11 April 2012

At SG Fleet we take privacy seriously and we are committed to protecting it. This policy explains when and why we and companies in or group collect personal information about individuals, how this information is used, the conditions under which it may be disclosed to others and how it is kept secure.

This policy may change from time to time so please check this page occasionally to ensure that you’re happy with any changes.

1. WHO WE ARE

SG Fleet UK Limited is part of the SG Fleet group of companies which offer a range of services, principally fleet management, leasing, employment benefit and vehicle tracking services.

Whenever dealing with one of our group companies, the relevant company is the data controller of your personal information in relation to the processing activities described below. A “data controller” is an organisation that decides why and how your personal information is processed.

Where this policy refers to “we”, “our” or “us” below, unless it mentions otherwise, it’s referring to the particular company that is the controller of your personal information.

2. THE PERSONAL INFORMATION WE COLLECT

Personal information is information or an opinion relating to an identified individual, or an individual who can be identified (directly or indirectly), whether the information or opinion is true or not; and whether the information or opinion is recorded in a material form or not. Personal information includes information such as your name, age, driver’s licence or contact details.

You may provide us with your personal information where you enter your personal information in a form on our website, engage with us in respect of our vehicles, products or services, or correspond with us by phone, email or otherwise or complete an application. It is provided entirely voluntarily. The information you give us may include:

    • your name, address, phone number, email address and other contact details, date of birth, gender and marital status;
    • employment related information such as your profession, occupation or job title, employer and payroll information;
    • banking or credit card details;
    • financial information and supporting documentation;
    • identification information (including information regarding your driving licence);
    • transaction history information;
    • legal proceedings;
    • vehicle-related information such as your driver’s licence, driving speeds, patterns and locations, fuel fills and purposes of travel;
    • personal references; and
    • details about your enquiry or any contract with you.

We may also ask you for information about your vehicle and information about your driving history including information about insurance policies or claims.

We may also be required to collect your name, address, date of birth and other verification information to comply with the requirements of the Proceeds of Crime Act 2002 and the Money Laundering Regulations 2007 and we will be using a third party provider to conduct verification searches using this information.

We may automatically collect technical information about you including anonymous data collected by our hosting server for statistical purposes, the Internet protocol (IP) address used to connect your computer or device to the internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform. We may also collect information about your vehicle and/or its location through our tracking services.

We may receive information about you from third parties in connection with our vehicles, products or services. For example, we may:

    • collect information about you from your employer or an introducer in order to provide you with a leased vehicle under an employee benefit scheme;
    • check your details with credit reference or fraud protection agencies and government registers and agencies in connection with any finance or credit application (See Credit Reference Agencies and Fraud Prevention below );
    • collect information from finance providers, service providers including fuel suppliers, insurance providers, maintenance providers, accident management or roadside assistance suppliers;
    • collect information from credit reporting bodies and other credit providers who have provided credit to you;
    • collect information from persons who know you including persons to whom you are financially linked; and
    • collect information from publically available or other sources to check that you hold a valid driving licence or verify any of the information that you give to us.

What happens if we can’t collect your personal information?

If you choose not to provide personal information, some or all of the following may happen:

    • we may not be able to provide you with the products and services that you require;
    • we may not be able to provide you with information about our products and services; or
    • we may be unable to tailor the content of our websites to your preferences.

3. HOW WE USE YOUR PERSONAL INFORMATION

The purposes for which we use your information and the legal basis under data protection laws on which we rely to do this are explained below.

Where it is required to complete a CONTRACT: We may use and process your personal information where we have supplied you (or continue to supply you) with a vehicle or any other products or services, (including those of a third party), or where you are in discussions with us about this and to provide you with access to protected areas of our website. We will use your information in connection with the contract for the supply or lease of the vehicle, products or service.

Where it is in your VITAL INTEREST: Where we have supplied you with any a vehicle, or any other product or service, we may use your personal information to contact you if there are any urgent safety or product recall notices to communicate to you or where we otherwise reasonably believe that the processing of your personal information will prevent or reduce any potential harm to you.

