OVERVIEW
Citygate Leasing Limited is a company registered in England and Wales (which is referred to as ‘we’ or ‘us’ in this policy)
We are committed to protecting and respecting any personal information you share with us.
This statement describes what types of information we collect from you, how it is used by us, how we share it with others, how you can manage the information we hold and how you can contact us.
We will always give you the option not to receive marketing communications from us. We will never send you unsolicited ‘junk’ email or communications or share your data with anyone else who might. We do not sell your information to third parties, but we do work closely with selected partners who help us to provide you with the information, products and services that you request from us. For example, Volkswagen Financial Services who provide leasing services to our customers.
The contents of this statement may change from time to time so you may wish to check this page occasionally to ensure you are still happy to share your information with us. Where possible, we will also contact you directly to notify you of any substantial changes.
This version of our Privacy Statement is live from 1st January 2024.
WHAT PERSONAL DATA DO WE COLLECT
We collect information about you and your vehicle when you engage with our website, applications, speak to our communication centre or come into any of our premises. We only collect information which is necessary, relevant and adequate for the purpose you are providing it for.
We also obtain information about you or your vehicle from some third parties, i.e insurance companies or breakdown companies in the event of a bodyshop repair or vehicle breakdown. Some of this information does not identify you personally, but provides us with information about how you use our services and engage with us (we use this information to improve our services and make them more useful to you). The information we collect includes some or all of the following:
EXPLAINING THE LEGAL BASES WE RELY ON
The law on data protection sets out a number of different bases for which a company may collect and process your personal data, including:
CONSENT
In specific situations, we can collect and process your data with your consent. For example, when you tick a box to receive email newsletters.
When collecting your personal data, we will obtain your marketing preferences to ensure you only receive communications through consented channels.
SOFT OPT-IN
We will use ‘soft opt-in’ from time to time. This will only be used for existing customers, on the basis of an individual who placed an order recently, gave us their details, and did not opt out of marketing messages. On this basis we would deem they are probably happy to receive marketing from us about similar products or services even if they haven’t specifically consented. However, we will always give a clear chance for our customers to opt out – both when they first place an order, and in any further marketing messages.
The soft opt-in rule means we may be able to email or text our own customers, but it does not apply to prospective customers or new contacts. It also does not apply to non-commercial promotions (eg charity fundraising or political campaigning).
CONTRACTUAL OBLIGATIONS
In certain circumstances, we need your personal data to comply with our contractual obligations. For example, if you place a lease order with us.
We will also ensure you receive timely reminders for the maintenance and end of lease options for your vehicle.
LEGAL COMPLIANCE
If the law requires us to, we may need to collect and process your data. For example, we can pass on details of people involved in fraud or other criminal activity affecting us to law enforcement.
It may also be necessary to contact and update you in the event of any national emergencies.
LEGITIMATE INTEREST
In specific situations, we collect and process your data to pursue our legitimate interests in a way which you might reasonably expect, as part of running our business, and which does not materially impact your rights, freedom or interests.
For example, we may use your purchase history with us to make you personalised offers.
We may use your personal data to send you offers by post, email, or contact you by telephone to advise you of offers we think may be of interest to you.
HOW WE USE YOUR DATA
Citygate Leasing Limited will only process information that is necessary for the purpose for which it has been collected. You will always have the option not to receive marketing communications from us (and you can withdraw your consent or object at any time).
The reasons for processing your data are detailed below;
Vehicle Leasing Sales, Servicing, Ancillary Services Sales: We collect data in the performance of a contract for the sale of a leasing product, servicing or to provide a service to ensure the contract is fulfilled.
Financing Vehicles: We will process your data in order to process the leasing finance order for you to lease the vehicle.
Marketing: We will process your data with your consent or on occasion, if applicable, under the legitimate interest to advise you on of offers or services that we feel you should be informed about.
Employee Information: We collect and store your personal data as part of our legal obligation linked to your contract of employment.
Recruitment: We have a legal obligation to share your personal data with Experian who are a credit reference agency who provide us with financial background checks for specific roles prior to you commencing employment with us.
HOW WE PROTECT YOUR DATA
We take steps to ensure that any third-party partners who handle your information comply with data protection legislation and protect your information just as we do. We only disclose personal information that is necessary for them to provide the service that they are undertaking on our behalf. We will aim to anonymise your information or use aggregated non-specific data sets wherever possible. We do not sell your information to third parties, but we do work closely with our third-party suppliers who fulfil business activities for us (like leasing funders/finance companies, system providers, marketing, events and market research agencies) and we take reasonable steps to ensure their data processing policies and procedures are in place to ensure we protect your information.
Third party advertising partners may set cookies on your devices through our site to collect your information. We do not control their use of your data. Further information about our advertising partners and their use of data can be found via our privacy preference centre under the More Info tab in our cookie policy.
HOW LONG WILL WE KEEP YOUR DATA
We will not use your personal information for any longer than we deem reasonably necessary. If you are a customer or otherwise have a relationship with us, we will hold and use personal information about you for a longer period than if we have obtained your details in connection with a prospective relationship.
Please see our Record Keeping Policy for our full details on how long we store customer data for.
Who do we share your data with?
We do not sell your information to third parties, but we do work closely with our third-party suppliers who fulfil business activities for us (like leasing funders/finance companies, system providers, marketing, events and market research agencies etc.)
However, we may from time to time disclose your information to the following categories of companies or organisations to which we pass the responsibility to handle services on our behalf: roadside assistance service providers, customer contact centres, mobility and car hire providers, direct marketing communications agencies and consultants, market research and market analytics service providers, our legal and other professional advisors.
We will also share your information with our retailers in situations where we need to pass your information to them to manage any request or complaint you have made to us. For example, where you have requested a test drive, we will need to share your personal information within our businesses so that they can contact you to arrange for the test drive to take place.
There are circumstances where we share your information within our company to fulfil orders, transactions, handle complaints or provide you with a service or information that you have requested.
WHERE YOUR PERSONAL DATA MAY BE PROCESSED
Due to the nature of our business, there may be some instances where your information is processed or stored outside of the EU. In those instances, we will ensure that appropriate safeguards are in place for that transfer and storage as required by applicable law.
WHAT ARE YOUR RIGHTS OVER YOUR PERSONAL DATA
You have the right as an individual to access your personal information we hold about you and make corrections if necessary. You also have the right to withdraw any consent you have previously given us and ask us to erase information we hold about you. You can also object to us using your personal information (where we rely on our business interests to process and use your personal information).
You have a number of rights in relation to your personal information under data protection law. In relation to most rights, we will ask you for information to confirm your identity and, where applicable, to help us search for your personal information. Except in rare cases, we will respond to you within 30 days after we have received any request (including any identification documents requested).
You can exercise the above rights and/or manage your information by contacting us using the details below:
Post: Data Protection Team, Citygate Automotive Limited, 664 Victoria Road, South Ruislip, Middlesex, HA4 0LN
Email: leasingdataprotection@citygate.co.uk
HOW CAN YOU STOP THE USE OF YOUR PERSONAL DATA FOR MARKETING
There are several ways you can stop direct marketing communications from us:
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.
CONTACTING THE REGULATOR
If you are unhappy, you have the right to lodge a complaint with a data protection regulator in the United Kingdom. The contact details for the Information Commissioner’s Office, the data protection regulator in the UK, are below:
Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Call: 0303 123 1113
Email: casework@ico.org.uk