At Autohorn Fleet Services Limited, your privacy is important to us. This policy will explain what personal information we collect, how it is used and how we keep it secure. We may change this Policy from time to time so please check this page to ensure you are happy with any changes. By using this website, you’re agreeing to be bound by this Policy. Should you have any questions regarding this Policy or about our privacy practices, please contact us by emailing sales@autohorn.co.uk or writing to Autohorn Fleet Services Ltd, The Engine Works, Fermetol Trading Estate, Leeman Road, York, YO26 4XD.

Who are we, what do we do?

Autohorn Fleet Services is a vehicle leasing and hire company and may operate under other brand names such as; Autohorn, Clear Car Leasing, Flexed, 1stCarLeasing and Europcar Daily Hire York. Autohorn Fleet Services Limited is registered in England and Wales company number: 3088452. Registered address: Autohorn Fleet Services Ltd, The Engine Works, Fermetol Trading Estate, Leeman Road, York, YO26 4XD. Autohorn Fleet Services is registered with the FCA (Financial Conduct Authority), registration number 672629, and a member of the BVRLA (British Vehicle Rental and Leasing Associated), member number 1919.

Types of information stored

We use many different kinds of personal information, and group them together like this.

Calls

Please note all of our calls are recorded for training and monitoring purposes.

Financial

Your financial position, status and history.

Contact

Where you live and how to contact you.

Socio-Demographic

This includes details about your work or profession, nationality, education and where you fit into general social or income groupings.

Transactional

Details about payments to and from your accounts with us, and insurance claims you make.

Contractual

Details about the products or services we provide to you.

Locational

Data we get about where you are, such as may come from your mobile phone, the address where you connect a computer to the internet, or in-vehicle connected technologies including GPS.

Behavioural

Details about how you use our products and services.

Technical

Details on the devices and technology you use.

Communications

What we learn about you from letters, emails, and conversations between us.

Social Relationships

Your family, friends, and other relationships.

Open Data and Public Records

Details about you that are in public records such as the Electoral Register, and information about you that is openly available on the internet.

Usage Data

Other data about how you use our products and services.

Documentary Data

Details about you that are stored in documents in different formats, or copies of them. This could include things like your passport, drivers licence, or birth certificate.

Special types of data

The law and other regulations treat some types of personal information as special. We will only collect and use these types of data if the law allows us to do so:

• Racial or ethnic origin
• Religious or philosophical beliefs
• Trade union membership
• Genetic and bio-metric data
• Health data including gender
• Criminal convictions and offences

Consents

Any permissions, consents, or preferences that you give us. This includes things like how you want us to contact you, whether you get paper statements, or prefer large-print formats.

National Identifier

A number or code given to you by a government to identify who you are, such as a National Insurance number.

How do we collect information from you?

We may collect personal information about (or your business) from companies within the Autohorn Fleet Services Group (such as Flexed/Autohorn/Europcar York) Data you give to us:

• When you apply for our products and services online
• When you talk to us on the phone or in branch
• When you use our websites, mobile device apps or web chat devicdes
• In emails and letters
• In insurance claims or other documents
• In financial reviews and interviews
• In customer surveys
• If you take part in our competitions or

Data we collect when you use our services. This includes the amount, frequency, type, location, origin and recipients:

• Payment and transaction
• Profile and usage data. This includes the profile you create to identify yourself when you connect to our internet, mobile and telephone services. It also includes other data about how you use those We gather this data from devices you use to connect to those services, such as computers and mobile phones, using cookies and other internet tracking software.