Where there is a LEGITIMATE INTEREST: We may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business, or that of a third party, including for the following purposes:

    • for marketing activities (other than where we rely on your consent to contact you by email or text as explained in Marketing section below);
    • for analysis to inform our marketing strategy, and to develop, improve and market our products and services generally;
    • to assess, enhance and personalise your customer experience and the operation of our website;
    • to verify the accuracy of data that we hold about you and create a better understanding of you as a customer including your purchasing preferences;
    • to assess the suitability of our products and services for you including the making of credit decisions and assessments about you which may involve credit scoring and to decide whether to provide you with products and services on credit (i.e. where you pay for these products and services after we supply them to you);
    • for network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access;
    • for prevention of fraud and other criminal activities;
    • in connection with debt recovery (including to trace your whereabouts to recover debts);
    • to comply with a request from you 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 lists in order to be able to comply with your request);
    • to assess and improve our service to customers through recordings of any calls;
    • for the management of queries, complaints, or claims;
    • where a third party has introduced your custom to us, we may pass back to the third party the necessary information to enable administration of any payment or settlement; and
    • for the establishment and defence of our legal rights.

Where there is a LEGAL REQUIREMENT: We will use your personal information to comply with our legal obligations including: (i) to assist the Driver and Vehicle Licensing Agency, HRMC, the ICO or other public authority or criminal investigation body; (ii) to identify you when you contact us; or (iii) to verify the accuracy of data we hold about you or perform our obligations under relevant data protection laws.

Where you have provided CONSENT: We may use and process your personal information where you have consented for us to do so:

    • in order to verify that you hold a valid driving licence;
    • in order to process any special categories of personal data (see Special Categories of Personal Data for further details); and
    • where necessary in relation to our marketing activities (see Marketing for further details).

You may withdraw your consent for us to use your information in this way at any time. Please see Withdrawing your consent for further details. Note that if you withdraw your consent to us processing certain data in connection with our vehicles, products or services, we may not be able to continue to provide you with them.

4. SPECIAL CATEGORIES OF PERSONAL DATA

From time to time, we may collect information about special categories of data, such as in relation to:

    • any health condition or disability; and
    • any driving offences, fines or fixed penalty notices.

We will only collect or use this information with your consent. We may use and share this information in connection with services on your behalf, such as:

    • obtaining insurance cover; or
    • dealing with any the management of fines or fixed penalty notices.

5. CREDIT REFERENCE AGENCIES AND FRAUD PREVENTION

When you apply to us for a vehicle, we will check our own records about you and your business partners.  We will also check the business records of you and your business partners at credit reference agencies (CRAs) and at fraud prevention agencies (FPAs).  When CRAs receive a search from us they will place a search footprint on your business credit file that may be seen by other lenders.  CRAs supply to us public (including electoral register) and fraud prevention information.  We will make checks such as assessing this application and verifying identities to prevent and detect crime and money laundering.  We may also make periodic searches at CRAs and FPAs to manage your account with us.

Information on applications will be sent to CRAs and will be recorded by them.  Where you hire from us, we will give details of your accounts and how you manage it/them to CRAs.  If you do not make payments in full and on time, CRAs will record the outstanding debt.  This information may be supplied to other organisations by CRAs and FPAs to perform similar checks and to trace your whereabouts and recover debts that you owe.  Records remain on file for 6 years after they are closed, whether settled by you or defaulted.

If you give us false or inaccurate information and we suspect or identify fraud we will record this and may also pass this information to FPAs and other organisations involved in crime and fraud prevention.

You find out more information by contacting the CRAs currently operating in the UK. The information they hold may not be the same so it is worth contacting them all.  They will charge you a small statutory fee.

6. DATA ANONYMISATION AND USE OF AGGREGATED INFORMATION

Your information may be converted into statistical or aggregated data in such a way as to ensure that you are not identified or identifiable from it. Aggregated data cannot be linked back to you as a natural person. We may use this data for analytical and research purposes.

