Photolease Limited is committed to protecting and respecting your privacy.
This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting our website you are accepting and consenting to the practices described in this notice.
For the purpose of the European Data Protection Regulations (‘GDPR’) and the Data Protection Act 2018 (the Act)
This Privacy Statement explains how we process your information and your rights under both DPA and GDPR.
Information we may collect from you
We may collect and process the following data about you:
Information you give us whilst making an application will typically include your name, home address, date of birth, contact details, company name, company trading address. We may also request bank statements and company accounts.
Information we collect and receive about you is from credit reference agencies, Companies House, Land Registry and other publically available sources of information.
Credit Reference Agencies have produced a standard Credit Reference Agency Information Notice (CRAIN) which sets out how data will be processed. CRAIN is GDPR compliant and has been shared with the Information Commissioner’s Office (ICO). More information is available at: www.experian.co.uk/crain.
Uses made of the information
We use information held about you in the following ways:
Information you give to us. We will use this information to underwrite your finance application, manage your account with us, contact you when necessary and for marketing communication if you have opted in to receive this
Information we collect and receive from other sources. We may combine this information with information you give to us and information we collect about you. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive).
Disclosure of your information
We may share your personal information with:
- Experian Credit Reference Agency – to provide credit searches
- Anchor Computer Systems – to manage your finance agreement through-out its lifecycle
- Aquis Insurance – to ensure suitable protection of the asset financed
- BACS Payment Schemes – to call direct debits on customer bank accounts
We may share your information with selected third parties including:
- Business partners, suppliers and sub-contractors for the performance of any contract we enter into with [them or] you, including without limitation any data processor we engage.
- Analytics and search engine providers that assist us in the improvement and optimisation of our site.
We may disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
Where we store your personal data
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
You have the right to ask us not to process your personal data for marketing purposes. We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at firstname.lastname@example.org.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Your rights under Data Protection Law
We operate under the Data Protection Act 2018 (‘DPA’) and the European General Data Protection Regulation (‘GDPR’).
The DPA and GDPR apply to ‘personal data’ we process and the data protection principles set out the main responsibilities we are responsible for.
We must ensure that personal data shall be:
a) processed lawfully, fairly and in a transparent manner;
b) collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
d) accurate and where necessary kept up to date;
e) kept for no longer than is necessary for the purposes for which the personal data are processed. We operate a data retention policy that ensures we meet this obligation. We only retain personal data for the purposes for which it was collected and for a reasonable period thereafter where there is a legitimate business need or legal obligation to do so. For detail of our current retention policy contact our privacy officer at email@example.com.
f) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
We ensure lawful processing of personal data by obtaining consent; or where there is a contractual obligation to do so in providing appropriate products and services; or where processing the data is necessary for the purposes of our legitimate interests in providing appropriate products and services.
In the majority of cases we process personal data based on your contract with us. In other cases, we process personal data only where there are legitimate grounds for so doing.
To meet our Data Protection obligations, we have established comprehensive and proportionate governance measures.
We ensure data protection compliance across the organisation through:
a) implementing appropriate technical and organisational measures including internal data protection policies, staff training, internal audits of processing activities, and reviews of internal HR policies.
b) maintaining relevant documentation on processing activities.
c) implementing measures that meet the principles of data protection by design and data protection by default including data minimisation, pseudonymisation, transparency, deploying the most up-to-date data security protocols and using data protection impact assessments across our organisation and in any third party arrangements.
Under the GDPR You have the following specific rights in respect of the personal data we process:
- The right to be informed about how we use personal data.
This Privacy Statement explains who we are; the purposes for which we process personal data and our legitimate interests in so doing; the categories of data we process; third party disclosures; and details of any transfers of personal data outside the UK.
- The right of access to the personal data we hold. In most cases this will be free of charge and must be provided within one month of receipt.
- The right to rectification where data are inaccurate or incomplete. In such cases we shall make any amendments or additions within one month of your request.
- The right to erasure of personal data, but only in very specific circumstances, typically where the personal data are no longer necessary in relation to the purpose for which it was originally collected or processed; or, in certain cases where we have relied on consent to process the data, when that consent is withdrawn and there is no other legitimate reason for continuing to process that data; or when the individual objects to the processing and there is no overriding legitimate interest for continuing the processing.
- The right to restrict processing, for example while we are reviewing the accuracy or completeness of data, or deciding on whether any request for erasure is valid. In such cases we shall continue to store the data, but not further process it until such time as we have resolved the issue.
- The right to data portability which, subject to a number of qualifying conditions, allows individuals to obtain and reuse their personal data for their own purposes across different services.
- The right to object in cases where processing is based on legitimate interests, where our requirement to process the data is overridden by the rights of the individual concerned; or for the purposes of direct marketing (including profiling); or for processing for purposes of scientific / historical research and statistics, unless this is for necessary for the performance of a public interest task.
- Rights in relation to automated decision making and profiling.
Please contact our privacy officer at firstname.lastname@example.org for more information about the GDPR and your rights under Data Protection law.
If you have a complaint about data protection at Photolease Ltd contact our privacy officer at email@example.com.
Alternatively contact our supervisory authority for data protection compliance (www.ico.org.uk): Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF
Tel: 0303 123 1113 (local rate) or 01625 545 745 (national rate)
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