Data from third parties we work with:

• Companies that introduce you to us, including your employer
• Financial advisers
• Card associations
• Credit reference agencies
• Insurers
• Retailers
• Comparison websites
• Social networks
• Fraud prevention agencies
• Payroll service providers
• Land agents
• Public information sources such as Companies House
• Loyalty scheme operators
• Agents working on our behalf
• Market researchers
• Government and law enforcement

New Customers

When proceeding with a vehicle lease (either through Flexed, ClearCarLeasing or 1stCarLeasing) you will be required to provide information that will be used for a credit application. Some of this information (outlined below) will be passed to relevant third-party credit agencies to determine eligibility for leasing. We will collect details such as:

• Full name
• Registered address (current and previous)
• Contact numbers
• Email addresses
• Employment details (current and previous)
• Driving license details
• Bank details
• Income and expenditure details
• Payment details

In addition to this, we may ask for further supporting documents to be included as part of the application. These details are necessary to complete an accurate credit check and when requested, new contracts cannot be created without this information.

Existing Customers

Once your application is successful a vehicle is supplied to you, we need to store the information outlined below in order to provide our goods and services.

• Full name
• Registered address (current and previous)
• Contact numbers
• Email addresses
• Driving license details including:
  • Copy of Driving License
  • Driving License (DVLA) checks (if applicable)
• Bank details
• Completed application form including:
  • Employment history
  • Income and expenditure details
• Vehicle insurance details (if required) including:
  • Insurance policy
  • Insurance certificate
• Any supporting application documents e. completed Guarantor Forms

In some cases, we may contact you to ensure the information on the database is refreshed and kept up to date. However, won’t market to your existing details if you have not provided us with the consent to do so. Sometimes, we may share your contact information with third parties to help us provide a better service for you. For example, your name, address and phone number data may be shared with third party companies so we can arrange the delivery of your new vehicle.

Who do we share your personal information with?

We may share your personal information with companies within the Autohorn Fleet Services group and these organisations:

• Agents and advisers who we use to help run your accounts and services, collect what you owe, and explore new ways of doing business
• HM Revenue & Customs, regulators and other authorities
• UK Financial Services Compensation Scheme
• Credit reference agencies
• Fraud prevention agencies
• Any party linked with you or your business’s product or service
• Companies we have a joint venture or agreement to co-operate with
• Organisations that introduce you to us
• Companies that we introduce you to
• Market researchers and/or customer satisfaction survey providers
• Independent Financial Advisors
• Price comparison websites and similar companies that offer ways to research and apply for financial products and services
• Companies you ask us to share your data
• Police or other law enforcement agencies where required by law or to comply with the terms of the agreement.

We may need to share your personal information with other organisations to provide you with the product or service you have chosen:

• When placing a vehicle order or arranging delivery, we may pass your information to manufacturers, dealers and/or brokers and all companies within those manufacturer, dealer and/or broker groups for further possible business with you including marketing.
• If you ask us to provide additional services such as daily rental vehicles, accident management, vehicle servicing, maintenance and repair, replacement tyres and glass, breakdown and recovery, and European travel, we will need to share your information with those third party providers.
• If you use direct debits, we will share your data with the Direct Debit
• If you apply for insurance through us, we may pass your personal or business details to the insurer, and onto any reinsurers.
• If you make an insurance claim, information you give to us or the insurer may be put on a register of claims. This will be shared with other insurers.
• In the case of accidents, offences, fines including foreign fines, penalties, charges including congestion charges and private parking charges, and tolls, we may share you details with third parties who contact us regarding such matters.

In the case of early settlement quotations, we will (where required) provide this information to the supplying dealer or broker, and (with your consent) to any other dealer or broker who asks us for one.

Marketing your personal information

We may use your personal information to tell you about relevant products and offers. The personal information we have for you is made up of what you tell us, and data we collect when you use our services, or from third parties we work with. We study this to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you. We can only use your personal information to send you marketing messages if we have either your consent or a ‘legitimate interest’. That is when we have a business or commercial reason to use your information. It must not unfairly go against what is right and best for you. You can ask us to stop sending you marketing messages by contacting us at any time. Whatever you choose, you’ll still receive statements, and other important information such as changes to your existing products and services. We may ask you to confirm or update your choices, if you take out any new products or services with us in future. We will also ask you to do this if there are changes in the law, regulation, or the structure of our business. If you change your mind you can update your choices at any time by contacting us.

