Privacy policy

1 OUR PRIVACY POLICY

1.1 Welcome to our privacy policy. We respect your privacy and are committed to protecting your personal data. This privacy policy explains how we collect and process your personal data through your use of our website, incoming call, or other channels, including any data you may provide through our website when you sign up for our marketing communications or engage us to provide services to you. It also informs you about how we look after your personal data when you visit our website (regardless of where you visit it from), call us or contact us from other channels and tells you about your privacy rights and how the law protects you.

2 WHO WE ARE

2.1 For the purpose of the UK General Data Protection Regulation and the Data Protection Act 2018, the data controller is Select Contracts (UK) Limited trading as Select Car Leasing (“Select Car Leasing”).

2.2 This privacy policy also applies to our appointed representatives who trade as Select Car Leasing, so when we refer to "we", "us" or "our" in this privacy policy, we are referring to the relevant data controller. Please contact our compliance team if you would like more information as to which entity is acting as data controller in relation to your personal data.

2.3 We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact our DPO using the details set out below.

2.4 Our website is not intended for children, and we do not knowingly collect data relating to children.

2.5 It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

3 CONTACT DETAILS

3.1 If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

3.1.1 Email address: dataprotection@selectcarleasing.co.uk

3.1.2 Postal address: Pacific House, Imperial Way, Reading, RG2 0TD.

3.1.3 Telephone number: 0118 920 5130.

3.2 You have the right to make a complaint at any time to the Information Commissioner's Office (or ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

4 CHANGES TO THIS PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

4.1 We keep our privacy policy under regular review.

4.2 This version was last updated on date set out at the bottom of this privacy policy.

4.3 It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

5 THIRD-PARTY LINKS

5.1 Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit .

5.1.1 We use Adobe Echo Sign for electronic signatures: Adobe Echo Sign does not store the information contained on the document and we don’t send this information on to Adobe. Customers are sent a document through our CRM system, which is then sent to Adobe’s EchoSign platform

5.1.2 We require anyone leasing a vehicle from us to complete a credit check. This will be instigated by our credit check partner, Creditas. As such you will use their website and systems to complete this. Please see their website for more information about how they use your data.

5.1.3 We are currently working with a energy supplier OVO, to offer free charging miles on a selected number of vehicles. To redeem this offer, you will have to visit their website. Please see their website for more information about how they use your data.

6 BVRLA INSPECTIONS

6.1 As a member of the British Vehicle Rental and Leasing Association (BVRLA), we are routinely audited to make sure we uphold the highest standards and comply with Financial Conduct Authority regulations. The BVRLA will not hold any 'customer' data, however they use a third party 'Product Partnership' to conduct the inspection programme. They use a secure portal for the uploading of 'customer files' (required as part of their inspection), which comply fully with data privacy retention rules.

7 VEHICLE RESERVATIONS AND CANCELLATIONS

We may use a programme called Airtable to process any vehicle reservations and cancellations. This would hold a limited amount of your personal data, to allow us to process these. If you would like to know more about what information we hold on this platform, please contact dataprotection@selectcarleasing.co.uk.

8 REVIEWS AND VEHICLE REVIEW INVITATIONS

8.1 You may receive emails from us asking you to give us reviews on TrustPilot, Google, Facebook or other platforms because you are our customer and/or you have previously completed a review for us. Please refer to the privacy policies of these websites for information about how they process your personal data.

8.2 If you are a customer of Select Car Leasing, we might contact you to ask you to review your vehicle with us. By writing a review for us you agree to us publishing this on our website. Should you wish to make your review anonymous please contact marketing@selectcarleasing.co.uk

9 AGGREGATOR WEBSITES

9.1 We promote some of our deals on aggregator websites, where you are asked to give us your details on a form on their website. These details get sent to us to register your enquiry. Please review the privacy policy on each the aggregator website for details about how the aggregator processes your personal data.

9.2 We currently work with a aggregator Carwow. We will send them any orders from our Carwow enquiries. This is data Carwow already have. This is for us to benefit from performance based discounts and to allow Carwow to ask them for reviews of us. We will send them only the email address, order date, postcode and make and model of the vehicle.

