We are committed to protecting and respecting your privacy. This privacy notice explains when and why we collect personal information, how we use it, the conditions under which we share it with other people and how we keep it secure.
This privacy notice applies to visitors to our Personal Contract Leasing (PCL) website, including individuals who have logged into our website and created accounts to quote or order PCL products and services from us, or organisations utilising our site to manage their schemes, or who have contacted us by telephone, e-mail or other means (including electronic means).
1 Who we are
We are Tuskerdirect Limited (known as Tusker), a company registered in England & Wales (company number 03864648) whose registered office is at Building 4 Hatters Lane, Croxley Green Business Park, Watford, Hertfordshire, United Kingdom, WD18 8YF.
We are a data controller for the purposes of the General Data Protection Regulation 2016 (GDPR).
Our registration number at the Information Commissioner's Office is Z668453X.
We are an appointed representative of Product Partnerships Limited (FRN 626349) for consumer credit activities, who are authorised and regulated by the Financial Conduct Authority (FCA).
2 How to contact us
If you have any questions about this privacy notice or our data protection policies generally, please contact us:
By post: Data Protection Officer, Building 4 Hatters Lane, Croxley Green Business Park, Watford, Hertfordshire, United Kingdom, WD18 8YF
By email: firstname.lastname@example.org
By phone: 0333 400 3696
3 Visitors to the website
3.1 What information do we collect and process?
When you visit our website we use third party services to automatically collect information about your computer, including your internet protocol (IP) address, information about your visit, your browsing history, and how you use our website.
If you receive an e-mail from us and you either click on a link in such e-mail or download any pictures contained in such e-mail, we can track information about your subsequent visit to our website and link this to your e-mail address.
If you contact us via our website, please see the "People who contact us" section below.
3.2 How is your information used?
Where this information includes contact details, we may also use this information to send you communications of products or services that may be of interest to you. Please see the "Marketing" section below for further details of our direct marketing policy.
3.3 Who has access to your information?
We may share statistical or aggregated data with our group companies and relevant third parties such as companies which undertake market research on our behalf. In addition, Google Analytics will have access to the website visitor information. We do not permit Google Analytics to access or process your data except in accordance with our instructions.
3.4 Lawful processing
When we process your personal data for the purposes of improving our website, we do so on the basis of our legitimate interests in maintaining a relevant and functioning website and improving customer experience.
We only use personal data obtained from the website to contact you if we feel we have a legitimate interest in informing you of the products and services we offer.
Users are any individuals who have logged into our website and created accounts to quote or order PCL products and services from us.
4.1 What information do we collect and process?
We receive information from you when you register an account with us (data available to view in the My Account area of our website), search our website for a vehicle, request a quote for a vehicle, order a vehicle from our site or communicate with us by phone, e-mail, live-chat or otherwise.
The personal data you provide may include your name, postal address, e-mail address, phone number, date of birth, salary, username & password, internet protocol (IP) Address, title & marital status, NI Number, Driver Licence number, Vehicle details, Payroll / Employee ID, digital signature (via DocuSign), financial and payment information, employment history, credit history, identification records and other information about yourself. This information is required to enable us to provide you with a vehicle or other related services and without this information we may not be able to offer you some of our products and services.
You may also provide contact details and other personal data when you voluntarily participate in a competition, special offer, promotion or survey or where you provide feedback on our products and services. You are not required to participate in any such promotions etc. or to provide feedback and this will not affect any of our services which we may provide to you.
We also collect information from Driving Licence agencies when assessing your application. Information may include details of any points on your licence.
4.2 How is your information used?
We will use your information to manage your account with us, contact you to discuss quotations, process any requests for quotes or any orders that you have submitted and carry out our obligations arising from any orders that you have entered into. In the process of fulfilling our obligations, we may contact you via email, phone, text / SMS, social media, post and LiveChat.
We may use the following automated decision making in regard to your personal data for elements of our services and products, for example to generate a list of vehicles for you, undertake driving licence checks and to generate quotes for vehicle insurance.
Credit Scoring & Crime Prevention
Close Brothers Limited, a company registered in England and Wales (company number 00195626) whose registered office is at 10 Crown Place, London, EC2A 4FT (“Close”), are also a data controller in relation to your personal data and any fair processing notice issued by Close also applies.
We use Close to provide credit for PCL vehicles. During the ordering process your personal information will be passed to Close so that an evaluation of affordability and credit can be carried out.
We only allow Close access to the minimum amount of personal information they need to perform credit search and to provide finance to you. This includes name, address, phone numbers and email addresses, date of birth, postal address, driving licence number, bank account information, employment history and salary.
