1. Introduction

 

GRENKE Leasing Limited (UK) (the ‘Business’) understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, (‘Our Site’) and only collect and use your personal data as described in this Privacy Policy. Any personal data we collect will only be used as permitted by law.

 

Please read this Privacy Policy carefully and ensure that you understand it.

 

This Privacy Policy should be read in conjunction with the Website Terms and Conditions and Cookie Policy.

 

 

2. Information About Us

 

Our Data Protection Officer is Robin Spurr who is responsible for this policy, and we are regulated by the Financial Conduct Authority (FCA).

 

All personal information that we may use will be collected, processed, and held in accordance with the provisions of UK General Data Protection Regulation (UK GDPR), which sits alongside the Data Protection Act 2018 (DPA 2018). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to services we offer to individuals and our wider operations in the European Economic Area (EEA). Together, the UK GDPR and EU GDPR and referred to as ‘GDPR’.

 

If you have any questions about our Privacy Policy you can email us at [email protected].

 

 

3. What Does This Policy Cover?

 

This Privacy Policy applies only to your use of Our Site.

 

Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

 

 

4. What Is Personal Data?

 

Personal data is defined by the UK General Data Protection Regulation  (GDPR) and the Data Protection Act 2018 (collectively, the Data Protection Legislation) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

 

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

 

 

5. What are my rights?

 

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

• The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions by emailing [email protected].
• The right to access the personal data we hold about you.
• The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete.
• The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold.
• The right to restrict (i.e. prevent) the processing of your personal data.
• The right to object to us using your personal data for a particular purpose or purposes.
• The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
• The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
• Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

 

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Clause 10 (How Do I Contact You).

 

It is important that your personal data is kept accurate and up to date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

 

Further information about your rights can also be obtained from the Information Commissioner’s Office.

 

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Clause 10 (How Do I Contact You).

 

 

6. What personal data do we collect and how?

 

Subject to the following, we do not collect any personal data from you. We do not place cookies on your computer or device, nor do we use any other means of data collection.

 

If you send us an email or complete an enquiry form, we may collect your name, your email address, and any other information which you choose to give us. For the purposes of the Data Protection Legislation, We are the data controller responsible for such personal data.

 

The lawful basis under the Data Protection Legislation that allows us to use such information is article 6(1)(f) of the GDPR which allows us to process personal data when it is necessary for the purposes of our legitimate interests, in this case, the proper operation and functionality of Our Site.

 

If you contact us as described above, you will be required to consent to our use of your personal data to contact you. In this case, our lawful basis for using your personal data will be article 6(1)(a) of the GDPR, which allows us to use your personal data with your consent for a particular purpose or purposes.

 

Whilst we do not collect personal data via the website, every time you access a page and retrieve a file, this process automatically saves general data to a log file. The storage is exclusively system-related and is purely for statistical purposes or to report criminal offences in exceptional circumstances.

We use this data to improve our websites and to present content tailored to your interests on various sites on the internet and on multiple devices. As part of this process, usage data is not merged with personalised data. Should you decide to provide us with your data, this data will be backed up securely during the entry process. The same applies to the storage in our system. For security reasons, we store your IP address. This can be accessed in case of a legitimate interest.

 

We do not save your browser history. A transfer of data to third parties or any other evaluation does not take place, unless there is a legal obligation to do so.

In detail, the following data record is saved for each access: 

 

• Device used
• Name of the accessed file
• Date and time of access
• Time zone
• Transferred data volume
• Report as to whether the access was successful
• Description of the type of web browser used
• Operating system used
• The previously visited site
• Provider
• User's IP address  

 

 

7. How Do You Use My Personal Data?

 

Where we collect any personal data, it will be processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with our obligations and safeguard your rights under the Data Protection Legislation at all times. For more details on security see Clause 8 (How and Where Do You Store My Data?), below.

 

As stated above, we do not generally collect any personal data directly from you, but if you contact us and we obtain your personal details from your email, we may use them to respond to your email. The other technical data referred to above is necessary for the technical operation of Our Site

 

We will not share any of your personal data with any third parties for any purposes other than storage on an email and/or web hosting server.

 

If you provide specific information about your needs or your person in the context of other enquiries (e.g. during our leasing test), we will save your data for the purpose of processing your request (Article 6 (1) (b) GDPR) and in the event that further correspondence should take place.