10 CAP HPI VEHICLE DATA

We derive our vehicle data from CAP HPI.

CAP HPI data and software is protected by copyright and database rights. All rights reserved.

As such, as a visitor to our website you are subject to the following terms:

- You are not permitted to use CAP HPI vehicle information from our website for personal or commercial purposes

- You are not permitted to mass extract or re utilise CAP HPI vehicle information from our website

- CAP HPI have the right enforce any breach of their terms directly against a individual website visitor

- You understand that the vehicle valuations from CAP HPI are provided “as is” and no warranties are given in relation to these valuations

11 PERSONAL DATA WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

11.1 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data) or data associated with an individual which in isolation would not allow a person to be identified.

11.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

11.2.1 Identity Data which includes first names and surnames, title, date of birth, country of birth, no. of adults living in the household, job title (current and previous), driving license no., nationality, gender, marital status and number of dependents .

11.2.2 Contact Data which includes previous and current address (and length of time at that address), property status, email address and telephone number. Where you make an online enquiry it also includes details of how you contacted us, for example via a clickthrough advert appearing in a Google (this is tracked using Google ID and GCLID) or Bing search or via social media (such as Facebook, Twitter, Instagram, LinkedIn, Google My Business ).

11.2.3 Financial Data which includes credit/loan information, income/tax information, property finance information, expenditure information, employment status (for current and previous employer), bank account and payment card details .

11.2.4 Transaction Data which includes details of your enquiry, your vehicle order and credit application and other details which you give us during the period of your vehicle lease. Where you are contacting us in a business capacity we will also collect other non-personal information such as the size of your fleet.

11.2.5 Technical Data which includes internet protocol (IP) address, GA4 data (including however not limited to sessions, users, time on page), date and time of IP address registration, browser type and version, time zone setting and location, the date and time your access our website, server log files, Google tags (Google ID and GCLID), the internet service provider of the accessing system, access browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website. If you visit our website via a referral website, we will also collect information about the referral website. We also collect other technical data and information which is collected and used in the event of an attack on our information technology systems .

11.2.6 Profile Data which includes:

(a) the data we collect from you in consequence of you logging into our customer account portal (such as your username and password , your vehicle order and queries concerning your order and also related identity data and contact data)

(b) data from your enquiries and your transactions with us (including, however not limited to: proof of address, passport, utility bill, bank statements, driving licence type and your business activities)

(c) data from companies including, but not limited to, Meta (Facebook and Instagram), Alphabet (Google) and LinkedIn

This may include information such as your age and gender, information about the vehicle(s) you are interested in, your budget, how often you have made enquiries, the type of organisation you come from and the size of the organisation’s fleet.

(d) Age data: we only use banded age ranges for marketing purposes

(e) Gender data: we will not use this for marketing purposes

11.2.7 Marketing and Communications Data which includes information about your preferences in receiving marketing from us and your communication preferences.

11.3 Most of the personal data listed above is collected directly from you, for example when you fill in forms on our website (either hosted by us or on marketing software, including however not limited to, Hubspot), or correspond with us by post, SMS, app based communication or messenger services (e.g. WhatsApp messenger and Facebook messenger), phone or email, or create an account on our customer account portal, or subscribe for our marketing communications, or enter a competition, or complete a survey, or give us feedback.

11.4 We may also receive information from third parties (such as credit reference agencies) or publicly available sources (such as Companies House and the Electoral Register) but we will only do so to the extent that this directly relates to your proposed order/transaction, e.g. to verify or expand the information you have provided to us.

11.5 We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate data about your usage of our website to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

11.6 We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. We will only confirm whether you have a criminal conviction or not, when you have a credit check.

12 IF YOU FAIL TO PROVIDE DATA

12.1 Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel the contract for our services but we will notify you if this is the case at the time.

13 NEWSLETTER TRACKING

13.1 Our email newsletters contain tracking pixels. A tracking pixel is a miniature graphic embedded in emails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of our online marketing campaigns. Based on the embedded tracking pixel, we may see if and when you open our marketing emails and which links within them you clicked on. We will not share this information in a way which would identify a personal individual with any third parties and only use this information for the purposes stated. If you unsubscribe, we might share this information with third parties, if this is for the purpose of opting you out of marketing communication being sent on our behalf by the third party.

