For the purposes of the Data Protection Act (‘DPA’), we are the company who is responsible for, and controls the processing of, your personal data often called” The Data Controller’.
This Policy was last updated in March 2019 and takes account of the General Data Protection Regulation (GDPR) reform effective from May 2018.
All staff members are trained in the importance of data consent and your private and security is key to how we operate our business.
We act as a credit intermediary and undertake several financial tasks that relate to consumer credit. Under GDPR we define that the basis for processing your personal data is done so under a Legitimate Interest - Article 6(1)(f) – “the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.”
Contact & Communication
Users contacting this website and/or its owners do so at their own discretion and provide any such personal details requested at their own risk. Your personal information is kept private and stored securely until a time it is no longer required or has no use, as detailed in the European General Data Protection Regulations (GDPR). Every effort has been made to ensure a safe and secure form to email submission process but advise users using such form to email processes that they do so at their own risk. We are registered with the Data protection agency for your added peace of mind.
This website and its owners use any information submitted to provide you with further information about the products / services they offer or to assist you in answering any questions or queries you may have submitted. This includes using your details to subscribe you to any email newsletter program the website operates but only if this was made clear to you and your express permission was granted when submitting any form to email process. Your details are not passed on to any unauthorised third parties and we will not sell or otherwise disclose any personal data provided to us to any other party.
Where we request data is collected we take your privacy seriously and will only use your personal information to administer your account and to provide the products and services you have requested from us. We will only contact you if you consent to us contacting you and will always ask for this purpose to say how you would like us to contact you:
- Text message
- Automated call
Personal Data being collected
What data is being collected and processed?
We will obtain personal data about you for you to use our services and to enter into agreement with Total Vehicle Leasing. We will collect, store and use elements of your personal data for the purposes of the finance related enquiry. The processing of this personal data is a contractual requirement and is necessary by us to administer your account and to provide the products and services you have requested from us. If you submit an online finance enquiry you will be required to agree to the terms of this Policy. If you fail to provide this consent and/or personal data, this may mean we will be unable to execute the contract and will result in termination of our services.
When engaging Total Vehicle Leasing at various times you will usually need to disclose to us the following:
• first name(s), surname or company name (including representation as the case may be)
• address (street, street number, postal code, city and country/region)
• email address
• date of birth
• telephone and mobile number
• employment details (employer name, employer address, employment history)
• monthly income and expenditure
• bank details (account number, account holder and card number)
• VAT ID number (as the case may be)
We will also monitor, record, store and use any telephone, email or other electronic communications with you for training purposes so that we can check any instructions given to us and to improve the quality of our customer service.
We will use the personal data you disclose to us for the purposes described in Our Terms.
These purposes include:
• to help us in dealing with your enquiries and help in obtaining the services which you require;
• to assist us identify you and any accounts that you hold with us;
• credit reference agencies (to propose you for vehicle finance);
• the finance provider (to produce the finance agreement);
• research, statistical analysis and behavioral analysis to customize our website
• customer profiling and analysing your preferences;
• fraud prevention/detection including security vetting;
• the supplying dealer group (to order and deliver the vehicle)
• billing and delivery
• to notify you of any changes to our website or to our services which may affect you;
• improving your experience and our services.
Information about other individuals
If as part of our process you give us information about others, you will be asked to confirm that the other third-party person has appointed you to act on his/her behalf. This is required where others are concerned if you ask another person to act on your behalf as a third party.
Under this third party authorisation, the other person can:
• Give consent on his/her behalf to the processing of his or her personal data for the purposes and reasons set out in this Policy; and
• Receive on his/her behalf any data protection notices.
Such third party authorisation will remain in place until this has been revoked, either by verbal or written communication.
Is my Data Stored Securely?
We safeguard personal data by storing it on a secure server protected by password and firewall. We use the most up-to-date firewall systems to provide the best possible protection for your data. Our website, as well as our internal Customer Intelligence System (CIS) is encrypted using a SSL/TSL (Secure Sockets Layer/ Transport Layer Security) connection.
