1. Introduction

This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we'll store and handle that data, and keep it safe.

We know that there's a lot of information here, but we want you to be fully informed about your rights, and how XLCR Group uses your data. For example, we will explain things such as the credit checking procedure, and how we combine data across XLCR Group to build a picture of you.

We hope the following sections will answer any questions you have, but if not, please get in touch with us.

It is likely that we will need to update this Privacy Notice from time to time. We'll notify you of any significant changes, but you're welcome to come back and check whenever you wish.

When using the XLCR Group websites, XLCR Vehicle Management Ltd is the data controller.

2. Who are XLCR Group?

XLCR Group is made up of a number of related businesses:

• XLCR Vehicle Management Ltd (thebestcardeals.co.uk, thebestvandeals.co.uk and fourwheels.co.uk)
• Intelligent Vehicle Finance Ltd (intelligentvehiclefinance.co.uk, insuredlease.co.uk and insured.lease)
• XFleet Vehicle Retail Ltd (xfleetcars.co.uk and xfleetvans.co.uk)

For simplicity throughout this notice, "we" and "us" means XLCR Group and its brands.

3. Explaining the legal bases we rely on

The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:

Consent

In specific situations, we can collect and process data with your consent, for example, when you tick a box to receive information from us and details of offers.

When collecting your personal data, we will always make clear to you which data is necessary in connection with a particular service.

Contractual obligations

In certain circumstances, we need your personal data to comply with our contractual obligations. For example, we may need to collect your address details to deliver a vehicle to you, and pass those details onto the supplier or a logistics company.

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 involving XLCR Group to law enforcement.

Legitimate interest

In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedoms or interests. For example, we will use your order history to send you or make available personalised offers.

We also combine the order history of many customers to identify trends and ensure we can keep up with demand, or develop new offers or services.

We may also use your address details to send you direct marketing information by post, telling you about products and services that we think might interest you.

4. When do we collect your personal data?

• When you visit any of our websites
• When you purchase a product or service from us, or request a quotation
• When you engage with us on social media
• When you contact us by any means with queries, complaints, etc.
• When you enter prize draws or competitions
• When you choose to complete any surveys we send you
• When you fill in any forms online, on paper, by email or over the telephone, including credit application forms
• When you've given a third party permission to share with us the information they hold about you
• We collect data from publicly-available sources (such as Companies House) when you have given your consent to share information or where information is made public as a matter of law
• Our premises may have CCTV systems operated for the security of our staff and customers. These systems may record your image during your visit.

5. What sort of personal data do we collect?

• Details of your interactions with us, such as phone calls, emails or visits to our websites. For example, we collect notes from our conversations with you, details of any complaints or comments you make, details of the purchases you make, how and when you contact us.
• Details you provide to us for the purposes of applying for credit. This may include personal details such as your full name, date of birth, current and previous addresses, details of your income & expenditure, gender, nationality and so on.
• Copies of documents you provide to prove your identity or address where the law requires this (including your passport and driving licence). This will include details of your full name, address, date of birth, and facial image. If you provide a passport, the data will also include your place of birth, gender and nationality.
• Details of your visits to our websites and which site you came to ours from.
• Information gathered by the use of cookies in your web browser. You can learn more about how we use cookies and similar technology.
• Your image may be recorded on CCTV if you visit one of our offices.
• To deliver the best possible web experience, we collect technical information about your internet connection and browser, the web pages viewed during your visit, the advertisements you click on, and any search terms you entered. Learn more about this.
• Your social media username, if you interact with us through those channels, to help us to respond to your comments, questions or feedback.

How and why do we use your personal data?

We want to give you the best possible customer experience. One way to achieve this is to get the richest picture we can of who you are by combining the data we have about you.

We then use this to offer you promotions, products and services that are most likely to interest you.

The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.

Of course, if you wish to change how we use your data, you'll find details in the "What are my rights?" section below.

Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you've asked for.

Here's how we will use your personal data and why:

