We are committed to respecting your privacy. This notice is to explain how we may use personal information we collect when you:
• ask us to provide a vehicle leasing, fleet management or funding solution for your business or your employer’s business;
• place an order for a vehicle such as an ex-leased vehicle, accessories or parts;
• contact us about a vehicle, accessories or parts you are considering hiring;
• communicate with us about your order or purchase;
• contact us about vehicle maintenance, repair, servicing or warranty work;
• contact us about mobility schemes;
• otherwise make an enquiry or make a complaint; or
• browse our website.
References to we, our or us in this privacy notice are to Fleet Financial Limited registered in Northern Ireland (Company No. 030373). Our registered office is at 62 Boucher Road, Balmoral, Belfast, County Antrim, Northern Ireland, BT12 6LR. The ultimate holding company of Fleet Financial Limited is Lookers plc registered in England and Wales under company number 111876 whose registered office is at Lookers House, 3 Etchells Road, West Timperley, Altrincham, WA14 5XS.
• When you interact with us, particularly when you purchase or hire a vehicle, or purchase accessories, parts or services, you may provide us with personal information about you, such as your name, previous names, address, gender, marital status, date of birth, telephone number, email address, occupation or job title, employee number, payment and financial information, including bank details, your insurance claims history and other insurance data, any criminal convictions for motoring offences and fines for traffic offences, information about your vehicle including service history and your motability details. We may also require information about additional drivers you nominate or next of kin and emergency contact information.
• You may also need to provide us with a copy of identification documents such as your passport, driving licence and/or a utility bill. These documents will include additional personal information about you such as (depending on the nature of the document) your nationality, place of birth, photograph and passport / driving licence number.
• Depending on the nature of our interactions with you, there may be certain essential personal information that we must collect from you so that we can provide you with the information, goods or services that you have requested. This will vary depending on the relationship we have with you.
• For example, if you contact us with an enquiry about a vehicle you are interested in purchasing or are hiring we will need to collect contact details so that we can get in touch with you. If you then decide to place an order for the vehicle we will need to collect additional information so that we can process that order, including your postal address and payment information.
• We may also ask you for additional personal information which it is optional for you to provide but which will allow us to improve the service that we provide to you. For example, you may provide us with additional contact details to make it easier for us to get in touch with you, or with additional information about your circumstances and preferences to allow us to better tailor our services to you.
• We will always aim to make it clear which personal information it is necessary for you to provide and which personal information is optional. However, if you are unsure as to whether you are required to provide any specific personal information please ask.
• Our premises have CCTV for security purposes and the safety of our staff. We may therefore collect CCTV footage of you if you visit our premises.
• We are committed to protecting your privacy, and will only use your personal information in accordance with applicable data protection legislation, including the Data Protection Acts 1998 and 2018 and the General Data Protection Regulation.
• Specifically, we may use your personal information as follows:
¬ to perform our obligations in respect of an order you place, including:
¬ fulfilling any order that you place for a vehicle, accessories, parts or services;
¬ authorising payments;
¬ responding to correspondence you send to us and fulfil the requests you make to us for test drives, brochure requests or information about specific vehicles;
¬ to perform our obligations under our contract with you, including:
¬ the delivery and return of vehicles;
¬ buying back vehicles;
¬ incident management if you or your vehicle is involved and there is loss or damage to the vehicle;
¬ providing breakdown or recovery assistance;
¬ driver license checking;
¬ administering fines, penalties and endorsements;
¬ providing and communicating with your business or your employer about after sale services (such as vehicle support, maintenance and repair services including warranty services);
¬ maintaining guarantee and service records;
¬ management of mileage recording, travel abroad, fuel cards, maintaining guarantee and service records and other vehicle administrative services under our contract with your business or employer;
¬ arranging a short-term hire if there is a need for a relief or hire vehicle for a short period;
¬ providing you with details of your employer’s company vehicle schemes;
¬ complying with your or your employer’s instructions regarding the provision by us of vehicle services;
¬ providing you or your employer with fleet status reports.