SSL is an industry standard and is used by millions of websites in the protection of their online transactions with their customers. We use all reasonable efforts to safeguard such personal data but you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data which are transferred from you or to you via the internet.
This complies with recent legislation requirements for websites to obtain explicit consent from users before leaving behind or reading files such as cookies on a user’s computer / device.
For more information on the usage of cookies by Google Analytics please see the Google website.
The following data is collected and stored by Total Vehicle Leasing until its automated deletion:
• IP address of the accessing computer/device
• Date, time and duration of your visit
• Name and URL of the accessed pages
• Identification data of the browser and operating system used
• Website from which the data was accessed
The nature and content of the information collected differs by cookie type, as does the length of time for which this data is retained. We will ensure that this retention period is not excessive and is only retained for the period that is necessary for the purpose for which it was collected.
Although this website only looks to include quality, safe and relevant external links, users are advised adopt a policy of caution before clicking any external web links mentioned throughout this website.
The owners of this website cannot guarantee or verify the contents of any externally linked website despite their best efforts. Users should therefore note they click on external links at their own risk and this website and its owners cannot be held liable for any damages or implications caused by visiting any external links mentioned.
Social Media Platforms
Communication, engagement and actions taken through external social media platforms that this website and its owners participate on are custom to the terms and conditions as well as the privacy policies held with each social media platform respectively.
Users are advised to use social media platforms wisely and communicate / engage upon them with due care and caution regarding their own privacy and personal details. This website nor its owners will ever ask for personal or sensitive information through social media platforms and encourage users wishing to discuss sensitive details to contact them through primary communication channels such as by telephone or email.
This website may use social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account.
How long will the data be stored for?
Total Vehicle Leasing take steps where relevant to erase any personal data that is no longer necessary for the purposes for which it is collected or where you have withdrawn consent for its processing and retention.
We will normally store the data for period of six years for compliance with our general legal obligations and for the exercise or defence of any legal claims. This six-year period satisfies the requirement of our regulator, The Financial Conduct Authority who we are authorised by and is also in line with other financial industry retention periods.
Under the General Data Protection Regulation (GDPR) reform you have the right to ‘block’ or request the deletion or removal of personal data to prevent further processing.
This right to erasure is also known as ‘the right to be forgotten’. There are specific circumstances in which you can request the deletion or removal of personal data examples are:
• Where the personal data is no longer necessary for the purposes for which it is collected or otherwise processed
• Where you withdraw consent
• When you object to the processing and there is no overriding legitimate interest for continuing the processing
• Where the personal data was unlawfully processed (i.e. otherwise in breach of the GDPR)
Right of Access to your data
You have the right to obtain from Total Vehicle Leasing confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, access to the personal data and the following information:
- the purposes of the processing
- the categories of personal data concerned
- the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations
- where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period
- the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing
- the right to lodge a complaint with a supervisory authority
- where the personal data are not collected from the data subject, any available information as to their source
- the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject
Where personal data are transferred to a third country or to an international organisation, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer.
- The controller shall provide a copy of the personal data undergoing processing.
- For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs.
- Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.
- The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others.
Rectifying or updating personal data
If you believe the personal data we hold about you is inaccurate, incomplete or requires a change, you have the right to rectification. If possible, we will inform any third parties to whom we have disclosed the personal data in question, so they can rectify their records.
We will typically respond to your request within one month.
We always aim to provide you with the highest standard of service but if there is any occasion where for whatever reason you are disappointed with the services which we have provided or have a specific query in relation to or arising out of any contract between you and us then you may contact us via:
(a) write to us at; FAO Customer Services Manager, Total Vehicle Leasing Ltd, Suite 5, St Anne’s House, 1 Old Market Place, Knutsford, Cheshire WA16 6DP citing ‘Queries’ as the reference;
(b) email us at firstname.lastname@example.org or
(c) call us on 01565 65 66 66