Your information will be used;
- for making a credit check on you. Close may carry out a search with a credit reference agency who will keep a record of their enquiry against your name and which may be linked to a joint applicant (“associated records”). For the purposes of any application for products or services from us, you may be assessed with reference to “associated records”. Where any search or application is completed or agreement entered into involving joint parties, Close may record details at credit reference agencies, as a result an “association” will be created that will link your financial records. Details of which credit reference agency Close have used are available on request from Tusker. Close may also add to your record with the credit reference agencies details of your agreement with them, any payments you make under it and any default or failure to keep to its terms. These records will remain on the credit reference agencies’ files for 6 years after our agreement with you is settled or terminated whether settled by you or, if applicable, your business or by way of default, agreed settlement or court judgment. These credit reference agencies may create, or add to, their own record about you, or, if applicable, your business, details of our search and your application. This and other information about you or, if applicable, your business and those with whom you are linked financially may be used to make credit decisions about you or your business;
- Close may use credit scoring techniques and automated decision making systems to either fully or partially assess your information. This means Close may automatically decline the provision of financing (i) based on your credit profile with credit reference agencies; or (ii) based on information received from fraud prevention agencies regarding whether you pose a fraud or money laundering risk. These credit scoring techniques and automated decision making systems may take into account any previous applications for finance, defaults or existing debt. The results of this decision may decide whether we provide you with our services or not. If you disagree with the results of an automated decision, you can request a review of your application;
- to allow Close to detect and prevent fraudulent activity including sharing personal data with fraud prevention agencies;
- to allow Close to detect and prevent money laundering or terrorist financing activity; and
- to manage and administer monthly payments under any agreement made with you, including recovery of any outstanding debt.
You can send us a request to review the accuracy of an automated decision that you are unhappy with by contacting us by email: PCL@tuskerdirect.com or by telephone: 0333 400 3696.
Where you participate in a competition or complete a survey, we will only use your information for the purposes notified to you in connection with such competition or survey.
Where you provide feedback (whether by phone, e-mail, LiveChat or otherwise), we may use such information to improve our services to you or to address a concern raised with us.
4.3 Who has access to your information?
Our staff have access to your personal data to support and provide guidance on our products and services and to carry out our obligations arising from any orders that you have entered into.
We share your personal information with Close for them to carry out affordability and credit checking, provide finance and manage any late or defaulted payments for the PCL product. In carrying out such processing Close will share your information with credit reference agencies, details of which are set out at the end of this notice.
We may also share your information with other third party service providers, also known as Data Processors, to complete tasks and provide services to you on our behalf. However, when we use third party service providers, we only share the personal information that is necessary to deliver a service and our contract requires them to keep your information secure and not to use it for their own purposes, for example they will not use it for direct marketing purposes. Please be reassured that we will not release your information to third parties for them to use for their own purposes, unless you have requested us to do so, or we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime.
Examples of services where we may use third party service providers include:
- driving licence checks
- vehicle ordering, delivery and collection systems and services
- vehicle valuation
- vehicle dealerships
- vehicle insurance
- vehicle funders
- vehicle tracking (for vehicles that have factory fitted trackers)
- service bookings and garages
- breakdown and accident assistance
- tyres and windscreens
- fines management and debt recovery (eg parking fines, speeding fines)
- customer surveys, competitions and feedback
- direct debit and payment handling
- financial and accounting systems
- daily rental providers
- digital signature services
- BVRLA for customer complaint handling and for vehicle leasing risk management (RISC database)
We may share your personal data with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We may also disclose your personal data to third parties:
- in the event that we sell or buy any business or assets, we may if relevant disclose your personal data to the prospective seller or buyer of such business or assets; or
- if we, or substantially all, of our assets are acquired by a third party, personal data held by us about our customers will be one of the transferred assets; or
- for credit brokering activities, Tusker is an appointed representative of Product Partnerships Limited (PPL), who are authorised and regulated by the FCA. We may disclose personal data to PPL to help investigate and mediate customer complaints.
We may process (including disclose) your personal data in order to comply with any legal obligations binding on us and to protect the rights, property, or safety of our staff, our customers, or others. We may also process (including disclose) your personal data to:
- our legal advisors for the purpose of establishing, exercising or defending our legal rights;
- our auditors for the purpose of preparing management and statutory accounts.
In complying with legal obligations or establishing, exercising or defending our legal rights, we may share your personal data with the following (i) the Financial Conduct Authority; (ii) HM Revenue & Customs; (iii) Courts and tribunals (iv) any other applicable regulatory authority (v) legal advisors, accountants and auditors
4.4 Lawful processing
When we process your personal data for the purposes of processing quotes or orders, including rectifying your data to ensure its accuracy, we do so on the basis of performance of a contract with you or taking steps with the intention of entering into a contract with you for our products and services. If no contract is in place and you are using the website to carry out quotations, we will use your personal data to contact you and discuss quotations as a legitimate interest.
