JCT600 Vehicle Leasing Solutions Ltd

Privacy Policy

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.

Key terms

It would be helpful to start by explaining some key terms used in this policy:

We, us, our	JCT600 Vehicle Leasing Solutions Ltd, JCT 600 Ltd and our group companies
Group Data Manager	Post:    Group Data Manager, JCT600 Vehicle Leasing Solutions Ltd., Tordoff House, Apperley Bridge, West Yorkshire, BD10 0PQ Email:  groupdatamanager@jct600.co.uk Phone: 0113 250 2600
Personal information	Any information relating to an identified or identifiable individual
Special category personal information	Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership Genetic and bio-metric data Data concerning health, sex life or sexual orientation

 

Personal information we collect about you

We may collect and use the following personal information about you:

• your name and contact information, including email address and telephone number and company details
• Information to enable us to check and verify your identity, e.g. your date of birth
• Information to enable us determine whether you are licensed to drive, whether you have any endorsements, where your vehicle, or the vehicles you lease, is serviced and what work has been undertaken.
• location data, if tracking devices are installed on your vehicles or you have permitted us to do this
• your billing/payment information, transaction and payment card information, credit profile and history
• your contact history, purchase history and preferences
• information to enable us to undertake credit or other financial checks on you
• Information about how you use our website, mobile applications, IT, communication and other systems
• your responses to surveys, competitions and promotions
• your employer’s/employees’ details, your employment position, history and job grade
• Details of your income and employer benefits
• CCTV footage if you attend our premises
• Details of your spouse, family members, and other users of the vehicle you use if you, or they, provide us with such detail
• Details of the pages you visited on our website, your IP address, devices you use and website address you used to access our site or applications from.

This personal information is required to provide our products and/or services to you, improve our services and/or for marketing purposes. If you do not provide personal information we ask for, it may delay or prevent us from providing our products and/or services to you.

 

How your personal information is collected

We collect most of this personal information directly from you, in person, by telephone, text, email[ and/or via our website our mobile application or from your employer/employee. We may also receive information from your family members/co-habitants if you have asked them to supply information to us or if they are connected to your account. However, we may also collect information:

• from publicly accessible sources, e.g. DVLA, Companies House or HM Land Registry, social/business media platforms;
• directly from a third party, e.g.:
  • credit reference agencies;
  • customer due diligence providers;
  • internet service provider;
  • software service provider;
  • an intermediary who introduces us to you/your business.
• from a third party with your consent, e.g. your bank, building society, DVLA.
• from cookies on our website—for more information on our use of cookies, please see our cookie policy
• via our IT systems, e.g.:
  • door entry systems and reception logs;
  • automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems;

 

How and why we use your personal information

Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:

• to comply with our legal and regulatory obligations;
• for the performance of our contract with you, your employer or to take steps at your request before entering into a contract;
• to enable you, or your employer, to provide goods or services to us;
• for our legitimate interests or those of a third party; or
• where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for	Our reasons
To provide products and/or services to you and/or your employer/employee	For the performance of our contract with you, your employer or to take steps at your request before entering into a contract
To obtain products and/or services from you and/or your employer	For the performance of our contract with you, your employer or to take steps at your request before entering into a contract
To prevent and detect fraud against you or your employer/employee	For our legitimate interests or those of a third party, ie to minimise fraud that could be damaging for us and for you
Conducting checks to identify our customers, their employees and verify their identity Screening for financial and other sanctions or embargoes Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety regulations, statutory accounting requirements	To comply with our legal and regulatory obligations
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies	To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, egg policies covering security and internet use	For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you and/or your employer/employees
Operational reasons, such as improving efficiency, training and quality control	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information	For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, eg in relation to our financial performance, customer base, product range or other efficiency measures	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorised access and modifications to systems	For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations
Updating and enhancing customer records	For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products
Statutory returns	To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments	To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Marketing our services and those of selected third parties to: ·         existing and former customers and their employees ·         third parties who have previously expressed an interest in our services ·         third parties with whom we have had no previous dealings.	For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers
Credit reference checks via external credit reference agencies	[For our legitimate interests or those of a third party, i.e. to ensure our customers are likely to be able to pay for our products and services]
External audits and quality checks, e.g. for accreditations and the audit of our accounts	For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligations

The above table does not apply to special category personal information, which we will only process with your explicit consent.