13.2 The personal data we collect via tracking pixels is stored and analysed to optimise the delivery of our marketing emails and to help adapt the content of future newsletters to make them more relevant to you. The personal data we collect this way will not be passed on to third parties.

14 COOKIES

14.1 As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

14.2 You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly.

14.3 For more information about the cookies we use, please see our cookie policy below.

15 HOW WE USE YOUR PERSONAL DATA

15.1 We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

15.2 Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

15.3 Automated Personalisation

We are using automated personalisation, to improve our marketing to you, to make sure you receive the most relevant communications from us.

We perform this using different variables, including but not limited to: vehicle, demographic, budget, organisational and location information and the information about the office you enquired with.

The data is only used for marketing purposes, so there are no significant consequences of us processing your data in this way. We have appropriate safeguards in place, as detailed in section 15.

You have the right not to be subject to a decision based solely on automated processing, including personalisation, which produces legal effects or similarly significantly affects you. If you have any concerns about how we use your data, then please contact our Data Protection Officer and we will make sure your data is no longer used for this purpose.

Unfair processing happens when this is deemed to discriminate against certain people; for example, resulting in them being offered costly or risky deals. It is an example of a significant effect. Whether the automated personalisation has a legal or significant impact depends on: 

• the intrusiveness of the automated personalisation process 

• the expectations and wishes of the individuals concerned 

• the way the marketing communication is delivered 

• the particular vulnerabilities of the data subject.

There are several caveats where this would not apply (based on consent and legitimate interest), please see these below: 

Automated decision-making that produces a legal or similarly significant effect is prohibited, unless it is done with an individual’s explicit consent. This processing is prohibited apart from in three specific instances, when it’s: 

• necessary for the entry into or performance of a contract 

• authorised by Union or Member State law applicable to the data controller 

• based on the individual’s explicit consent. This would need to be separate to consent for marketing.

We are not required to divulge trade secrets or intellectual property regarding how we carry out our automated personalisation.

How we carry out automated personalisation?

Our automated personalisation can take information from a variety of sources to create derived or inferred data. 

We make sure we only automatically personalise the necessary data required for us to send our campaigns, at the time we send the campaign and can not be processed for other reasons. 

We understand this new data is also personal data because it relates to and could identify a living individual. Therefore, we take appropriate safeguards to protect your data, as outlined elsewhere in section 15 of our privacy policy.

We only automatically personalise data for marketing where we have a lawful basis to do so (according to GDPR)

o Automatic personalisation can potentially be carried out using legitimate interests as a lawful basis

o As such, we will not use historic data or financial/credit status information

o The more extensive or intrusive automated personalisation for direct marketing is, the more it is likely to infringe an individual’s rights

- If that is the case, legitimate interests cannot be used as a lawful basis. And as such, we will ask for consent from the individual.

o If consent is explicit for automated personalisation, it can also be relied on to carry out automated personalisation that has legal or similarly significant effects

o However, for large scale automated personalisation or where it is considered to have a high risk legal or significant impact beyond what we think you have consented to, we would complete a Data Protection Impact Assessment.

Using third parties for automated personalisation: 

We may use third parties, such as but not limited to, Mosaic, to personalise our data.

Before carrying out this automated personalisation, we would make sure the data collected was in line with GDPR at source and that they have their own lawful basis to transfer personal data to us.

We will also take steps to make sure the third party has told the people it collects data from what will happen to their data (according to GDPR requirements) and how they can opt out of marketing.

If we re use publicly available personal data, or personal data obtained from a third-party organisation, we will make sure the third party’s privacy notice adequately describes the circumstances in which the data will be further processed. And we will consider whether the further processing is compatible with the original purpose this was collected.

Right to complain: 

You have the right to opt out of processing at any time and this will be implemented immediately, please contact our data protection officer to opt out of automated personalisation.

