About UsBridle Vehicle Leasing is part of the Bridle Group and a trading name of Hanborough Enterprises Limited (‘the Company’, ‘Us’, ‘We’ or ‘Our’). Hanborough Enterprises Limited is regulated for consumer credit activities and insurance distribution by the Financial Conduct Authority – Firm Reference Number 631448. You can check this information at www.fca.org.uk Hanborough Enterprises Limited is registered with the Information Commissioners Office for the processing of data under The Data Protection (Charges and Information) Regulations 2018. Our Data Protection Licence number is Z264186X. You can check this information at www.ico.org.uk Hanborough Enterprises Limited is a member of the British Vehicle Rental and Leasing Association and abide by their Code of Conduct. For further information visit www.bvrla.co.uk We are a broker and not a lender. Our website address is www.bridlevehicleleasing.co.uk
Controller of Personal InformationAny personal information processed by us is controlled by Hanborough Enterprises Limited, which is considered the “data controller” of your personal information under European Union and UK data protection law. Our Data Protection Officer is Mr Alan Carreras and he may be contacted By email to: email@example.com By calling: 01993 894981 By writing to: Bridle Vehicle Leasing, Hanborough Enterprises Ltd, Tamarisk House, North Leigh Business Park, North Leigh, Witney, Oxfordshire OX29 6SW If you have a contract or agreement with one of our funders or one of our suppliers of other services, then that other company will also separately be considered a “data controller” under European Union UK data protection law. You can access the privacy policies of the other companies via their own websites.
What do we mean by personal information?Personal information means details which identify you or could be used to identify you, such as your name and contact details including your email address, your vehicle registration details, your date of birth, your marital and residential status, your employment details, your bank details and information about any agreement that you have contracted through us. It may also include information about how you use our website and mobile applications.
When and why do we collect ‘sensitive personal data’?Certain categories of personal information, such as that about race, ethnicity, religion, health, sexuality or biometric information are special categories of data requiring additional protection under European Union and UK data protection law and is referred to here as “sensitive personal data”. Generally, we try to limit the circumstances where we collect and process sensitive personal data. An example of where we may collect and process ’sensitive personal data’ includes a request that a communication device in a vehicle is disconnected which is not ’sensitive data’ but may imply or suggest your religion, health or other information.
What do we use your personal information for?The main purposes for which we use your personal information are: Arranging the provision of finance, the supply of a vehicle and ancillary products and services through either ourselves or a third party supplier such as a finance company, maintenance provider and/or insurance provider Providing access to and managing your agreement for the supply of a vehicle or for other services that you have requested To respond to emails received from you To send status updates and service communications to you To keep track of your mileage To provide services tailored to your requirements and to treat you in a more personal way Providing and managing access to our website To personalise and tailor your experience on our website Identify you when you contact us If we need to process your personal data to comply with legal obligations to which we are subject We may need to process your personal data to comply with legal obligations binding or accepted by us. For example, we may need to retain your transaction records for a period of time to comply with tax or accounting requirements, or to carry out checks on you to satisfy our obligations under anti-money laundering legislation or disclose your personal data if forming part of an investigation by law enforcement To carry out analysis and market research With your permission and/or where permitted by law, we may use your data to carry out marketing which may include contacting you by phone, text message, mail, email or social media to keep you informed of Bridle Group’s products and services. We will not however send you unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the General Data Protection Regulation (EU) 2016/679 (GDPR) and Privacy and Electronics Communications (EC Directive) Regulations 2003 To undertake targeted online advertising To improve our website, products and services For management and administrative purposes
When will we send you marketing?When we have your permission, we will send you marketing communications from us or from a firm within the Bridle Group of companies or from a firm which is part of Hanborough Enterprises Ltd. As a company which is part of Bridle Group and Hanborough Enterprises Ltd, we do sometimes send marketing communications that include a business partners’ products and services related to the supply, operation or running of a vehicle and in respect of ancillary products, as well as our own. We will only allow third parties or other members of our group to send marketing communications to you when we have agreed marketing from third parties. We will respect your choice as to what communications you wish to receive and how these are sent.
