This policy describes how we use your personal data when you use our website www.gatesleasing.co.uk, buy our goods or when we provide services to you. We have provided this policy to ensure that you understand what personal data we may collect and hold about you, what we may use it for and how we keep it safe. You have legal rights to access the personal data that we hold about you and to control how we use it.
Who we are and how you can contact us
We are Gates Leasing, Company Number 05259226. Our registered head office address is at Gates Corner, Edinburgh Way, Harlow, Essex, England. CM20 2EG.
You can contact us in writing at Gates Corner, Edinburgh Way, Harlow, Essex, England. CM20 2EG or by emailing firstname.lastname@example.org. If you would like to speak to us, please call us on 01438 366013.
Please refer to the sections on Our data protection team, Your rights to know what personal data we hold and to control how we use it and How to make a complaint for further contact information.
Our data protection team
We have a dedicated data protection team who oversee our handling of personal data.
You can contact our data protection team in writing at Gates of Stevenage, Arlington Business Park, Gunnelswood Road, Stevenage, Hertfordshire, SG1 2BE, or by email at email@example.com or by calling 01438 366013 (see Who are we and how you can contact us) and marking your correspondence for the attention of The Data Protection Team.
What personal data we collect about you
personal data that you provide to us. There are lots of ways in which you may share your personal data with us. For example, you may register on our website, post on social media sites that we run, or contact us in connection with goods or services that you would like to buy or have already bought from us. The personal data that you provide to us may include your name, address, e-mail address and phone number, financial and credit card information.
personal data that we receive from third parties. If we work with other businesses or use sub-contractors, these parties may collect personal data about you which they will share with us. For example, we may have your name and contact details passed to us by Ford Motor Company which refers you to us so that we can provide you with our goods or services, or receive feedback, or we may receive details from a finance company you are using to finance the lease of a vehicle through us.
personal data about your use of our website. This is technical information and includes details such as your IP address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, as well as details of how you navigated to our website and where you went when you left, what pages or products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and any phone number used to call our customer service number
What we use your personal data for
We use your personal data in the following ways: personal data that you provide to us is used to:
provide you with the information, products and services that you request from us
provide you with marketing information in accordance with your marketing preferences (see How we use your personal data for marketing)
manage and administer our business
review and improve our goods and services
personal data that we receive from third parties is combined with the personal data that you provide to us and used for the purposes described above.
personal data about your use of our website is used to:
administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
to improve our website and to ensure that content is presented in the most effective manner for you and for your computer or mobile device
to allow you to participate in interactive features of our service, when you choose to do so
as part of our efforts to keep our site safe and secure
to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you
to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them
A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and 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.
Overall, cookies help us 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.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
When we need your consent to use your personal data
Whilst we always want you to be aware of how we are using your personal data, this does not necessarily mean that we are required to ask for your consent before we can use it. In the day to day running of our business, we may use your personal data without asking for your consent because:
we are entering into and carrying out our obligations under a contract with you
we need to use your personal data for our own legitimate purposes (such as the administration and management of our business and the improvement of our services) and our doing so will not interfere with your privacy rights
In exceptional circumstances, we may wish to use your personal data for a different purpose which does require your consent. In these circumstances, we will contact you to explain how we wish to use your data and to ask for your consent. You are not required to give consent just because we ask for it. If you do give consent, you can change your mind and withdraw it at a later date.
Please refer to the section on How we use your personal data for marketing to read about marketing consents.
Personal data you are legally obliged to provide
You are not under a legal obligation to provide us with any of your personal data but please note that if you elect not to provide us with your personal data we may be unable to provide our goods or services to you.
Your rights to know what personal data we hold and to control how we use it
You have a legal right to know what personal data we hold about you - this is called the right of subject access. You can exercise this right by sending us a written request at any time. Please mark your letter “Subject Access Request” and send it to The Data Protection Team at Gates Leasing Ltd, Gates of Stevenage, Arlington Business Park, Gunnelswood Road, Stevenage, Hertfordshire. SG1 2BE or by email to firstname.lastname@example.org or by post or email using the details in the Who we are and how you can contact us (see the section on Our data protection Team for contact details).
