Purposes and legal basis for processing your personal information
The protection of your personal information is very important to us and we will only process your personal information for the following purposes:
a) to allow us to deal with your enquiries
b) to provide you with a service
c) to authenticate your identity
d) to manage our relationship with you
e) to inform you about our products and services , including by direct marketing
f) for administrative purposes
g) for debt administration and factoring
h) for purposes related to our proposed corporate activity, such as a sale or merger
i) to maintain our own accounts and records
j) to support and manage our employees
k) where required to do so by law for e.g. sharing for crime prevention.
At Liberty Leasing we rely on the following legal bases for the processing of your personal information, depending upon the purpose:
Contract: where necessary to perform a contract with you or to take steps at your request before entering into a contract with you.
Consent: in some cases we may request your consent for processing, if so this will be specific to the processing and we will inform you of the purpose and you can provide or refuse such consent at your discretion.
Legitimate Interests: where necessary for our legitimate interests or those of third parties which are not overridden by your interests, rights or freedoms. These comprise providing our services, direct marketing, fraud prevention, ensuring network and information security, indicating possible criminal acts or threats to public security, processing employee or client data and administrative transfers within our group of companies.
Legal Obligation: where Liberty is under any legal obligations, e.g. with respect to anti-money laundering or other regulatory matters, which requires us to process or share personal data.
Ordinarily the lawful basis relied on by Liberty Leasing is that of contract, legitimate interests or legal obligation depending on the purposes of the processing. However, for transparency and good housekeeping, we may also request your specific consent from time to time, but where one of the other bases above applies, we do not rely on that as the sole legal basis of processing.
If you have provided consent to our processing of your personal data, your consent can be withdrawn at any time by contacting the Data Protection Officer. This will not affect processing before withdrawal or which is based on another lawful basis of processing.
We may provide your personal data to the following recipients:
- credit reference agencies – experian.co.uk/crain, www.equifax.co.uk/crain, www.transunion.co.uk/crain (previously CallCredit)
- fraud prevention agencies, law enforcement
- persons who may provide goods and services that we believe would be relevant to you
- our service providers, including anyone we appoint as a data processor
- financiers, including block discounters, banks and other financial institutions
- professional advisers for e.g. solicitors, accountants, auditors, enforcement / tracing agents and valuers
- consultants / contractors
- insurance providers
- prospective purchasers of our business or company and their advisers
- other members of our group of companies
Please note that some recipients may be located outside of the European Union (“EU”) in countries which have not been designated as ensuring an adequate level of protection for personal data. Where that is the case, see below.
Transfer of your personal data outside of the EU
Your personal information may be transferred outside of the EU for further processing in the context of any operation we may have outside the EU or by the recipients described above.
Except where the transfer is necessary to perform a contract with you or to implement pre-contract measures at your request or to perform or conclude a contract with a third party (including your associated business) in your interest, we will ensure at least one of the following safeguards is implemented:
- we will only transfer the data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
- where we transfer the data to third parties, we will use specific contracts between us and the recipient in a form approved by the European Commission to protect it; or
- where the transfer is to the USA, the recipient is within the EU-US Privacy Shield.
If you would like a copy of the relevant safeguard(s) please email us at firstname.lastname@example.org.
Retention of personal information
We keep your personal information for the following periods:
- where you have proceeded in doing business with us for six years after termination of the business relationship, except where the law requires us to keep it for longer;
- in other cases we retain data for as long as the law requires us to do so.
Personal information will not be held for longer than is necessary for the purposes for which it was processed and will be periodically reviewed to determine whether retention is still required.
Your rights as a data subject
You may have a right to the following:
- Right to be informed
- Right of access
- Right to rectification
- Right to erasure
- Right to restrict processing
- Right to data portability – for e.g. you may be able to request for your personal data to be transferred from one data controller to another in certain circumstances
- Right to object
- Rights related to automated decision making including profiling
- Right to lodge a complaint with our supervisory authority, namely the Information Commissioner Office (“ICO”):
Telephone: 0303 123 1113
To exercise any of these rights, please contact Liberty Leasing’s Data Protection Officer.
As mentioned above, where processing of your personal data is based only on your consent, you have the right to withdraw that consent at any time. Your withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.
How to complain
Complaints can be made to us at any time, free of charge in person, by telephone (including text message), email, letter, fax or via the website to any member of staff at Liberty Leasing. This is without prejudice to your right to complain to our supervisory authority, the ICO.
Links to other websites
Our website may contain links to other sites and personal information may be collected through those other websites, however, this Privacy Notice does not apply to those websites.
Changes to our Privacy Notice
We keep this Notice under regular review and, as such, the Notice may change from time to time. We recommend that you read this Notice before submitting any personal information to us through our website and regularly thereafter for any changes.
This Notice was last updated in May 2019.