USER WEBSITE AND COMMUNICATION PRIVACY NOTICE
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 registered users of our website, including individuals who have logged into our website and created accounts to quote or order products and services from us, or organisations utilising our site to manage their schemes.
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 Data Protection Act 1998 (DPA) and the General Data Protection Regulation 2016 (GDPR). Our registration number at the Information Commissioner's Office is Z668453X.
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: Andrew Beard, Data Protection Officer, Building 4 Hatters Lane, Croxley Green Business Park, Watford, Hertfordshire, United Kingdom, WD18 8YF
By email: email@example.com
By phone: 0333 400 2020
Users are any individuals who have logged into our website (as hosted via any domain name registered in our name) and created accounts to quote or order products and services from us. This includes organisations utilising our website to manage their employee benefit schemes provided by us.
3.1 What information do we collect and process?
We receive information from you when you register an account with us, 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, payroll ID 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.
Your employer may register an account with us and provide us with your personal data in connection with your employer's employee benefit scheme. This data may include name, email address and payroll or employee id. This information will be used by our system to verify that you are employed by your employer and will allow you to sign in and register your details, enabling you to fully utilise our 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.
3.2 How is your information used?
We will use your information to manage your account with us (in the My Account area of our website), 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.
Your employer will also use this information to review and accept any orders you place within our website and to manage the car benefit scheme.
We may use 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, using your details to retrieve and display vehicles that are within the affordability parameters and filters you have specified
- undertake driving licence checks, to ensure that you are legal to drive
- generate quotes for vehicle insurance, using your personal and vehicle details to calculate an insurance premium
You can send us a request to review the accuracy of a decision that you are unhappy with by contacting us by email: firstname.lastname@example.org or by telephone: 0333 400 2020.
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.
3.3 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.
Your employer also has access to your information to review and accept any orders you place within our website and to manage the car benefit scheme.
We may share your information with our 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 direct marketing. 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, services and agents
- vehicle dealerships
- vehicle insurance
- 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
- 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 we obtain funding for providing you with the vehicle, we may disclose your personal data to our funder;
- for the purpose of securing funding on your behalf with financial services organisations, including companies which provide hire-purchase funding and banks providing such funding, we may provide personal data to enable such financial services organisations to carry out necessary searches in order to enable them to make a funding decision for you and meeting their legal and regulatory requirements. In addition, these funders may share your data within their group of companies who provide services to them and so that they and any other companies in their group can look after your relationship with us and them;
- 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;
- 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;
- if you do not pay your debt (for example parking or speeding fines), we may transfer your debt to another organisation and give them details about you and that debt; or
- if you hold an insurance policy with us, we will pass information to the insurer to manage your insurance (including underwriting and claims, to help develop new services and to assess financial and insurance risk).
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.
3.4 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 relating to you (via your employer) or taking steps with the intention of entering into a contract relating to you (via your employer) for our products or services.
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 defendng our legal rights.
5. Data Retention
We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our contracts.
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.
6. 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: email@example.com or by telephone: 0333 400 2020.
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 any time periods. All requests for access to personal data should either be sent by email to: firstname.lastname@example.org or by post to: Data Protection Officer, Tuskerdirect Limited, 4 Hatters Lane, Croxley Green Business Park, Watford, Herts. WD18 8YF.
7. 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. We are also fully accredited members of the Direct Marketing Association (DMA) and subscribe to their Code of Practice.
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.
8. Data transfers
We do not transfer any personal data outside of the European Economic Area (EEA).
9. 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 email@example.com 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.
10. Your rights
Your personal data is protected by legal rights, which include your rights to:
10.1. object to our processing of your personal data;
10.2. request that your personal data is erased or corrected or restricted;
10.3. request that any automatic decision-making or profiling is reviewed;
10.4. request access to your personal data;
10.5. request the transfer of your personal data to you or a third party; or
10.6. 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.
11. 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.
Version: 2.1 - Updated: 12/09/2018