How can you change what marketing communications you receive, how you receive them and unsubscribe?If you decide you would no longer like to be sent marketing communications, you can change your mind at any time. The ways to stop being sent marketing communications are described below: By email to: firstname.lastname@example.org By calling: 01993 894981 By writing to: Bridle Vehicle Leasing, Hanborough Enterprises Ltd, Tamarisk House, North Leigh Business Park, North Leigh, Witney, Oxfordshire OX29 6SW. Please always quote the trading name of the company that you wish to cease receiving marketing communications from. In addition, each marketing communication we send by email will also have an unsubscribe option which will allow you to stop you receiving further marketing emails. You may also stop any further text messages by replying with the word “STOP”. We aim to action requests to stop being sent marketing communications within 10 working days of receiving those requests, but it is possible you will receive some marketing in the period prior to that change being made. Please note that if you tell us that you do not wish to be sent further marketing communications, you will still receive service communications (as described above) which are necessary. If you ask us to stop sending marketing communications, please note we will retain your personal information for the purposes of indicating that you do not want to receive marketing communications. If you wish to change how we use your personal information, including exercising your right to be forgotten, please see section ‘What are your legal rights in relation to the personal information we hold about you?’ and ‘How can you exercise your legal rights and change how we use your data?’
What is our legal basis for using your personal information?We, companies which are part of Bridle Group and firms which are part of Hanborough Enterprises Ltd will only process your personal information where we have a legal basis to do so. The legal basis will depend on the reason or reasons the companies which are part of Bridle Group of companies and Hanborough Enterprises Ltd collected and needs to use your information. Under EU and UK data protection laws in almost all cases the legal basis will be: Because we need to use your information so that we can process your application for the provision of a product or service and otherwise perform the contract you have with us or through us Because it is in our legitimate interests as a business to use your personal information to operate and improve our business as a credit broker and supplier of ancillary products Because we need to use your personal information to comply with a legal obligation To protect the vital interests of you or another person Because you have consented to us using your information for a particular purpose More information on each legal basis is provided below. If processing of your data is subject to any other laws, then the basis of processing your data may be different to that set out above and may in those circumstances be based on your consent in all cases.
How long do we keep personal information?We will keep your information for as long as we need it for the purpose it is being processed for. For example, when you contract a vehicle with or through us, we will keep the information related to your agreement, so we can fulfil the management of the arrangement you have made and after that, we will keep the information for a period which enables us to handle or respond to any complaints, queries or concerns relating to the contract. The information may also be retained so that we can continue to improve your experience with us and to ensure that you receive any loyalty rewards which are due to you. We will actively review the information we hold and delete it securely, or in some cases anonymise it, when there is no longer a legal, business or customer need for it to be retained. If you stop interacting with us as a customer, we will remove or anonymise your information after 7 years. Performance of a contract with you It will be necessary for the companies which are part of Bridle Group and Hanborough Enterprises Ltd to use your personal information to complete a contract that you have made with us. For example, we will need to use information such as your contact details and payment information to provide you with the vehicle and/or service that you have requested and paid for.
Legitimate InterestsAs a credit broker and provider of ancillary products we have a legitimate business interest to use the personal information we collect to offer an effective service and carry out our business.
Compliance with legal obligationsThere are situations where we are subject to a legal obligation and need to use your personal information to comply with those obligations.
ConsentAlternatively, we may collect and use your personal information where you have given your specific consent to us doing so. If the basis of our processing your data is consent to marketing, you can withdraw your consent to such processing at any time, by one of the following methods described below: By email to: email@example.com By calling: 01993 894981 By writing to: Bridle Vehicle Leasing, Hanborough Enterprises Ltd, Tamarisk House, North Leigh Business Park, North Leigh, Witney, Oxfordshire OX29 6SW. Or if you are a registered user of our online system, you can change your marketing preferences at any time in your account area Please always quote the trading name of the company that you wish to withdraw your consent from. However, if you withdraw your full consent, in some circumstances, it may mean we will not be able to provide all or parts of the services you have requested from us
Who do we share your personal information with?Your personal information may be shared with the companies within our group. We share information with them, so they can assist us in providing services to you and to understand more about you. For example, if you have a maintenance agreement with one of the other members of the Hanborough Enterprises Ltd group we may use this information to understand more about the sorts of travel services you are likely to be interested in. You will only be sent marketing emails from other companies within our group where you have provided your consent to those companies. We may also disclose your personal information to the following third parties for the purpose described here: We will need to share your data with a) finance companies to obtain finance approval for the funding of a vehicle b) vehicle dealerships to obtain finance approval for the funding of a vehicle with the manufacturer’s finance company, c) suppliers in order that we may order a vehicle for you, register the vehicle, arrange delivery to you and for servicing and warranty purposes d) suppliers who provide additional services or products such as insurance and maintenance We may share your data with other companies in our group for reporting or market research or for the supply of additional products and services We may sometimes contract with third parties to supply products and services to you on our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law In certain circumstances, we may be legally required to share certain data held by us, which may include your personal data, for example, where we are involved in legal proceedings, where we are complying with legal obligations, a court order, or a governmental authority We may compile statistics about the use of our website including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where we transfer any personal data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR We do not sell personal information to third parties, and we only allow third parties to send you marketing information where we have your consent to do so.