 

Promotional communications

We may use your personal information to send you updates (by email, text message, telephone or post) about our products and/or services, including exclusive offers, promotions or new products and/or services.

We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never sell and/or share it with other organisations outside the JCT group of companies for marketing purposes without your express consent. The cookies installed on our website do share data with third parties for marketing purposes. For more information about the nature and purpose of the cookies on our website, please see our cookie policy. 

 

You have the right to opt out of receiving promotional communications at any time by:

• contacting us at groupdatamanager@jct600.co.uk
• using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts

We may ask you to confirm or update your marketing preferences if you or your employer instruct us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.

 

Who we share your personal information with

We routinely share personal information with:

• companies within the JCT600 group
• third parties we use to help deliver our products and/or services to you, e.g. payment service providers, warehouses, delivery companies IT service providers which may host our website / App’s and store data on our behalf;
• other third parties we use to help us run our business, e.g. marketing agencies, banks, lawyers, insurers;
• third parties approved by you, e.g. social media sites you choose to link your account to or if you accept marketing or analytical cookies, third party payment providers;
• credit reference agencies;
• our insurers and brokers;
• your employer;
• car manufacturers, finance companies, accreditation agencies.

 

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you, unless you agree otherwise. We may also share personal information with external auditors.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

We will not share your personal information with any other third party.

 

Where your personal information is held

Information may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).

Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the EEA’.

 

How long your personal information will be kept

We will keep your personal information while you have an account with us, whilst we are providing products and/or services to you/your employer and for at least 7 years after we have delivered our services/products to you or your employer. We will only keep your personal information for as long as is necessary:

• to respond to any questions, complaints or claims made by you or on your behalf;
• to show that we treated you fairly;
• to keep records required by law;
• to discharge our contractual/legal obligations owed to you or your employer;
• to demonstrate we have discharged our obligations;
• for accounting and audit purposes.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods may apply for different types of personal information.

When it is no longer necessary to retain your personal information, we will delete or anonymise it.

Where you have subscribed to receive marketing material from us we will keep your personal data for 2 years from the point at which you invite us to send you communications or from the point at which you interact with you, unless you unsubscribe.

We have CCTV cameras installed in our premises for the purpose of crime prevention and for health and safety reasons. We retain such information for a maximum of 3 months.

 

Transferring your personal information out of the UK OR EEA

To deliver services to you, it may become necessary share your personal information outside the UK or the European Economic Area (EEA). We may do this if our service providers are located outside the UK or EEA. If we do transfer your data out of the UK or the EEA, such transfers will be subject to special rules under European and/or UK data protection law.

If you accept/give your consent to cookies from our website, your personal data may also be transfer to selected third parties outside of the UK and EEA. For further details see our cookies policy.

 

Your rights

You have the following rights, which you can exercise free of charge:

Access	The right to be provided with a copy of your personal information (the right of access)
Rectification	The right to require us to correct any mistakes in your personal information
To be forgotten	The right to require us to delete your personal information—in certain situations
Restriction of processing	The right to require us to restrict processing of your personal information in certain circumstances, e.g. if you contest the accuracy of the data
Data portability	The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object	The right to object: —at any time to your personal information being processed for direct marketing (including profiling); —in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

 

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

• email, call or write to our Group Data Manager or submit a Subject Access Request via www.jct600.co.uk/sar;
• let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
• let us know what right you want to exercise and the information to which your request relates.

 

Keeping your personal information secure

We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We continually test our systems to ensure your personal information is safe.

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

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

How to complain

We hope that we can resolve any query or concern you may raise about our use of your information.

You have the right to lodge a complaint with a supervisory authority. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.

 

Changes to this privacy policy

This privacy notice was last updated in October 2021. We may change this privacy policy from time to time.

How to contact us

Please contact us Group Data Manager by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.

Our contact details are shown below:

Our contact details	Post:   Mr Nigel Shaw, Group Finance Director, JCT600 Ltd., Tordoff House, Apperley Bridge, West Yorkshire, BD10 0PQ
Group Data Manager	Post:    Group Data Manager, JCT600 Ltd., Tordoff House, Apperley Bridge, West Yorkshire, BD10 0PQ

 

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