 16 MARKETING AND OPTING OUT

16.1 We strive to provide you with choices regarding our use of your personal data, particularly around marketing and advertising. By ticking the relevant box on the enquiry form or any of the other forms where we ask you to subscribe to the newsletter, you are agreeing to receive marketing communication from us. We produce regular email newsletters to inform our customers, prospects, and business partners about matters which may be of interest, including but not limited to car, LCV and other automotive product tips, special offers, news and vehicle reviews and relevant news and offers from our automotive and sponsorship partners. We might occasionally also send you a survey, pertaining to your attitudes, behaviour, what content you would like to hear more about and other relevant questions determined by Select Car Leasing. If you have previously unsubscribed, you are allowing us to resubscribe you to the newsletter. We store your details on the password-protected software platform when you agree to receive marketing communications from us. Only people with white listed IP addresses can access the platform.

16.2 We also carry out email marketing (using the email address provided by the recipient), direct mail, telephone (using the telephone number(s) provided by the recipient), SMS/MMS or other digital messages, instant messaging, social media (including Facebook, Twitter, Instagram, LinkedIn and Google My Business - for example, people who have interacted with our adverts previously, lookalike audience campaigns and industry targeted campaigns), Google and Bing Search adverts (including however not limited to Google pay per clickthrough adverts, Bing pay per clickthrough adverts, digital remarketing if you visited our website or leased with us, renewal campaigns, lookalike audience campaigns, campaigns targeted to website behaviour using GA4 data), marketing from third party websites and affiliate websites we might work with, display advertising, social advertising, mobile push advertising, instant messaging or other communication methods.

16.3 The lawful basis we rely on for processing your personal data for marketing purposes is as follows:

16.3.1 You will receive marketing communications from us where you have provided your consent to receive these (for example via our website, during the order process, following contact with us, or in response to a communication from us), or where you have opted in to receiving our marketing communications. We only rely on consent to process your personal data for marketing purposes if it is a freely given, specific, informed and unambiguous indication of your wishes. You can withdraw your consent at any time using the link at the bottom of our communications to you. 

16.3.2 You will receive marketing communications from us if you have requested information from us and you have not opted out of receiving that marketing. If you are a business enquirer or customer (with or without a live enquiry or contract on our systems) and you have given us a email address (i.e. you deal with us in your capacity as a representative of a registered company or other corporate body but excluding sole traders and partnerships), we may contact you regarding our deals and marketing offers (based on the ICO Electronic Mail Marketing guidance, which gives a guide to the Privacy Electronic and Communications Regulation, and is stating that “you can email or text any corporate body”). We will email anyone on the account connected to your business, except if you have unsubscribed. You have the right to opt out of receiving these at any time. 

16.3.3 We might occasionally send a mailer to people who have decided not to go ahead with a lease with us, to ask them if they would like to sign up to receive car, LCV and other automotive product tips, special offers, news and vehicle reviews and relevant news and offers from our automotive and sponsorship partners from us. If someone does not sign up, we will not send them any further marketing communications.

16.3.4 You can opt out at any time using the link at the bottom of our communications to you. As clearly detailed on our website forms, we use ICO and PECR opt in and soft opt in guidance and rules as the basis to send these communications.

16.4 Our “legitimate interest” means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interest. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interest against any potential impact on you in respect of specific activities by contacting us.

16.5 When we rely on the “soft opt-in” for sending marketing communications, we do so in accordance with the ICO’s soft opt in guidance.

16.6 When we ask you for consent, we will make this clear to you and we will keep logged details about when and how you gave us your consent. We may ask for your consent when you sign up for our marketing communications via a form on our website, when you make an enquiry or when you contact our customer services team.

16.7 If you have provided your consent for marketing purposes, the data we collect when you sign up (namely Identity, Contact, Technical and Profile Data as described above and your marketing and contact preferences) will be used only to send you our email newsletters. As part of this we will use your data to form a view on what we think you may want or need, or what may be of interest to you . If you have completed a order online form on our website, we ask for other information from you (namely Financial and Transaction Data), however this will only be used for the credit proposal and will not be used for marketing purposes.

16.8 You may withdraw your consent, or opt-out of receiving our marketing communications (where these are sent on the basis of our legitimate interest), at any time by following the unsubscribe/preference links in any marketing message sent to you or by emailing us at email dataprotection@selectcarleasing.co.uk.