Credit Reference Agencies (CRAs)

We need carry out credit and identity checks when you apply for a product or services for you or your business. We will use Credit Reference Agencies to help us with this. If you use our services, from time to time we may also search information that the CRAs have, to help us manage those accounts. We will share your personal information with CRAs and they will give us information about you. The data we exchange can include:

• Name, address and date of birth
• Credit application
• Details of any shared credit
• Financial situation and history
• Public information, from sources such as the electoral register and Companies We’ll use this data to:
• Assess whether you or your business is able to afford to make repayments
• Make sure what you’ve told us is true and correct
• Help detect and prevent financial crime
• Manage accounts with us
• Trace and recover debts
• Make sure that we tell you about relevant

We will go on sharing your personal information with CRAs for as long as you are a customer. This will include details about your settled accounts and any debts not fully repaid on time. It will also include details of funds going into the account, and the account balance. If you borrow, it will also include details of your repayments and whether you repay in full and on time. The CRAs may give this information to other organisations that want to check credit status. We will also tell the CRAs when you settle your accounts with us. When we ask CRAs about you or your business, they will note it on your credit file. This is called a credit search. Other lenders may see this and we may see credit searches from other lenders. If you apply for a product with someone else, we will link your records with theirs. We will do the same if you tell us you have a spouse, partner or civil partner – or that you are in business with other partners or directors. You should tell them about this before you apply for a product or service. It is important that they know your records will be linked together, and that credit searches may be made on them. CRAs will also link your records together. These links will stay on your files unless one of you asks the CRAs 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 CRAs 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

Fraud Prevention Agencies (FPAs)

We may need to confirm your identity before we provide products or services to you or your business. Once you have become a customer of ours, we will also share your personal information as needed to help detect fraud and money-laundering risks. We use Fraud Prevention Agencies to help us with this. Both we and fraud prevention agencies can only use your personal information if we have a proper reason to do so. It must be needed either for us to obey the law, or for a ‘legitimate interest’. A legitimate interest is when we have a business or commercial reason to use your information. This must not unfairly go against what is right and best for you. We will use the information to:

• Confirm identities
• Help prevent fraud and money-laundering
• Fulfil any contracts you or your business has with

We or an FPA may allow law enforcement agencies to access your personal information. This is to support their duty to detect, investigate, prevent and prosecute crime. FPAs can keep personal information for different lengths of time. They can keep your data for up to six years if they find a risk of fraud or money-laundering.

FPA Information we will use

These are some of the kinds of personal information that we use:

• Name
• Date of birth
• Residential address
• History of where you have lived
• Contact details, such as email addresses and phone numbers
• Financial data
• Data relating to your or your businesses products or services
• Employment details
• Vehicle details
• Data that identifies computers or other devices you use to connect to the This includes your Internet Protocol (IP) address.

How we use your information

By entering into a rental or lease agreement, you agree that we can process and store your personal information in connection with this agreement including data collected from the vehicle. We may use your information to analyse statistics, for market research, credit control and to protect our assets. You agree that if you break the terms of this agreement we can pass your personal information to credit reference agencies, debt collectors, the police or any relevant organisation. We can also give this information to the British Vehicle Rental and Leasing Association (BVRLA), which can share your personal information with its members to prevent crime and protect their assets, as allowed under the Data Protection Act. Your information may also be recorded via in-car technology such as the Satellite Navigation System, Phone Book or Infotainment System. If this information is not cleared prior to the return of the lease, this may be accessible by our team members. However, we will always pre-check vehicles in between bookings to make ensure sensitive data is wiped from the car.

How do we protect your personal information?