7. OTHERS WHO MAY RECEIVE OR HAVE ACCESS TO YOUR PERSONAL INFORMATION

We may disclose your personal information to:

    • our contractors (these individuals have a responsibility to keep your information confidential);
    • insurers, financiers and rating agencies, and their financier group companies, contractors or other third party service providers (particularly in the provision to you of products and services involving insurance and finance we are required to pass your details to insurers and financiers);
    • service providers, such as web site hosting providers, IT system administrators and digital transaction management providers;
    • third parties including government agencies or toll road operators where required or allowed by law or court or tribunal order or in order to register or to protect our interests or to deal with infringements;
    • any party acting on your behalf (e.g. financial advisers, lawyers, or accountants);
    • your employer or your guarantor;
    • suppliers of purchased goods or other persons who have or require an interest in the purchased goods;
    • organisations to whom we outsource functions including professional advisers and collection and mercantile agents; and
    • third party service providers in respect of our products and related services including service providers assisting you with repairs and claims and any person who introduces you to us.

Group companies: We may share your information to our Group companies. Our group companies may use your personal information in the ways set out in this Privacy Policy.

Our suppliers and service providers: When we use third party service providers, we will contract with them to keep your information secure and not to use it other than in accordance with our specific instructions.

Third parties who provide products and services to you: We work closely with various third parties to bring you a range of products and services that are complementary to those that we provide. In particular, we may offer finance or insurance products, or maintenance, repair or recovery services in relation to your vehicle. When you enquire about or purchase one or more of these products or services through us, the relevant third party may use your details to provide you with information and carry out their obligations arising from any contracts you have entered into with them. These third party product providers may share your information with us, which we will use in accordance with this policy. In some cases, they will be acting as a controller of your information and therefore we advise you to read their privacy policy. 

Financial Service Organisations: Your personal data may be shared with financial services organisations and rating agencies for the purpose of the funding, refinancing, sale or securitization associated due diligence and review of the products and related services provided to you. We may provide personal data to enable such financial services organisations to carry out necessary searches in order to enable them to make a funding decision for you and meeting their legal and regulatory requirements. In addition, these funders may share your data within their own group of companies, as well as contractors and other thirds party service providers who provide services to them, and so that they and any other companies in their group can look after your relationship with us and them.

Any funder with whom we share your personal information will use and process this in accordance with its own privacy policy. A list of the funders who may receive your personal information can be viewed here.

Other ways we may share your personal information: We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation. We may also transfer your personal information if we’re under a duty to disclose or share it in order to comply with any legal or regulatory obligation, to detect or report a crime, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our visitors and customers. We also disclose information when required to do so by law, for example under a court order, or in response to properly made demands under powers contained in legislation. We will always take steps with the aim of ensuring that your privacy rights continue to be protected.

8. WHERE WE STORE YOUR PERSONAL INFORMATION

All information you provide to us may be transferred to countries outside the European Economic Area (EEA). By way of example, this may happen where any of our group companies are incorporated in a country outside of the EEA or if any of our servers or those of our third party service providers are from time to time located in a country outside of the EEA. These countries may not have similar data protection laws to the UK.

If we transfer your information outside of the EEA in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this policy. These steps include imposing contractual obligations on the recipient of your personal information or ensuring that the recipients are subscribed to ‘international frameworks’ that aim to ensure adequate protection. Please contact us using the details at the end of this policy for more information about the protections that we put in place and to obtain a copy of the relevant documents.

9. HOW LONG WE KEEP YOUR PERSONAL INFORMATION FOR

If we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws. We do not retain personal information in an identifiable format for longer than is necessary.

We may need your personal information to establish, bring or defend legal claims.  For this purpose, we will always retain your personal information for up to 7 years after the end of your contract with us or the date it is no longer needed by us for any of the purposes listed under How we use your personal information above. The only exceptions to this are where:

    • you make an enquiry with us but do not contract with us for any vehicle, product or service, in which case we will hold your information for no longer than 12 months;
    • the law requires us to hold your personal information for a longer period, or delete it sooner;
    • you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law (see further Erasing your personal information or restricting its processing below); or
    • in limited cases, the law permits us to keep your personal information indefinitely provided we put certain protections in place.  

