changes to this policy by email or through the private messaging system on our website.
8. Third party websites
8.1 Our website includes hyperlinks to, and details of, third party websites.
8.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
9. Updating information
9.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
10. Cookies
10.1 Our website uses cookies. Please see our cookie policy below for details
11. Data protection registration
11.1 We are registered as a data controller with the UK Information Commissioner's Office.
11.2 Our data protection registration number is ZA252064

Website Cookie Policy

1 Introduction
1.1 Our website uses cookies.
1.2 By using our website you consent to our use of cookies in accordance with the terms of this policy. If you want to adjust or remove certain cookies, please see the information below.
2 About cookies
2.1 A cookie is a file containing an identifier (a string of letters and numbers) that we store on your browser or the hard drive of your computer (or other device such as mobile phone) if you agree. The identifier is then sent back to the server each time the browser requests a page from the server.
2.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. We use both session and persistent cookies on our website.
2.3 Cookies do not typically contain any information that personally identifies a user
2.4 Cookies can be used by web servers to identify and track users as they navigate different pages on a website and identify users returning to a website.
3 Analytics cookies
3.1 We use Google Analytics to analyse the use of our website and so that we can improve it for individuals that visit and use it.
3.2 Google Analytics is a web analytics tool that helps website owners understand how visitors engage with their website. Google Analytics customers can view a variety of reports about how visitors interact with their website so that they can improve it.
3.3 Like many services, Google Analytics uses first-party cookies to track visitor interactions as in our case, where they are used to collect information about how visitors use our site. We then use the information to compile reports and to help us improve our site.
3.4 Cookies contain information that is transferred to your computer’s hard drive. These cookies are used to store information, such as the time that the current visit occurred, whether the visitor has been to the site before and what site referred the visitor to the web page.
3.5 Google Analytics collects information anonymously. It reports website trends without identifying individual visitors.
4 Blocking cookies
4.1 You may choose to restrict or block cookies from this website, or indeed any other website, by adjusting the privacy settings within your browser. The help section within your browser should provide you with comprehensive information on how to tailor these settings to your needs. Unless you have adjusted your browser setting so that it will refuse cookies, our website will issue cookies when you navigate to our site.
4.2 Blocking all cookies will have a negative impact upon the usability of many websites.
4.3 If you block cookies, you will not be able to use all the features on our website.
5 Deleting cookies
5.1 You may also choose to delete the cookies already stored on your computer.
5.2 Deleting cookies will have a negative impact on the usability of many websites.
6 General Information about cookies
6.1 For comprehensive information, including how to restrict, block and delete cookies, please visit: http://www.aboutcookies.org