When we process your personal data for the administrative purposes or in order to secure funding, we do so on the basis that we have a legitimate interest in pursuing business aims and objectives.
When we process your personal data for legal purposes we do so on the basis that we have a legal obligation to do so (including our reporting obligations to the Financial Conduct Authority and HM Revenue & Customs, as well as our obligations under applicable legislation including the Money Laundering Regulations, Bribery Act 2010 and the Modern Slavery Act 2015) or such processing is necessary in order to protect the vital interests of a natural person, or is in our legitimate interests in establishing, exercising or defending our legal rights.
5 People who contact us by phone, e-mail, LiveChat or other means
5.1 What information do we collect and process?
Telephone - When you call us, we will collect your name and telephone number, and where relevant, we may collect other details including other contact details and information relating to any contract for products or services relating to you. All telephone calls are recorded.
E-mail - We will collect your name, e-mail address and the contents of your message and any attachments. If you click on a link to our website contained in an e-mail from us or if you download any pictures embedded in an e-mail from us, we collect information about any subsequent visit to our website, which will be linked to your e-mail address. Please see the "Visitors to our website" section above for further information.
LiveChat - We will collect your name, email address and a transcript of the LiveChat conversation.
Other social media - If you contact us via Facebook, LinkedIn or other social media, we will collect your name and/or online avatar and any other personal information that you make available to us on these platforms.
Business Contacts - You are considered a business contact if you are a sole trader, trustee, partner in a partnership, owner, director, officer or employee of a corporate entity. We may receive personal data about you as a business contact (in particular name, business or work contact details, details about who the individual works for, the individual's role in any such organisation and the individual's credentials) when you correspond with us or provide us with your business card etc.
We may also receive personal data about you from various third parties and public sources such as:
- from your business or from third party references or from professional advisors.
- from publicly available sources such as Companies House or your business's website.
5.2 How is your information used?
We may use any information obtained by phone, e-mail, LiveChat or other social media to:
- Help identify Tusker’s staff training needs and improve staff performance;
- Establish the facts in the event of a complaint either by a customer or a member of staff and so assist in resolving it;
- Send product related material through the post;
- Assist in quality control to identify any issues in processes;
- Customer assurance / security
Personal data relating to business contacts is used to manage our business relationships with professional advisors, regulatory authorities, public authorities, law enforcement agencies and others, which will include investigating complaints and defending our legal rights.
5.3 Who has access to your information?
Our staff have access to any personal data collected by phone, e-mail, LiveChat and social media, via our in-house customer management systems, so they can provide support and guidance and respond to customer queries.
We have a contractual agreement in place with a third party provider to supply and support our phone system and our LiveChat facility. We do not permit this provider to access or process your data except in accordance with our instructions.
We use social media (including Facebook and LinkedIn) in accordance with their terms and conditions, and subject to their respective privacy policies.
We will share information relating to business contacts with your business or organisation, our professional advisors and any applicable regulatory authorities, public authorities or law enforcement agencies or any other third party as may be required in the course of our relationship with you.
5.4 Lawful processing
When we process your personal data in connection with telephone calls, LiveChat sessions, e-mails or social media, we do so on the basis of our legitimate interests in discussing our products and services with you, in creating and retaining records of such communications for training purposes and for evidentiary purposes or to respond to customer queries.
Where you are a recipient of our products and services we process your personal data arising from telephone calls, LiveChat sessions, e-mails or social media on the basis of performance of a contract relating to you where such communications are relevant to such a contract.
When we process personal data in your capacity as a business contact, we do so on the basis that it is necessary for our legitimate interests to perform a contract with your organisation or business, to manage third party relationships, to run our business efficiently and profitably, to enhance, modify and improve our services and products, and to pursue our commercial objectives where this does not override your rights and freedoms as a data subject.
We would like to send you information about products and services we offer which may be of interest to you, as well as other information which may be relevant to you such as special offers or promotions.
6.1 Marketing communications
If you have provided us with business contact details, we will send you marketing information by post, telephone, e-mail, text or other electronic instant messages where it is in our legitimate interests in pursuing sales leads to do so (provided that you have not opted out of such communications and provided that it constitutes fair processing of your personal data to do so).
If you have provided us with personal contact details, we will only send you marketing e-mails or texts or other electronic instant messages where you have specifically consented to receive such communications. We may provide you with marketing information by post or by telephone where it is in our legitimate interests in pursuing sales leads to do so (provided that you have not opted out of such communications and provided that it constitutes fair processing of your personal data to do so).
6.2 Marketing preferences
You can set your marketing preferences in the My Account area of our website, including opting in or out of any particular type of marketing communication. If you have consented to receive marketing, you may opt out at a later date.