• To manage our relationship with you or your business, such as dealing with any enquiries, applications or orders you make. If we don't collect your personal data, we won't be able to deal with your enquiry, application or order and comply with our legal obligations. For example, your details may need to be passed to a third party to supply or deliver a product or service that you have ordered, and we may keep details for a reasonable period afterwards in order to fulfil contractual and legal obligations.
• To respond to your queries and complaints. Handling the information you send enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interest in providing you with the best service and understanding how we can improve our service based on your experience.
• To protect our business and you from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We will also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We'll do this as part of our legitimate interest.
• To protect our customers, premises, assets and staff from crime, we operate CCTV systems in our premises which record images for security. We do this on the basis of our legitimate business interests.
• To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
• If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. Our aim is to protect the individuals and businesses we interact with from criminal activities.
• With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text and telephone about relevant products and services including tailored special offers, discounts, promotions, events, competitions, etc. Of course, you are free to opt out of hearing from us by any of these channels at any time.
• To send you relevant, personalised communications by post in relation to updates, offers, services and products. We will do this on the basis of our legitimate business interest. You are free to opt out of hearing from us by post at any time.
• To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, product recall notices, and legally required information relating to your orders and applications. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we did not use your personal data for these purposes, we would be unable to comply with our legal obligations.
• To display the most interesting content on our websites, we may use data we hold about you. We do this on the basis of your consent for our website to place cookies or similar technology on your device. For example, we might display a list of vehicles you've recently looked at, or select offers to show you based on your order history with us and any other data you've shared with us.
• To administer any of our prize draws or competitions which you enter, based on your consent given at the time of entering.
• To develop, test and improve the systems, services and products we provide to you. We will do this on the basis of our legitimate business interests.
• To comply with our contractual or legal obligations to share data with law enforcement. For example, when a court order is submitted to share data with law enforcement agencies or a court of law.
• To send you survey and feedback requests to help us improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps us to make our products and services more relevant to you.
• To build a rich picture of who you are and what you like, and to inform our business decisions, we will combine data captured from across XLCR Group, third parties and data from publicly-available sources as we have described in the section "What sort of Personal Data do we collect?". We will do this on the basis of our legitimate business interest.

7. Combining your data for personalised direct marketing

We want to bring you offers and promotions that are most relevant to your interests at particular times. To help us form a better, overall understanding of you as a customer, we combine your personal data gathered across the XLCR Group as described above, for example your order and application history with us. For this purpose, we also combine the data that we collect directly from you with data that we obtain from third parties to whom you have given your consent to pass that data onto us, or data which is available as a matter of public record — such as information from Companies House.

8. How we protect your personal data

We know how much data security matters to all our customers. With this in mind, we will treat your data with the utmost care and take all appropriate steps to protect it.

We secure access to our websites using "https" technology.

Access to your personal data is password-protected, and sensitive data such as payment card information is tokenised to ensure it is protected.

We regularly monitor our systems for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.

9. How long will we keep your personal data?

Whenever we collect or process personal data, we will only keep it for as long as is necessary for the purpose for which it was collected.

At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.

Some examples of customer data retention periods:

Orders

If you become a customer of ours, we will keep the personal data you give us for up to ten years after you cease to be a customer so we can respond to any questions or complaints, show that we have treated you fairly, and maintain records to comply with our legal, regulatory and contractual obligations.

Who do we share your personal data with?

We share your personal data with trusted third parties, for example, the lenders and insurance companies which provide the finance and insurance contracts you order, dealers and vehicle manufacturers who supply and build the vehicles you order, logistics companies who deliver those vehicles, and so on.

Here's the policy we apply to those organisations to keep your data safe and protect your privacy:

• We provide only the information they need to perform their specific services
• They may only use your data for the exact purposes specified in the contract between us and them
• We work closely with them to ensure that your privacy is respected and protected at all times

Examples of the kind of third parties we work with are:

• Lenders who provide the finance products we supply to you
• Insurers and their administrators who underwrite and administer the insurance products we supply to you
• Credit reference agencies and fraud prevention agencies
• Vehicle manufacturers, dealers and suppliers
• IT companies who support our business systems
• Operational companies such as logistics/delivery companies
• Direct marketing companies who help us manage our electronic communications with you
• Companies such as Google and Facebook to show you products that might interest you while you're browsing the internet. This is based on either your marketing consent or your acceptance of cookies on our websites. See our Cookies Notice for details.
• Data insight companies to ensure your details are up to date and accurate

Sharing your data with third parties for their own purposes

We will only do this in very specific circumstances, for example:

• With your consent, given at the time you supply your personal data, we may pass that data to a third party for their direct marketing purposes.
• For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement agencies.
• We may also be required to disclose your personal data to the Police or other enforcement, regulatory or Government bodies, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.
• If you are involved in a road traffic accident or offence, or incur a fine, toll, Congestion Charge, penalty charge, private parking charge or similar, we may need to provide your personal data to the council, authority or company which issued it or contacted us about it
• We may, from time to time, expand, reduce or sell XLCR Group and this may involve the transfer of divisions or the whole business to new owners. If this happens, your personal data will, where relevant, be transferred to the new owner or controlling party, under the terms of this Privacy Notice.
• For further information, please contact our Data Protection Officer.