16.9 As part of the process of unsubscribing from our marketing communications, we may need to keep your data to ensure we can unsubscribe you from any subsequent marketing.

16.10 We utilise preference centres to understand which type of email marketing you would like to receive from us. You can access this via the manage preferences link at the bottom of every email marketing we send to you.

16.11 If you have provided us with information which enables us to contact you in a variety of different ways, we will communicate with you in accordance with your preferences and give priority to those means of communication which are most suitable to the marketing messages being sent to you.

16.12 We may host forms on third party websites. For information about how the platform will use your information, please go to their terms and conditions.

16.13 When us or an agency working on our behalf extracts reporting from a platform we use, this might include personal information, including however not limited to email address and first name. 

Accordingly, we have to treat that personal information in the same ways as any other personal information under the GDPR. 

This is used only to optimise our marketing campaigns and their performance.

We will only keep the personal information for as long as it is necessary for the specified purposes. And store this in a secure location.

16.14 We may purchase data from other companies, for the purpose of sending tailored campaigns to you. In such cases, us and the list company are the data controllers. We rely on legitimate interest as the basis for processing personal data from these purchased lists. We will only purchase data from companies who comply with data protection law and who we make sure have their lists cleaned regularly. Before sending a marketing campaign to the individuals on such lists we check that the other company has completed a legitimate interest assessment (and where relevant a data protection impact assessment) and we will also have completed a legitimate interest assessment to make sure we have considered the privacy implications of our campaign. You have the option to opt-out of such campaigns by clicking on the unsubscribe link on the campaign.

16.15 We take spam extremely seriously, so will only send communications to you from particular domains, including:

16.15.1 selectcarleasing.co.uk

16.15.2 selectvanleasing.co.uk

16.15.3 selectcarleasing.co

16.15.4 selectcarleasing.com

16.15.5 selectcarleasing.info

16.15.6 selectcarleasing.ltd

16.15.7 selectcarleasing.limited

16.15.8 selectcarleasing.london

16.15.9 selectcarleasing.net

16.15.10 selectcarleasing.online

16.15.11 selectcarleasing.org

16.15.12 selectcarleasing.uk

16.15.13 selectcarleasing.wales

16.15.14 selectcarleasinglimited.co.uk

16.15.15 selectcarleasinglimited.com

16.15.16 selectcarleasings.co.uk

16.15.17 selectvanleasing.com

16.15.18 selectvanleasing.uk

16.15.19 selectvanleasing.wales

16.15.20 selectvans.co.uk

16.15.21 selectfleetleasing.co.uk

16.15.22 selectfleetleasing.com

16.15.23 selectfleetmanagement.co

16.15.24 selectfleetmanagement.co.uk

16.15.25 selectfleetservices.co.uk

16.15.26 selectfleetservices.com

16.15.27 selectfleetsolutions.co.uk

16.15.28 selectelectric.co

16.15.29 selectelectric.uk

16.15.30 selectelectriccarleasing.co.uk

16.15.31 selectelectriccarleasing.com

16.15.32 selectelectriccarleasing.net

16.15.33 selectelectriccarleasing.uk

16.15.34 selectelectricleasing.co.uk

16.15.35 selectelectricleasing.com

16.15.36 selectelectricleasing.net

16.15.37 selectelectricleasing.uk

17 CHANGE OF PURPOSE

17.1 We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you would like an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

17.2 If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

17.3 Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

18 DISCLOSURE OF YOUR INFORMATION

18.1 We may share your information with third parties, as described below.

18.2 We may share your personal information (including your Identity, Contact, Financial, Transaction and Profile Data as described above) with

18.2.1 our group companies, sales companies (some of which have offices based in the EU) and authorised representatives so that they may handle your enquiry or order;

18.2.2 our funders/lenders (if you proceed with an order this is the finance company you enter into an agreement with); and

18.2.3 other third parties such as vehicle manufacturers, charging partners, MOT and servicing providers, warranty/ maintenance and insurance providers, alloy wheel/tyre/GAP/cosmetic insurance providers, battery cover providers, servicing providers, vehicle/fleet management providers, and dealerships - for example to assess your credit application and to progress your order (including to communicate with you about the details and progress of your order/charger/vehicle/fleet management/maintenance/insurance and matters such as arranging delivery and/or collection).