You can also opt out of any marketing communications by:
- clicking on the "unsubscribe" links in any marketing e-mails;
- emailing us at PCL@tuskerdirect.com;
- calling us on 0333 400 3696; or
- if you have signed up to receiving marketing from us by text, replying STOP to the last message you received from us.
Where you are a registered user of our website, you can set your marketing preferences within the registered user area of our website, including opting in and out of any particular type of marketing communication.
- If you have consented to receive marketing, you may opt out at a later date.
6.3 Who has access to your information?
Our marketing staff have access to any personal data obtained for marketing purposes. We will not sell or rent your information to third parties. We will not share your information with third parties for their marketing purposes.
We may also use the services of third party marketing companies and platforms, including;
- Customer surveys and feedback
- Product and service reviews
- Analytics platforms
- SMS services
- Emailing services
- Marketing printing and postal services
6.4 Lawful processing
When we process your business contact data for marketing purposes, we do so on the basis of our legitimate interests in pursuing sales leads to inform you of the services and products we offer.
When we process your personal contact data for marketing purposes, we do so on the basis of your consent or in limited circumstances on the basis of our legitimate interests in pursuing sales leads.
7 Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
We will usually retain your personal data for 7 years following the expiry of all contracts with us relating to you, unless we are obliged to retain your personal data for a longer period as a result of an overriding legal obligation. Such legal obligations include our reporting obligations to the Financial Conduct Authority and HM Revenue & Customs, as well as our obligations under applicable legislation including the Money Laundering Regulations, Bribery Act 2010 and the Modern Slavery Act 2015.
Personal data contained within a cookie is retained for as long as it is valid, accurate and up to date or until such time that you choose to unsubscribe.
When we anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes we may use this information indefinitely without further notice to you.
In some circumstances you can ask us to delete your data: see your right to request erasure below for further information.
8 How you can access and update your information
The accuracy of your information is important to us.
You can view and edit your contact details within the My Account area of our website, where you can also make choices about how we communicate with you. Or can you can contact us requesting an update to your information by email: PCL@tuskerdirect.com or by telephone: 0333 400 3696.
You also have the right to ask for a copy of the personal information and data we hold about you. All requests must be in writing, and it would be helpful if any such request also indicates what information you are seeking and between any particular dates. All requests for access to personal data should either be sent by email to: email@example.com or by post to: Data Protection Officer, Tuskerdirect Limited, 4 Hatters Lane, Croxley Green Business Park, Watford, Herts. WD18 8YF.
9 How secure is your information?
The secure protection of your information is extremely important to us, and we have implemented advanced controls and measures to remove risks to your information and protect against loss, misuse, or unauthorised access. Any personal information is protected with 128-Bit encryption. When you are on a secure page, a padlock icon will appear near the URL, showing that your connection with the Tusker website is secure and encrypted.
Tusker is certified to ISO27001:2013, which demonstrates we have an industry gold-standard security management system, which has been put in place to help safe guard and protect your information.
Our website may contain links to other third party 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 part of this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
10 Data transfers
We do not transfer any personal data outside of the European Economic Area (EEA).
11 Data protection complaints
All complaints regarding our handling of personal information will be logged and actioned by us and treated seriously. Any complaints of this nature should be made to the Data Protection Officer at firstname.lastname@example.org or in writing to Data Protection Officer, Tuskerdirect Limited, 4 Hatters Lane, Croxley Green Business Park, Watford, Herts, WD18 8YF.
You also have the right to lodge a complaint with a supervisory authority, which is the Information Commissioner’s Office (ICO) for the UK, about how we are processing your personal data.
12 Your rights
Your personal data is protected by legal rights, which include your rights to:
12.1 object to our processing of your personal data;
12.2 request that your personal data is erased, corrected or restricted;
12.3 request that any automatic decision-making or profiling is reviewed;
12.4 request access to your personal data;
12.5 request the transfer of your personal data to you or a third party; or
12.6 the right to withdraw consent at any time where processing is based on your consent, without affecting the lawfulness of any such processing prior to withdrawal of consent.
If you want to exercise any of these rights, please contact us using the details above.
13 Credit Reference Agencies
The three main credit reference agencies CallCredit, Equifax and Experian each use and share personal data they receive about you that is part of, derived from or used in credit activity and this is explained in more detail in the Credit Reference Agency Information Notice available at any of the following:
Consumer Services Team, PO Box 491, Leeds, LS3 1WZ
or call 0330 024 7574
Customer Service Centre, P.O. Box 10036, Leicester, LE3 4FS
or call 0800 014 2955
Customer Support Centre, PO Box 8000, Nottingham, NG80 7WF
or call 0344 481 0800
Our website is not intended for children and we do not knowingly collect data relating to children.
15 What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
16 Time to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
17 Changes to this Policy
We reserve the right to change the policy at any time, so please check back regularly to keep informed of updates to this Policy.
Last Updated: January 2019