If you expressly agree to be contacted by e-mail, telephone or post (according to Art. 6 Para. 1 a GDPR) within the scope of the contact form or another enquiry, you grant GRENKE AG, GRENKE Leasing Ltd (UK) and GC Factoring Ltd the opportunity to inform you in future by telephone, e-mail or post about current products and services, in the selected category. We may also store your data for the purpose of sending you our latest newsletter / eGuide. In addition, we store your IP address and the date of your registration in order to be able to prove your subscription in case of doubt. You can object to the use of your data for advertising purposes at any time or unsubscribe from the newsletter at any time by clicking on the unsubscribe link in the footer of the email.

 

If you do not give your consent, your data will be deleted after your request has been processed. Excluded from this is data for which legal or otherwise prescribed storage obligations exist. 

 

Within the framework of our contact forms we work with the Eloqua, a service of the provider ORACLE Nederland B.V., Hertogswetering 163, 3543 AS Utrecht, P.O. Box 40387, 3504 AD Utrecht, The Netherlands. For further information on the processing of data by Eloqua

 

 

8. How and Where Do You Store My Data?

 

We will store your personal data in the UK and the EEA. This means that it will be fully protected under the UK General Data Protection Regulation (UK GDPR), which sits alongside the Data Protection Act 2018 (DPA 2018) and the EU General Data Protection Regulation (EU GDPR).

 

 

9. How Can I Access My Personal Data?

 

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

 

All subject access requests should be made in writing and sent to the email or postal addresses shown in Clause 10 (How Do I Contact You).

 

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

 

We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

 

 

10. Cookie Policy

 

Please refer to our Cookie Policy.

 

 

11. Newsletters / eGuides

 

We are happy to inform you on the basis of your consent about the latest news with our newsletter/eGuides. 

 

In order to receive them, you must enter your name and e-mail address. You can also enter and submit further optional information. After you have submitted your e-mail address, you will receive an e-mail from us to the e-mail address you have specified, in which you must click a confirmation link to verify the e-mail address you provided. 

Your data will be stored by us only for the purposes of sending our newsletter/eGuide. In addition, we store your IP address and the date of your registration in order to be able to prove the subscription in case of doubt. 

 

In addition, in order to measure the success of our newsletter/eGuides, we collect data on whether the email is opened, when it is opened and which links are clicked.

 

For the delivery of our emails we work with the Eloqua service of the provider OR-ACLE Nederland B.V., Hertogswetering 163, 3543 AS Utrecht, P.O. Box 40387, 3504 AD Utrecht, The Netherlands. Emails sent with the help of Eloqua use tracking technologies. We use this data primarily to find out which topics are of interest to you by tracking whether our emails are opened and which links you click on. We then use this information to improve the emails we send you and the services we provide, and to link them to existing tracking or profiling information. We will not be able to track your emails if you have disabled the display of images in your email program by default. In this case, however, the newsletter will not be displayed in full and you may not be able to use all the features. If you display the images manually, the above-mentioned tracking will take place. For further information on using Eloqua.

 

You can unsubscribe from the newsletter at any time by clicking the unsubscribe link at the bottom of the email.

 

 

12. Data Processing for Competitions

 

When you participate in competitions, we process personal data that we receive from you, e.g. your name, email address and, if applicable, your customer number and other data, in order to enable you to participate in the competition. We will inform you within the scope of the competition as to which of your details are required for participation.

 

The data is processed in order to provide, conduct and handle competitions. We process personal data of participants in sweepstakes and competitions only in compliance with the relevant data protection provisions. The legal bases for the data processing are Art. 6 para. 1 lit. b GDPR in relation to data processing for conducting the competition and otherwise Art. 6 para. 1 lit. f GDPR, insofar as the processing serves our legitimate interests (e.g. in the security of the competition; in the protection of our interests against misuse through possible recording of IP addresses when competition entries are submitted). Insofar as we ask you for your consent to send advertising via email as part of the competition and you give us your consent to do so, the legal basis for this processing is Art. 6 para. 1 lit. a GDPR.

 

Participants' data will only be transmitted to other bodies if this is necessary for conducting the competition (e.g. for the purpose of sending prizes) or if a participant has consented to the transmission. External recipients may also be external service providers who help us carry out the competition as our processors, for example when we use entry forms as part of the competition. These processors are carefully selected and regularly reviewed by us. You may only use the data for the purposes specified by us and in accordance with our instructions.

 

Participants' data will be deleted when the data is no longer required to carry out the competition and we no longer require the data to achieve the purposes delineated. Data may be processed after the competition has come to an end in particular in the following situations: if we answer queries about the prizes or fulfil the prize benefits; in this case, the retention period also depends on the type of prize and may be up to three years, in particular in the case of goods or services, in order to be able to process warranty cases, for example. Furthermore, the participants' data may be stored for longer in individual cases, e.g. in the case of reporting on the competition in online and offline media. If data was also collected for other purposes within the scope of the competition, its processing and the retention period depend on the prerequisites for this use (e.g. in order to subscribe to a newsletter within the scope of a competition, see the privacy notice for the newsletter under lit. d).