11. Where your personal data may be processed

Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA), such as the USA.

Protecting your data outside the EEA

The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway. We may transfer personal data that we collect from you to third-party data processors in countries that are outside the EEA.

If we do this, we have procedures in place to ensure your data receives the same standards of protection as if it were being processed inside the EEA. For example, our contracts with third parties stipulate the standards they must follow at all times. If you would like more information about these contracts, please contact our Data Protection Officer.

Any transfer of your personal data will follow the applicable laws and we will treat the information under the guiding principles of this Privacy Notice.

12. What are your rights over your personal data?

You have the right to request:

• access to the personal data we hold about you, free of charge in most cases
• the correction of your personal data when incorrect, out of data or incomplete
• that we stop using your personal data for direct marketing (either through specific channels, or all channels)
• that we stop any consent-based processing of your personal data after you withdraw that consent
• that an automated decision by one of our lenders is reviewed by a person

You have the right to request a copy of any information about you that XLCR Group holds at any time, and also to have that information corrected if inaccurate. To ask for your information, please contact the Data Protection Officer, XLCR Group, XLCR House, 35-43 Albert Road, Colne, BB8 0BU, or email [email protected]. To ask for your information to be amended, please contact our Customer Services team using the same email address, or by calling 08000 833 711.

If we choose not to action your request, we will explain to you the reasons for our refusal.

Your right to withdraw consent

Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.

Where we rely on our legitimate interest

In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

Direct marketing

You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.

Checking your identity

To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

13. How can you stop the use of your personal data for direct marketing?

There are several ways you can stop direct marketing communications from us:

• click the unsubscribe link in any email communication that we send you. We will then stop any further emails from that particular division.
• if you are completing an application online, updating your preferences when prompted during the application process
• you can contact us by writing to us, emailing us, texting us or calling us

Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.

14. Credit Reference Agencies

Our lenders will carry out credit and identity checks when you apply for a product or service for you or your business. They may use Credit Reference Agencies to help with this.

They will share your personal information with Credit Reference Agencies and they will give information about you to them. The data they exchange can include:

• your name, address and date of birth
• credit applications
• details of any shared credit
• your financial situation and history
• public information from sources such as the electoral register and Companies House

They will use this data to:

• assess whether you or your business is able to afford to make repayments
• make sure what you've told us and them is correct
• help detect and prevent financial crime
• manage your account with them
• trace and recover debts

If you become a customer of theirs, they will continue to share your information with Credit Reference Agencies for as long as you remain one of their customers. This will include details about your repayments and whether you repay in full and on time. The Credit Reference Agencies may give this information to other organisations that want to check your credit status. They will also tell the Credit Reference Agencies when you settle your accounts with them.

When they ask Credit Reference Agencies about you or your business, a credit search will be recorded on your credit file. Other lenders may see this.

If you apply for a product with someone else, they will link your records with theirs. They will also do this if you tell us you have a spouse, partner or civil partner, or if you are in business with other partners or directors. You should tell them about this before you apply for a product or service with us. It is important that they know that your records will be linked together, and that credit searches will be made on them.

The Credit Reference Agencies will also link your records together. These links will stay on your files unless one of you asks them to break the link. You will normally need to give proof that you no longer have a financial link with each other.

You can find out more about the Credit Reference Agencies on their websites, in the Credit Reference Agency Information Notice. This includes details about:

• who they are
• their role as fraud prevention agencies
• the data they hold and how they use it
• how they share personal information
• how long they can keep data
• your data protection rights

Here are the links to the information notice for each of the three main Credit Reference Agencies:

• Callcredit
• Equifax
• Experian

15. Automated decisions & credit scoring

As part of our lenders' credit checks, an automated decision may be made based on the personal information you provide, the information they already hold, and the information they collect from other sources, about you or your business. This helps to make sure their decisions are quick, fair, efficient and correct, based on what they know. These automated decisions can affect the products, services or features that they may offer you now or in the future, or the price they charge you for them.

When you provide your details for a credit application, you will be asked to consent to the application being processed using credit scoring. Some lenders will not be able to consider your application without this consent. Other lenders will allow you to request that they do not make their decision based on the automated score alone.

In all cases, you can object to an automated decision, and ask that a person review it.

16. Contacting the Regulator

If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner's Office.

You can contact them by calling 0303 123 1113, or visit www.ico.org.uk/concerns.

17. Any questions?

We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.

If you have any questions that haven't been covered, please contact us. Email [email protected], or write to the Data Protection Officer, XLCR Group, XLCR House, 35-43 Albert Road, Colne, BB8 0BU.

This notice was last updated on 12 March 2020.