What are your legal rights in relation to the personal information we hold about you?Under data protection laws in the European Union and the UK, you have certain rights in relation to your personal information. Responses to exercise your rights will be provided within one month and generally there is no fee for making these requests. If your request is particularly complicated we may extend the deadline for responding to three months, but we will let you know if this is the case. We will handle all requests in accordance with applicable law. However, depending on the right you wish to exercise, and the nature of the personal information involved, there may be legal reasons why we cannot grant your request. Further explanation of those rights and the exceptions to them are set out below. Details of how to exercise your rights are set out in the section below ‘How can you exercise your legal rights and change how we use your data?’ Your rights include the following: You may request us to stop sending you marketing. To see how to change your permission to market please refer to ‘How can you change what marketing communications you receive and how you receive them?’. If you do so we will no longer be able to send you marketing communications. However, if you subsequently arrange the finance of a vehicle or ancillary products through us we will need to send you communications about these. These communications will help you get the most from the services we provide and may also contain options and other details about the services you will or may wish to be using You may request us to stop using your personal information where we are doing so under legitimate interests (see the section ‘What is our legal basis for using your personal information’ for examples of when that applies) unless it is needed for dealing with legal claims or we have other compelling legitimate reasons that override your rights You may request us to stop processing of your personal information for marketing purposes including analytics for the purposes of targeted marketing, including online advertising. You may access the personal information we hold on you
There are some limited exceptions to this right, such as information relating to others who have not consented to the disclosure of their information and information which is legally privileged. Please see ‘Accessing your personal information’ for more details You may ask us to correct your personal information (the 'right of rectification’) if that information is inaccurate. How to do this see section on ‘How can you change what marketing communications you receive and how you receive them?’ You may ask for personal information which identifies you to be erased (or forgotten) To do this we will remove the information that identifies you from the data we hold in our active systems (“anonymise”). However, a separate and restricted copy of the identifying information will be kept for 7 years to meet the obligations we have to law enforcement, national authorities and legal proceedings. Considerations: We may need to retain certain elements that relate to a contract between you and the company or companies which are part of the Bridle Group and Hanborough Enterprises Ltd and our suppliers including funders because we need it for our own legal and auditing purposes (for more information on the basis on which we process your personal information see the section ‘What is our legal basis for using your personal information?’) A record of your request including the personal information you supplied will be retained in the application used to carry this out for 3 years In some circumstances it may mean we will not be able to provide all or parts of the services you have requested from us in relation to previous agreements or retain any preferences you have previously shared with us We cannot erase your personal information if you have online access to our online customer system as we require this information to deliver our contract with you. If you wish to proceed you will need to advise us that you no longer require access We cannot erase your personal information if you have a contract with or through us. For legal reasons, we need to keep information linked to these. You may come back to us once this time has passed and submit a request We cannot erase your personal information if we have identified that you either have an open complaint with us or we hold a previous case for you within the past 6 years. We are required to retain this information in case there is a need to re-open the complaint
How can you exercise your legal rights and change how we use your data?If you wish to change how we use your personal information, please contact us by writing to us at the following address: The Data Protection Officer Bridle Vehicle Leasing Hanborough Enterprises Ltd Tamarisk House North Leigh Business Park North Leigh Witney Oxfordshire OX29 6SW We will require some information to identify you, either a copy of your passport or driving licence and a recent proof of address which will only be used to process your request. We will verify your identity before processing your request.
Accessing your personal informationIf you wish to receive a copy of your information, you can make your request in writing and include the following information with your request: Your name and postal address Details of your request A photocopy of your passport or driving licence, so that we can verify your identity A recent proof of address Your signature and the date of the request If you are applying on behalf of another person then signed authority from the individual is required Any details which may help us locate the information which is the subject of your request, for example: The name of the finance company Agreement number Vehicle registration number Telephone recording details (identifier number, the number you call from, the number and option you dialled, the date and time of your call).
How to get in touch with us and your right to complain to our supervisory authority?We work hard to handle your information responsibly. If you are unhappy about the way we do this, or if you have any questions about this policy, please contact the Data Protection Officer. Our Data Protection Officer is Mr Alan Carreras and he may be contacted by email firstname.lastname@example.org or by post The Data Protection Officer Bridle Vehicle Leasing Hanborough Enterprises Ltd Tamarisk House North Leigh Business Park North Leigh Witney Oxfordshire OX29 6SW We hope that we will be able to resolve any concerns you may have. However, you have a right to complain to the UK’s Supervisory Authority for data protection, the Information Commissioner at: Information Commissioner's Office
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