 

 

13. Data analysis and Third-Party Systems

We use the following Third-Party Systems on our website to assist in data analysis.

 

a. Piwik

 

We use Piwik, a software for statistical evaluation of user access.

 

Your IP address will be abbreviated before it is saved. However, Piwik uses cookies that are stored on users' computers and enable the user’s use of the website to be analysed. In this case, pseudonymous usage profiles of the users can be created from the processed data. The information generated by the cookie regarding your use of this online content is stored on our server and not passed on to third parties. 

You can revoke your consent to this data processing as follows:

b. Use of Eloqua

 

Eloqua will use corresponding cookies that are stored on your computer and that enable an analysis of the use of the website (hereinafter referred to as usage behaviour). If you have already used a website that uses Eloqua, you may already have an Eloqua cookie. Even if this cookie is set on other websites, the information from your visit to our websites is only visible to us and is not shared with Oracle or any other users of the Eloqua system. It is also not possible for us to use this cookie to record or view information about your visits to any other websites.

 

The information generated by the cookie about your use of this website is transferred to a server and stored there. On our behalf, Eloqua uses this information to evaluate your use of the website and to compile reports on website activity. If you wish to prevent the use of Eloqua cookies or the evaluation of usage behaviour on your device in the future, this is possible via the following link: Eloqua Opt-Out .

 

If you enter personal data (e.g. in the contact form) during your visit to the website, this data will be processed with the usage behaviour in order to offer you content on the website and in our newsletter that is geared to your interests, as well as to be able to send you news and information about our company or our range of services based on your data, which are geared to your individual interests. For this purpose, it is technically necessary that we combine your accrued and given data in user profiles and evaluate them for the aforementioned purposes. This is done internally and only for the aforementioned purposes.

 

The legal basis for the pseudonymous evaluation of the use of our website is your consent (Article 6 (1) (a) GDPR), which you may have given us in the course of using our website.

 

The information generated by the cookie about your use of this website is transferred to a server and stored there. On our behalf, Eloqua uses this information to evaluate your use of the website and to compile reports on website activity. If you wish to prevent the use of Eloqua cookies or the evaluation of usage behaviour on your device in the future, this is possible via the following link: Eloqua Opt-Out .

 

You can find further information on data protection in connection with the use of Eloqua here: Oracle Privacy Policy.

 

 

c. Use of Facebook Meta Pixel

 

On our website we use the so-called “Facebook pixel” from “Facebook” (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2 Ireland). With the Facebook pixel we can classify the visitors of our website into certain target groups in or-der to be able to show you advertisements ("Ads") on Facebook.

 

The recorded data (e.g. IP addresses, information about the web browser, the location of the website, buttons clicked, possibly pixel IDs and other features) cannot be viewed by us, but can only be used in the context of displaying certain advertisements. When the Facebook pixel code is used, cookies are also set.

 

If you have a Facebook account and are logged in, your visit to this website will be assigned to your Facebook user account.

 

In order to exchange the respective data, your browser automatically establishes a direct connection with the Facebook server. We have no influence on the scope and further use of the data that is collected by Facebook through the use of this tool and therefore inform you according to our level of knowledge. By integrating the Facebook Pixel, Facebook receives the information that you are visiting the corresponding site of our website and that you have accessed or clicked on one of our advertisements. If you are registered with a Facebook service, Facebook can assign the visit to your account. Even if you are not registered with Facebook or have not logged in, there is the possibility that the provider will find out and save your IP address and other identification features.

• You can find out how the Facebook pixel is used for advertising campaigns at https://www.facebook.com/business/learn/facebook-ads-pixel

• You can find more information on Facebook's privacy policy at https://www.facebook.com/policy.php

• Further information on data processing by Facebook is available at https://www.facebook.com/about/privacy

We use these functions in order to be able to present you with offers that match your interests.

 

We store your data as long as we need it for the respective purpose (display of interest-based advertising), or as long as you have not objected to the storage of your data or have revoked your consent. The deactivation of the “Facebook Custom Audiences” function is possible for logged-in users at https://www.facebook.com/settings/?tab=ads#. You can change your settings for advertisements in Facebook using this link.