¬ where you have expressly consented to us doing so, including:
¬ where you have asked us to enquire about or obtain finance for you to contact brokers and finance companies, to try to find and secure funding on your behalf by introducing you to organisations which provide funding for leased vehicles and assisting you with making an application for finance;
¬ where you have requested that we keep you up-to-date with news, updates, promotions and events, by the types of communication that you have asked us to use;
¬ where you make an enquiry or request any particular information, to respond to that enquiry and provide the requested information;
¬ where you have asked us to arrange a lease of a vehicle with a third party;
¬ where you have asked us to process a change of ownership of your vehicle
¬ where it is necessary to protect your vital interests, including where we need to tell you about a potential safety issue or product recall;
¬ where it is necessary for compliance with legal obligations, including:
¬ for record keeping and regulatory compliance purposes; and
¬ for carrying out checks to prevent money laundering; and
¬ for registering your vehicle with the Driver and Vehicle Licensing Agency
¬ complying with requests from governmental or judicial authorities
¬ where we otherwise have a legitimate interest in doing so, including:
¬ sharing your personal information within the Lookers Group and/or with the manufacturer of a vehicle you purchase, as described in more detail in paragraphs 3 and 4;
¬ verifying the accuracy of information that we hold about you and create a better understanding of you as a customer;
¬ for network and information security purposes so we can take steps to protect your information against loss, damage, theft or unauthorised access;
¬ to comply with a request from you regarding the exercise of your rights;
¬ to inform you of an update to our terms and conditions and policies;
¬ to inform you of a change in our services;
¬ carrying out checks to prevent fraud to protect us from dishonest activity;
¬ handling billing, invoicing and debt recovery;
¬ reminding you about vehicle services and MOTs which are due to ensure you comply with the lease and (where applicable) the continued validity of any warranty, that your vehicle remains safe and legal to drive, and to maintain our customer relationship with you;
¬ reminding you of your options exercisable at the end of a finance agreement;
¬ advising you of options available to you which we believe you will find beneficial during the course of your finance agreement;
¬ informing you about our range of vehicles in your preferred brand including new vehicles;
¬ advising you of vehicle lease renewal and/or special offers
¬ to send you promotional offers which are related to the products and services we provide;
¬ to administer competitions and promotions that you enter with us from time to time and to distribute prizes;
¬ analysing, evaluating and improving our services so that your visit to our website, applications and customer service centre are more useful and enjoyable;
¬ using automated methods to analyse, combine and evaluate information that you have provided to us so that we can deliver the most appropriate customer service to you by tailoring and making relevant all our service and communications (for example, when your mileage suggests your vehicle is due for a service);
¬ undertaking market analysis and market research (including contacting you with customer surveys and otherwise obtaining feedback) to enable us to improve the service we offer and so that we can better understand you as a customer and provide tailored offers, products and services that we think you will be interested in;
¬ ensuring that our website is presented in the most effective manner for you and your computer and tracking your use of our website through the use of cookies and log files to help us to provide a positive user experience and improve and increase usage of our website;
¬ operating a CCTV system on our premises to protect the safety and security of our staff, vehicles and property;
¬ storing phone call recordings and other communications and queries received from you for both quality improvement and staff training purposes.
• The Lookers Group consists of various companies. Where you provide personal information to one company within the Lookers Group it may be shared with other companies within the Lookers Group. This is in our legitimate interests to enable us to operate our Group effectively and to enable us to provide you with an efficient service.
• Details of the Lookers Group are contained in the Appendix.
• We work closely with a variety of different vehicle manufacturers and suppliers to bring you a wide range of vehicles to choose from.
• Your personal information will in the first instance be collected by us, and will be used for the purposes described in paragraph 2. We will also share your personal information with the manufacturer to be used for purposes such as recalls and market analysis.
• In addition, where you have provided your consent, the manufacturer may use the personal information that you have provided to us to send you marketing communications (we may ask you for consent on the manufacturer's behalf and where we do so we will pass your preferences, including any changes to these preferences, onto the manufacturer).
• We share your personal information with the manufacturer because:
¬ it is in our legitimate interest to do so, as we are required to do so by the terms of our agreement with the manufacturer and to maintain our on-going relationship with the manufacturer;
¬ it is required to fulfil your order or other transaction, handle complaints or provide you with a service or information that you have requested;
¬ it is in the manufacturer’s legitimate interest to have that information, to enable it to communicate important information to you, better understand customer demographics and requirements and (where you have agreed to receive marketing communications) to send you information that it believes may be of interest to you; and
¬ it is also in your interest that we share your personal information with the manufacturer, so that you can receive important safety information and other relevant communications.
• The manufacturer has its own responsibilities to you for any use it makes of your personal information and will have its own privacy notice which will provide you with more information about how the manufacturer uses your personal information. You can contact the manufacturer directly if you require more information about how the manufacturer will use your personal information or if you want to exercise any of your rights in respect of the manufacturer's use of your personal information.
• We may also share your personal information with:
¬ a finance provider and/or broker for the purposes of investigating the options available to you, obtaining a proposal and putting that finance agreement in place including, if you are a director of a corporate customer of ours, so the finance provider can complete credit and fraud checks if appropriate;
¬ a third party providing value added services to you such as:
¬ an insurance provider;
¬ service, maintenance and repair providers;
¬ roadside assistance service providers including breakdown and recovery providers;
¬ customer contact centres;
¬ mobility and car hire providers;
¬ any party you have given us permission to speak to (such as a relative or friend), your motor insurance company and other people and companies associated with you
¬ accident and incident management providers;
¬ financial organisations, banks and credit brokers;
¬ credit reference agencies;
¬ driving licence checking providers;
¬ governmental and regulatory authorities;
¬ providers of outsourced services, such as
¬ hosting and IT support or maintenance services and IT security (to the extent necessary for the provider to provide those outsourced services to us);
¬ direct marketing communications agencies and consultants;
¬ market research and market analytics service providers;
¬ legal, accountancy, auditors and other professional advisers;
¬ data storage and destruction companies;