18.2.3.1 Our partnership with MotorEasy will allow us to have joint data controller permissions for any customer data. This therefore allow them to send marketing to you, for the products they provide on behalf of us - these will all be branded as from MotorEasy working with Select Car Leasing.

18.2.3.2 Other third parties we work with including, however not limited to, funders/dealers/Run your car/Run your fleet/British Car Auctions/Right Charge/Creditas/OVO are all joint data controllers of your data, when you decide to lease with us or take one of their products

Funders, lenders and other third parties mentioned above, will retain your data for the purposes stated, according to their data retention policies. Please contact them for more information.

18.3 We may share your personal information with our business partners, suppliers and sub-contractors and other third parties (including vehicle dealers, credit agencies and similar, organisations, the providers of IT services, professional advisors, insurers and HMRC) for the performance of any contract we enter into with them or you.

18.4 We may share your personal information with analytics and search engine providers (for example, your IP address, with software platforms like Google Analytics - if you accept cookies on our website) to assist us in the improvement and optimisation of our website and our marketing.

18.5 We may work with selected third party data list companies (such as Market Location Data/118 Data Resource Limited), and use their software.

This is where we purchase data, for the purpose of sending tailored campaigns to you. We rely on legitimate interest as the basis for processing personal data from these purchased lists. We will only purchase data from companies who comply with data protection law and who we make sure have their lists cleaned regularly. Before sending a marketing campaign to the individuals on such lists we check that us (as we are the data controllers of the data) and other company have completed a legitimate interest assessment (and where relevant a data protection impact assessment) to make sure we have considered the privacy implications of our campaign. You have the option to opt-out of such campaigns by clicking on the unsubscribe link on the campaign.

We will also receive clickthrough data from these companies, from anyone who has clickedthrough on our mailer. We will either: 

- Follow them up by telephone (if they have opted in) for 4 weeks after you have clickedthrough on the mailer with: 

o Did you receive our email? And then discuss our offering 

o A normal cold call asking what they’re doing around vehicle leasing 

- Use the web URLs to get uploaded to Meta and Google and used for paid social campaigns and PPC campaigns

Market Location Data will send email marketing to their databases on behalf of other companies, such as Select Car Leasing or other affiliate companies. As they are a third party data solutions provider we have no control over who receives this. Importantly please note if you are a current or prior Select customer, have enquired with us at any time, are a newsletter subscriber or have previously unsubscribed from our email marketing, you may receive a communication from them about offers or other information from Select. You can unsubscribe at any time from these emails.

For more detailed information on Market Location Data/118 Data Resource lead sources please visit the respective company privacy notices below to learn more about their individual data acquisition and handling practices. You can also opt out of updates and marketing by clicking on the unsubscribe button at the footer of our email communications. 

Market Location/118 Data Resource Limited: http://www.118information.co.uk/privacy/

Email: Customer.services@118group.co.uk

Phone: 0121 355 8600 

Address: 62 Anchorage Road, Sutton Coldfield, B74 2PG

18.6 If we sell, transfer or merge parts of our business or our assets, if we acquire or merge with other businesses, we may disclose your personal information to the prospective seller or buyer. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. We will provide any further information about this at the time as required by law . And will inform the individuals who have their personal information disclosed.

18.7 If another company becomes an appointed representative or partner of Select Vehicle Group Holdings, they may disclose your personal information to Select Vehicle Group Holdings for the same purposes that the individual gave us consent to use their data for. If a change happens to their business, then Select Vehicle Group Holdings may use their personal data in the same way as set out in this privacy policy. We will provide any further information about this at the time as required by law . And will inform the individuals who have their personal information disclosed .

18.8 We may also disclose your personal information:

18.8.1 if we are under a duty to do so to comply with any legal obligation;

18.8.2 to enforce or apply the terms relating to the use of our website or our contract with you; or

18.8.3 to protect our rights or property or the safety of our staff, customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

19 WHERE WE STORE YOUR PERSONAL DATA

19.1 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 policy .