 

 

d. Google Ad Manager and Google Analytics

 

We use Google Ad Manager Click from Google Ireland Limited, Gordon House, Bar-row Street, Dublin 4, Ireland. With this technology, cookies are set which evaluate how you use our website and which enable your browser to be recognized when you visit websites that belong to the Google advertising network. For this purpose, the Google Analytics tracking code uses so-called double click cookies in addition to the Google Analytics cookies. These collect data on which third-party websites in the Google Dis-play Network you have visited and which advertisements you have clicked on. In addition, data from first-party cookies (e.g. Google Analytics cookies) and third-party cookies (e.g. Google cookie for display preferences) are linked. This enables us to evaluate the display of advertisements and your interaction with these advertisements.

 

We use Google Ads Conversion Tracking. With this technology, cookies are set when you interact with one of our advertisements, e.g. click on it. Cookies are used to analyse what happens after you have interacted with an advertisement, e.g. whether you have bought our product, viewed the ad from a mobile phone, downloaded our app or signed up for a newsletter.

 

We use this technology to present you with interest-based advertisements on other websites in the Google advertising network. The advertisements relate to content that you have previously viewed on our website.

 

The data that are collected via the Google functions are saved and regularly deleted.

 

You can prevent the storage of cookies by making the appropriate setting in your browser.

 

You can also prevent Google from collecting the data and processing the data by down-loading and installing the browser add-on available under the following link.

 

Google Dynamic Remarketing and Double Click as well as Google Ads Conversion Tracking: You can object to the storage of cookies and the associated data processing by deactivating personalized advertising via your advertising settings. You can deactivate the use of cookies by third-party providers via the deactivation website of the net-work advertising initiative. Alternatively, you can deactivate double-click cookies by installing a browser plug-in.

 

This can restrict the functionality of our website. You can find further information in the Google privacy policy.

 

 

e. LinkedIn Insights and Conversion Tracking

 

We use the LinkedIn Insight Tag of the provider LinkedIn Corporation, 2029 Stierlin Court, Mountain View, California 94043, USA for this website. The LinkedIn Insight Tag creates a LinkedIn "browser cookie" which collects the following data:

• IP address,

• time stamp,

• page activities,

• demographic data from LinkedIn, if the user is an active LinkedIn member.

 

This technology enables us to generate reports on the performance of our advertisements and information on website interaction. For this purpose, the LinkedIn Insight Tag is integrated on this website, which establishes a connection to the LinkedIn server if you visit this website and are logged into your LinkedIn account at the same time.

 

We Use LinkedIn Ad Campaigns to engage our target audience using the LinkedIn platform to provide engagement through leads. Such activity may include:-

• Sponsored Content – engagement through the LinkedIn news feed

• Sponsored Messaging – engagement through the LinkedIn Messaging function

• Lead Gen Forms – through LinkedIn ads.

• Text and Dynamic Ads – display ads on LinkedIn.

 

We process your data in order to evaluate campaigns and to collect information about website visitors who may have reached us through our campaigns on LinkedIn.

 

We store your data as long as we need it for the respective purpose (campaign evaluation), or you have not objected to the storage of your data or have revoked your consent.

 

The collected data is encrypted. More information can be found here. Here you will find the LinkedIn privacy policy and the LinkedIn opt-out.

 

 

f. Google Maps

 

We integrate the maps of the service "Google Maps" provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The data processed may include, but is not limited to, the IP addresses and location data of users, which, however, are not collected without their consent (usually performed as part of the settings of their mobile devices). Unless you have expressly consented to the use, our legal basis for this data processing is our legitimate interest in order to design our website to meet your needs. The data could also be processed in the USA. Privacy policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated

 

 

g. YouTube

 

By playing a video on our website, you consent to the processing of personal data such as your IP address or browser information which may be transmitted to YouTube and, if necessary, merged with existing data. YouTube is a service provided via a European subsidiary by a provider from the USA (Google LLC), where the level of data protection is inadequate by EU standards. Access from this side or from US authorities cannot be completely ruled out.

 

 

h. Trustpilot

 

 

We use Trustpilot who are Trustpilot A/S, Pilestraede 58, 5th floor, DK-1112 Copenhagen K, which is the entity responsible for processing your personal data.

 

Trustpilot is an online review community that's open to everyone to use be that customers, businesses and the community. Trustpilot is an online review community that connects businesses and consumers through genuine feedback from customers about their buying and service experiences.

 

Trustpilot automates the customer feedback process.

 

When leaving a review, using Trustpilot, the data you submit is collected by Trustpilot and is made available, electronically, to Grenke enabling the analysis of feedback provided by our Customers.

 

 

14. How Do I Contact You?

 

To contact us about anything to do with your personal data and data protection, including to make a subject access request you should email [email protected].

 

 

15. Changes to this Privacy Policy

 

We may change this Privacy Policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

 

Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up to date.

 

Any printed version of this policy should be considered obsolete.