You also have rights to:
prevent your personal data being used for marketing purposes (see How we use your personal data for marketing for further details)
have inaccurate personal data corrected, blocked or erased
object to decisions being made about you by automated means or to your personal data being used for profiling purposes
object to our using your personal data in ways that are likely to cause you damage or distress
restrict our use of your personal data
require that we delete your personal data
require that we provide you, or anyone that you nominate, with a copy of any personal data you have given us in a structured electronic form such as a CSV file
You can find full details of your personal data rights on the Information Commissioner’s Office website at www.ico.org.uk.
Automated decision making and profiling
We do not make use of automated decision making however, if you are requiring us to propose your details onto a finance company you need to be aware that in most cases they will use automated decision-making software.
When we will share your personal data with others
We share your data with the following people in the day to day running our business:
any business partners, suppliers and sub-contractors we work with to provide you with goods or services that you have requested from us
analytics and search engine providers that assist us in the improvement and optimisation of our site
Finance houses for the purpose of assessing your credit score where this is a condition of us entering into a contract with you
We may also share your personal information with third parties on a one-off basis, for example, if:
we sell or buy any business or assets (including our own), in which case we will disclose your personal data to the prospective seller or buyer of such business or assets
How we keep your personal data safe
We take every care to ensure that your personal data is kept secure. The security measures we take include:
only storing your personal data on our secure servers
ensuring that our staff receive data security awareness training
keeping paper records to a minimum and ensuring that those we do have are stored in locked filing cabinets on our office premises
maintaining up-to-date firewalls and anti-virus software to minimise the risk of unauthorised access to our systems
enforcing a strict policy on the use of mobile devices and out of office working
Unfortunately, sending 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 personal data sent to our website therefore you send us personal data at your own risk. Once we have received your personal data, we will use strict procedures and security features (some of which are described above) to try to prevent unauthorised access.
How we use your personal data for marketing
We will add your details to our marketing database if:
you make an enquiry about our goods or services
you buy our goods or services
you have told a third party that you would like them to pass us your contact details so that we can send you updates about our goods and services
you have registered an interest on our website regarding the goods or services we provide and have indicated during the sign-up process that you are happy to receive marketing communications
We may send you marketing communications by email, telephone, text message and post.
You can ask us to only send you marketing communications by particular methods (for example, you may be happy to receive emails from us but not telephone calls) or you may ask us not to send you any marketing communications at all.
We may ask you to indicate your marketing preferences when you first register an account on our website, visit one of our dealerships or telephone us. You can check and update your current marketing preferences at any time by calling or emailing us using the details set out in the Who we are and how you can contact us section above.
We will only share your personal data with third parties for marketing purposes if you provide us with your consent to do so by ticking a box on a form we use to collect your personal data.
When we will send your personal data to other countries
How long we keep your personal data
We only keep your personal data for as long as we actually need it. In practice, this means that we will keep:
Financial records of transactions for 7 years
your name and contact details for marketing purposes for 7 years from the last point we have supplied you with goods or services
your name and contact details for marketing purposes for 3 years in the event of you making an enquiry
a record of the goods and services (including a copy of your full customer file) we provide to you for 7 years
complaint records for 7 years
Please note that we may anonymise your personal data or use it for statistical purposes. We keep anonymised and statistical data indefinitely, but we take care to ensure that such data can no longer identify or be connected to any individual.
How you can make a complaint
If you are unhappy with the way we have used your personal data please contact our data protection Team to discuss this using the contact details set out in the section above. See Who we are and how you can contact us.
You are also entitled to make a complaint to the Information Commissioner’s Office which you can do by visiting www.ico.org.uk. Whilst you are not required to do so, we encourage you to contact us directly to discuss any concerns that you may have and to allow us an opportunity to address these before you contact the Information Commissioner’s Office.
How we keep this policy up to date
We will review and update this policy from time to time. This may be to reflect a change in the goods or services we offer or to our internal procedures or it may be to reflect a change in the law.
The easiest way to check for updates is by looking for the latest version of this policy on our website (www.gatesleasing.co.uk) or you can contact us by using the “contact us” tab on our website to ask us to send you the latest version of our policy.
Each time we update our policy we will update the policy version number shown in the footer and at the end of the policy and the date on which that version of the policy came into force.
This is policy version 1 which came into effect on 7/3/2018