Keeping your identity safe is our primary consideration. As such, we take all of the necessary technical and organisational measures to protect the confidentiality and security of your personal information. These efforts include, but not necessarily limited to:

• Storing your personal information in a secure working environment not available to the public and only accessible to authorized Autohorn Fleet Services Ltd employees.
• Using industry-standard SSL encryption (or similar) to protect the security of information stored online and through the use of UK-based private servers.
• Verifying identities of an authorised person(s) before they can access any personal information we hold about them.
• We also have measures to automatically-delete any information after a set time period as outlined in this Privacy Notice.

How long is my information kept for? Please refer to our retention schedule here. Who has access to my data/information? Your sensitive information will be viewable by authorized members of our organisation. By giving your permission you may also nominate an individual who you agree can deal with your lease in your absence. Your information may be required to be shared with third party companies for us to deliver our services. This could include (but not limited to) sharing data to obtain a credit decision or to be passed onto external companies to deliver your car. We may not be able to provide certain services without doing so. We also reserve the right to disclose your personal information to comply with applicable laws (such as the Data Protection Act 1998) and government or regulatory bodies’ lawful requests for information. You have the right to request a copy of all of your information held about you on file and have the right to be ‘forgotten’ as requested once all your hire/lease obligations have been completed. However, in some cases, we are required to keep some information for legal and auditing purposes.

If you decide not to provide your personal information

We may need to collect personal information by law, or under the terms of a contract we have with you. If you choose not to give us this personal information, it may delay or prevent us from meeting our obligations. It may also mean that we cannot perform services needed to run your accounts or policies. It could mean that we cancel a product or service you have with us. Any data collection that is optional would be made clear at the point of collection.

Letting us know if your information is incorrect

You have the right to question any information we have about you that you think is wrong or incomplete. Please contact us if you want to do this. If you do, we will take reasonable steps to check its accuracy and correct it.

Objecting to the use of your personal information

You have the right to object to our use of your personal information, or to ask us to delete, remove, or stop using your personal information if there is no need for us to keep it. This is known as the ‘right to object’ and ‘right to erasure’, or the ‘right to be forgotten’. There may be legal or other official reasons why we need to keep or use your data. But please tell us if you think that we should not be using it. We may sometimes be able to restrict the use of your data. This means that it can only be used for certain things, such as legal claims or to exercise legal rights. In this situation, we would not use or share your information in other ways while it is restricted. You can ask us to restrict the use of your personal information if:

• It is not
• It has been used unlawfully but you don’t want us to delete
• It not relevant any more, but you want us to keep it for use in legal
• You have already asked us to stop using your data but you are waiting for us to tell you if we are allowed to keep on using it.

If you want to object to how we use your data, or ask us to delete it or restrict how we use it or, please contact us.

Withdrawing Consent

 You can withdraw your consent at any time. Please contact us if you want to do so. If you withdraw your consent, we may not be able to provide certain products or services to you. If this is so, we will tell you.

Your data protection rights

Under data protection law, you have rights including:

Your right of access

• You have the right to ask us for copies of your personal

Your right to rectification

• You have the right to ask us to rectify information you think is You also have the right to ask us to complete information you think is incomplete.

Your right to erasure

• You have the right to ask us to erase your personal information in certain

Your right to restriction of processing

• You have the right to ask us to restrict the processing of your information in certain

Your right to object to processing

• You have the right to object to the processing of your personal data in certain

Your right to data portability

• You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. Please contact us at sales@autohorn.co.uk or call 01904 557 536 if you wish to make a request.

How can you contact us?

If you have any questions, complaints or queries regarding what’s been outlined in this Privacy Notice or how we collect our information then please contact us by:

• Emailing sales@autohorn.co.uk
• Calling our team on 01904 557 536

Or you can write to us by post to: Autohorn Fleet Services Ltd, The Engine Works, Fermetol Trading Estate, Leeman Road, York, YO26 4XD

How to complain

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:

Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF Helpline number: 0303 123 1113 Please note that Autohorn Fleet Services Ltd will occasionally update and make any corrections to this Privacy Notice. Please check back regularly to see these changes or how these might affect you.