19.2 All information you provide to us is stored on our secure servers. 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.

19.3 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 and prevent unauthorised access .

19.4 If you make any online payment to us, the payment transfer will handled by a third party provider such as WorldPay. No payment information is stored on our website.

19.5The data you sent to us when a form is completed on our website or when you contact us directly is sent to our CRM system, so we can contact you. If you choose to provide us with information, including personal data, you understand that we are storing this and/or transferring it to our hosting partner’s cloud infrastructure hosted with server provider (AWS) locations and systems and this might include the United Kingdom and the EU. Our hosting partner and AWS complies with applicable law when transferring your personal information outside of the country there the information is collected. For data originating from a European Union member state, Our hosting partner and AWS uses a variety of data transfer mechanisms (including standard contractual clauses) for this purpose. The information stored about your enquiry or order is secure and encrypted.

19.5.1 We may send you emails, to facilitate your enquiry and order. These are either sent via our website or through our CRM system. Those sent through our website and CRM are distributed and fulfilled via a third party platform. These do not store your email address (except where a enquiry fails to process to our CRM system, in which case this is stored for 30 days), however they do see this as part of the distribution process. For more information about how they use your information and which third parties we use, please contact dataprotection@selectcarleasing.co.uk.

19.6 We may occasionally submit documents or ask you to submit documents to us in very limited cases via Microsoft 365 (Outlook). And this will be the primary form of communication we have with you outside of telephone calls. As such your email address and any emails and attachments you send to us will be stored in the leasing consultants inboxes until these are deleted in accordance with the data retention time frames discussed in section 14.2.

20 DATA SECURITY

20.1 We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. These include:

20.1.1 Technical measures such as deploying the most up-to-date data security protocols .

20.1.2 Organizational measures such as internal data protection policies, staff training, internal audits of processing activities, reviews of internal HR policies, measures to meet the principles of data protection by design, data minimisation, pseudonymisation, transparency and the use of data protection impact assessments.

20.2 We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

20.3 All of these measures help us to ensure the most complete protection of personal data processed through our website and our customer relationship management systems. However, internet-based data transmissions may have security gaps, so absolute protection may not be guaranteed. For this reason, you are always free to transfer personal data to us via alternative means (for example by telephone) if you wish.

20.4 We have also put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

21 DATA RETENTION - HOW LONG WE WILL USE YOUR DATA

21.1 We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

21.2 To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

21.3 Details of retention periods for different aspects of your personal data can be requested by contacting dataprotection@selectcarleasing.co.uk.

21.4 In some circumstances you can ask us to delete your data: please see the paragraph entitled Request erasure (below) for further information.

21.5 In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes . In particular, we analyse anonymously collected data to increase the data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject. We may use such anonymised information indefinitely without further notice to you.

22 YOUR LEGAL RIGHTS

22.1 Under certain circumstances, you have rights under data protection laws in relation to your personal data. These are detailed below.

22.2 If you wish to exercise any of the rights set out above, please contact us (see paragraph 2 above).

22.3 You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

22.4 We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

22.5 We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

22.6 You have the following legal rights:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (please see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request .

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data's accuracy.

• Where our use of the data is unlawful but you do not want us to erase it.

• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. Provided it is technically feasible to do so and does not adversely affect the rights and freedom of others, we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you .

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent .

This privacy policy was last updated on 15 July 2024

Cookie Policy

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

Cookies are text files that are stored in a computer system via an Internet browser. Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Many websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate the individual browser of the website visitor from other Internet browsers that contain other cookies. A specific Internet browser can be recognised and identified using the unique cookie ID.

Through the use of cookies, Select Car Leasing can provide the users of this website with more user-friendly services that would not be possible without the cookie setting.

By means of a cookie, the information and offers on our website can be optimised with the user in mind. Cookies allow us to recognise our website users. The purpose of this recognition is to make it easier for users to utilise our website. The website user that uses cookies, does not have to enter access data each time the website is accessed, because this is taken over by the website, and the cookie is thus stored on the user's computer system.Another example is the cookie of a shopping cart in an online shop. The online store remembers the articles that a customer has placed in the virtual shopping cart via a cookie.