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to our website and any transmission is at your own risk. Once we have received your personal information, we put in place reasonable and appropriate controls to ensure that it remains secure against accidental or unlawful destruction, loss, alteration, or unauthorised access.

When you log into the secure section of our website we use a secure server. Any data you give us when you are logged into the secure section of our website, is encrypted using a Secure Socket Layer (SSL) session. SSL is an industry standard and is one of the best ways to ensure Internet messages are not intercepted. You should be aware, however, that some older browsers cannot use SSL. If your browser does not support 128 bit encryption (or higher) you will not be able to log into or use our secure website services.

Our general email enquiry forms are not sent via an encrypted channel and for this reason we ask that you do not include confidential information or sensitive personal information when using them.

While we use SSL encryption to protect user information online, we will use all reasonable endeavours to protect user information off-line. However, any personal details or other information entered onto or submitted through the site or by email to us is entered or transmitted at the user's risk and we shall not be liable for any such information being intercepted or accessed by any third party without our knowledge.

If you have given us permission to conduct business with you by electronic means then your personal information may be stored by our third party document handler, DocuSign but for no longer than 6 months

Where we have given (or where you have chosen) a password which enables you to access an account, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Our website may contain links to other websites run by other organisations. This Privacy Policy does not apply to those other websites‚ so we encourage you to read their privacy statements. We cannot be responsible for the privacy policies and practices of other websites even if you access them using links that we provide. Further, if you linked to our website from a third party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party website and recommend that you check the policy of that third party website.

11. USE OF COOKIES

Cookies are small data files that are placed onto the hardware device which you use to browse the internet (e.g. your computer, smartphone or tablet) by websites that you visit. Cookies contain information about your visits to that website and the purpose of cookies is to enable our websites to remember you, and your browsing habits, when you visit it again in the future.

We may work with third parties to research certain usage and activities on our website.  No personal information about you is shared except to the extent it is required to be used by a third party or parties for providing such research, and in the course of conducting this research we, and these third parties may place a unique "cookie" on your browser.

We use cookies to gather information on IP addresses, to analyse trends, administer the site, track users' movements on the site and gather broad demographic information for aggregate use.  IP addresses are not linked to other personally identifiable information and will not be used to deliver targeted marketing messages.

If our website requires you to register or login to gain access to the website, cookies are used to assist in this process. Cookies are used as part of the registration process, they are also used to store the username while the user is logged into the site and to track the number of times the user has tried to log in during a single visit.

For information about blocking the use of cookies, please refer to the instructions/help screen on your Internet browser.  Please note that you may not be able to use or access certain parts of the website or online services if you block the use of cookies.

12. MARKETING

We may collect your preferences to receive marketing information directly from us by email in the following ways:

    • if you register an account with us online, we will ask you if you would like to provide your consent to receive marketing information directly from us by email or other electronic means; or
    • if you make an enquiry or place an order for a vehicle, product or service, we may contact you by email or other electronic means with marketing information about similar vehicles, product or services, except where you indicate you would prefer otherwise as set out below.

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.

We may contact you with targeted advertising delivered online through social media and platforms operated by other companies by using your personal information, or use your personal information to tailor marketing to improve its relevance to you, unless you object.  

We will only share your information with our Group of Companies and third party partners for them to contact you with marketing information about their products and services where you have indicated that you would like us to do so. Once shared, the relevant third party’s privacy policy will apply to their processing of your personal information, not ours. If you’d like to opt-out of receiving marketing from a third party after providing your consent, you can do so at any time by contacting the relevant third party directly.

You have the right to opt-out of our use of your personal information to provide marketing to you in any of the ways mentioned above. Please see Withdrawing your consent and Objecting to our use of your personal information above for further details on how you can do this.

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