You can find more information about cookies at http://www.allaboutcookies.org and http://www.youronlinechoices.eu. For a video about cookies visit http://www.google.com/intl/en-GB/policies/technologies/cookies/.

Cookies we use are detailed below:

a. Cookies from Google Analytics:

We use Google Analytics log cookies (such as _utma, _utmv, _utmc, _utmz, and _utmb) to identify user’s activities such as which pages are being visited and how long for. This helps us analyse data about webpage traffic and user’s behaviours to improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system. You can find more details about Google analytics cookies here.

Overall, cookies help provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

Google Analytics places a cookie on the information technology system of the website visitor. With the setting of the cookie, Google is enabled to analyse the use of our website. With each call-up to one of the individual pages of this website, which is operated by the controller and into which a Google Analytics component was integrated, the Internet browser on the device used by the website visitor will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, Google gains knowledge of personal information, such as the IP address of the website visitor, the access time, the location from which the access was made, and the frequency of visits of our website by the website visitor, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements.

These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.

b. Targeting or banner advertising cookies including remarketing with Google Double click and YouTube channel

This type of advertising is designed to provide you with a selection of products based on what you have viewed on our website and deliver adverts to you when you visit other selected websites. The adverts may highlight alternative vehicle options from other categories suitable to your browsing history.

The technology behind these adverts uses cookies that are usually placed by third parties such as advertising networks with the website operator’s permission. They remember that you have visited a website and the information is shared with other organisations such as advertisers.

Please be assured that the data contained in the cookie used in these adverts is completely anonymous and does not contain any of your personal details.

c. Social Media:

Select Car Leasing uses social media for the purposes of promoting and communicating about the enterprise. This includes the use of various remarketing services through social media platforms including, but not limited to, Facebook, Twitter, LinkedIn, Instagram and Google remarketing services to advertise our content, products and services on these social media channels to previous visitors to our site. Any data collected will be used in accordance with our own privacy policy and the social network's privacy policy. Details around how you may opt out of receiving these cookies can be found in some of the links below:

• Facebook cookie policy

• Twitter cookie policy

• Linked-in cookie policy

• Instagram cookie policy

• Google My Business cookie policy

Select Car Leasing uses the You Tube Channel for the purposes of marketing and remarketing of the enterprise to different audience groups using video advertising. These audiences include, but are not limited to, the general population of the UK, specific targeted audiences (e.g. such as those interested in cars, luxury cars and other motor vehicles), audiences who have visited other websites, previous Select Car Leasing website visitors and also ‘Lookalike’ audiences. By using You Tube, the user is subject to the data and privacy policies of this organisation, not Select Car Leasing.

d. Google Adwords

If a website visitor reaches our website via a Google ad, a conversion cookie is filed on the device of the website visitor through Google. A conversion cookie loses its validity after 30 days and is not used to identify the website visitor. If the cookie has not expired, the conversion cookie is used to check whether certain sub-pages, e.g. the shopping cart from an online shop system, were called up on our website. Through the conversion cookie, both Google and the controller can understand whether a person who reached an AdWords ad on our website generated sales, that is, executed or cancelled a sale of goods.

The data and information collected through the use of the conversion cookie is used by Google to create visit statistics for our website. These visit statistics are used in order to determine the total number of users who have been served through AdWords ads to ascertain the success or failure of each AdWords ad and to optimise our AdWords ads in the future. Neither our company nor other Google AdWords advertisers receive information from Google that could identify the website visitor.

e. Display Ad Cookies

Select Car Leasing uses Display Advertising for the purposes of marketing and remarketing of the enterprise to different audiences using various Display ad networks. For this we use ad form platform, which stores cookies on your PC using Ad Form Ad Serving system. This allows advertisers to collect and store data about internet users and use them for analysis and online behavioural advertisements. Users can read about their privacy policy here: https://site.adform.com/privacy-policy-opt-out/.

The website visitor may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the website visitor deactivates the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable.