PRIVACY AND COOKIES POLICY

1. INTRODUCTION

About us

In this Privacy Notice and Cookie Policy references to “we” or “us” or “WeFlex” are to:  WeFlex Ltd, a company registered in England and Wales (company number 09704423), and its subsidiaries (listed below).  We act as data controllers in respect of the personal data that we process.

WeFlex Ltd’s subsidiaries

  • WeFlex Car Sales Ltd, company number 10226992
  • WeFlex Cover Ltd, company number 11143023
  • WeFlex 5 Ltd, company number 11006325
  • WeFlex 4 Ltd, company number 10541262
  • WeFlex 3 Ltd, company number 10241120
  • WeFlex 1 Ltd, company number 09938689
  • WeFlex 2 Ltd, company number 09939252

If you have any questions about how we collect, store or use your information, or you would like to update the information we hold about you, you may contact us by writing to us at The Dock 50 Porters Walk, Wapping Lane, London, England, E1W 2SF or emailing support@weflex.co.uk.

About this Privacy Notice and Cookie Policy

This Privacy Notice and Cookie Policy tells you what personal data we collect, why we need it, how we use it and what protections are in place to keep your personal data secure.

It applies to all visitors to our website in addition to our prospective and existing customers and third party suppliers. It should be read in conjunction with any other privacy notices and information that we provide to you on how we use your personal data.

We may change the content of our website and how we use cookies without notice, and consequently our Privacy Notice and Cookie Policy may change from time to time in the future. Any changes we may make to this policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. We therefore encourage you to review our Privacy Notice and Cookie Policy when you visit the website from time to time to stay informed of how we are using your personal data.

This Privacy Policy and Cookie Policy was last updated in June 2018.

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

What is personal data?

         Your personal data is information about you, and any information from which you can be identified – either by reference to an identifier (e.g. your name, location data or online identifier (IP address)) or from factors specific to your physical, cultural or social identity.

2. WHO DO WE COLLECT PERSONAL DATA FROM?

We may collect personal data:

  • From you, where you visit our website;
  • From you, where you fill in forms on our website, visit our offices in person or contact us by phone, email or otherwise; and
  • From our third party suppliers.

3. HOW DO WE COLLECT PERSONAL DATA?

Information provided to us by you

Personal data is provided to us by you:

  • When you enter information into our website, e.g. when you register to use our website, when you enter details into our online enquiry form, when you apply for our FlexiLease product, our FlexiBuy product or our short-term vehicle rental product and when you report a problem with our site;
  • When you visit our offices in person; and
  • When you contact us by email, by telephone or by post.

Information collected automatically by us

Personal data is collected by us automatically, when you visit our website – details of this are set out in section 4.

Information provided to us by third parties

Personal data is provided to us by third parties – details of this are set out in section 4.

4. WHAT PERSONAL DATA DO WE COLLECT AND PROCESS?

Information provided to us by you

Personal data provided to us by you may include, as applicable:

  • Your name, address, e-mail address and phone number;
  • Your date of birth, your marital status, your gender, your employment history, whether you own or rent your home and which of our products and services you are interested in;
  • Data on your income, your savings, your debt history, other financial details, your bank information and credit card information;
  • Whether you have a PCO/PHV licence, your licence details, whether you work on the Uber or another platform and information on your work patterns; and
  • Proof of identity, including your passport, driving licence, your National Insurance number and utility bills.

Information collected automatically by us

Personal data collected by us automatically, when you visit our website, may include:

  • Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
  • Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time);
  • Products and services you viewed or searched for;
  • Page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number; and
  • Interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

Information provided to us by third parties

We work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, analytics providers, search information providers and credit reference agencies) and may receive information about you from them.

5. WHAT DO WE USE YOUR PERSONAL DATA FOR?

What your personal data is used for

We use your personal data for the following purposes:

Information you give to us

We will use this information:

  • To enter into contracts with you, where applicable;
  • To carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us. This includes adding you as a beneficiary under the WeFlex insurance policy where you have requested this, and administering details of accidents and insurance claims; and
  • To notify you about changes to our products and services.

In these circumstances, the legal basis for processing the data is our legitimate interest in operating our business, including the handling of insurance claims. The processing of your personal data will, in many cases, also be necessary for the performance of our contract with you, or to take steps at your request prior to entering into a contract with you.

We will also use this information to comply with our legal obligations, e.g. where we are obliged to disclose information under orders from courts and regulators. In such circumstances, our legal basis for processing the personal data will be compliance with a legal obligation.

In addition, we will use the information that you provide to us:

  • To provide you with information about other products and services we offer that are similar to those that you have already purchased or enquired about; and
  • To provide you, or permit selected third parties to provide you, with information about products or services we feel may interest you, to notify you of special offers or to carry out market research.

In these circumstances, the legal basis for processing the data is our legitimate interests. We have a legitimate interest in keeping you informed about our products and services that may be of interest to you. Please note that when we send you marketing communications, there are separate laws that we adhere to, in addition to data protection laws.

If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about products and services similar to those which have already been provided to you. If you are a prospective customer, we will contact you by electronic means only if you have consented to this.

Where we permit selected third parties to use your data (whether you are an existing or prospective customer), they will contact you by electronic means only if you have consented to this.

If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data (i.e. the application form). You may opt out of receiving marketing communications from us at any time by contacting us at support@weflex.co.uk, and each marketing communication that we send provides a straightforward means of opting out.

Where you are a customer, we may collect vehicle telematics data as further described in our contract with you. This data is used in the legitimate interests of WeFlex, to help ensure that our vehicles are driven responsibly and to help us to comply with our own third party contracts, where applicable.

Information collected automatically by us

We will use this information:

  • To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • To improve our site to ensure that content is presented in the most effective manner for you and for your computer;
  • To allow you to participate in interactive features of our service, when you choose to do so;
  • As part of our efforts to keep our site safe and secure;
  • To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
  • To ensure that content from our site is presented in the most effective manner for you and for your computer; and
  • To make suggestions and recommendations to you and other users of our site about products or services that may interest you or them.

In these circumstances, the legal basis for processing the data is our legitimate interest in administering and improving our website and its features, and keeping our website secure.

Information provided to us by third parties

We may combine this information with information you give to us and information we collect about you. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive).

Automated decision-making

Where you wish to enter into an agreement with us, WeFlex will carry out an automated ‘scoring’ process as part of your application, to tell us whether you meet the relevant criteria. Please note that the results of this process are always reviewed by a member of the WeFlex team – we consider each application carefully and do not accept or reject any applications solely on the basis of the automated ‘scoring’ process.

What happens if I do not provide my personal data?

         Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

6. WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?

Your personal information

We may share your personal information 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. Details of the current members of the WeFlex group are provided in section 1.

We may pass your personal data on to third party service providers contracted to WeFlex in the course of dealing with you. Any third parties that we share your personal data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on our behalf. When they no longer need your personal data to fulfil this service, they will dispose of the details in line with WeFlex’s procedures.

We may share your personal information with the following third parties, where relevant:

  • Our staff, agents and contractors;
  • Our professional advisors;
  • Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
  • Credit reference agencies (see the section on credit reference agencies below for further detail on this); and
  • Analytics and search engine providers that assist us in the improvement and optimisation of our site.

We may also share your information with third parties such as regulatory authorities, or where we are under a legal obligation to disclose your information (for example where we are required to share information in accordance with legislation, to prevent fraud and other criminal offences, or because of a court order). We may disclose your information in order to enforce our legal rights or to protect the legal rights of our members or others.

In addition to the above, we may disclose your personal data to third parties:

  • in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; and/or
  • if WeFlex Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

Credit reference agencies

In order to process your application we will supply your personal information to credit reference agencies (CRAs) and they will give us information about you, such as about your financial history. We do this to assess creditworthiness and product suitability, check your identity, manage your account, trace and recover debts and prevent criminal activity.

We will also continue to exchange information about you with CRAs on an ongoing basis, including about your settled accounts and any debts not fully repaid on time. CRAs will share your information with other organisations.

The identities of the CRAs, and the ways in which they use and share personal information, are explained in more detail at:

Call Credit

www.callcredit.co.uk/crain

Equifax

www.equifax.co.uk/crain

Experian

www.experian.co.uk/crain

7. HOW DO WE KEEP YOUR PERSONAL INFORMATION SAFE?

What we do

We have security measures in place to restrict access to personal data, to guard against unauthorised or unlawful processing of personal information and against damage to, accidental loss or destruction of, your personal information.

The security measures applied include storing your personal information on secure servers, encrypting transfers of personal data to or from our servers, and only granting access to your personal information where necessary.

Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Third parties

The terms of our contracts with third party contractors include obligations on them in relation to what personal information they can process and what they can do with that information to ensure that such processing meets or exceeds the standards required by data protection law.

8. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?

WeFlex will process collect, store and use the information you provide in a manner compatible with applicable data protection law and other legislation. We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. We are required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices.

We keep your personal information only for as long as is reasonably necessary for the purposes for which we process your personal information. These purposes are listed at section 5 of this Privacy Notice and Cookie Policy.

9. INTERNATIONAL TRANSFERS

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the processing of your payment details.

10. YOUR RIGHTS

You have certain rights under data protection legislation in relation to the personal information that we hold about you. These rights apply only in particular circumstances and are subject to certain exemptions such as public interest (for example the prevention of crime). They include:

  • The right to access your personal information;
  • The right to rectification of your personal information;
  • The right to erasure of your personal data;
  • The right to restrict or object to the processing of your personal data;
  • The right to object to the use of your data for direct marketing purposes;
  • The right to data portability;
  • Where the justification for processing is based on your consent, the right to withdraw such consent at any time; and
  • The right to complain to the Information Commissioner’s Office about the use of your personal data.

Exercising your rights

If you would like to contact us about your rights, please see the contact details in section 1.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

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.

WeFlex accepts the following forms of ID when information on your personal data is requested:

  • Passport;
  • Driving licence;
  • Birth certificate; and/or
  • Utility bill (from last 3 months).

We try to respond to all legitimate requests within one month. Occasionally it could 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.

11. COOKIE POLICY

About cookies

Our website uses cookies. A cookie is a small file of letters and numbers that we put on your computer if you agree. The cookies may transmit information via your browser with a purpose of authenticating or identifying the computer (via e.g. the IP address) or the user. Cookies may contain information such as registration data and user preferences.

When a server receives a request from a computer which stores a cookie from the website, the server is able to use the information stored in the cookie in combination with the information stored on the server to allow the website to respond to you as an individual and to tailor their operations to your needs, likes and dislikes by gathering and remembering information about your preferences. A cookie cannot collect information from your computer and cannot carry any viral or other damaging files.

(website: www.allaboutcookies.org.).

How we use cookies

Our site uses cookies to distinguish you from other users of our site. This helps us to provide you with a good experience when you browse our site and also allows us to improve our site.

Our cookies help us to:

  • Make our site work as you would expect;
  • Remember your settings during and between visits;
  • Improve the speed/security of our site;
  • Allow you to share pages with social networks like Facebook;
  • Continuously improve our site for you; and
  • Make our marketing more efficient.

We do not use cookies to:

  • Collect any sensitive information (without your express permission);
  • Pass data to advertising networks;
  • Pass personal data to third parties; or
  • Pay sales commissions.

You can find more information about the individual cookies we use and the purposes for which we use them below.

What specific cookies does this website use and for what purposes?

Below are tables showing the cookies used by our website along with the purpose of each of them.

Website Function Cookies

Cookie Name               Further information

_smSessionId               Website Session cookie

_smToken                     Temporary web cookie

We use cookies to make our site work including:

  • Remembering if we have already asked you certain questions (e.g. whether you declined to use our app or take our survey); and
  • The automatic completion of web forms.

These cookies must be set, otherwise you will not be able to use our site.

Social Website Cookies

Our products may have social plug-in capabilities which may include tracking cookies used to track both members and non-members of social networks for additional purposes such as behavioural advertising, analytics, and market research.

Cookies are set by:

Cookie Name                        Further information

Facebook Social Plugin          https://www.facebook.com/help/www/443483272359009

Google Plus                            https://www.google.com/intl/en/policies/privacy/partners/

LinkedIn                                  https://www.linkedin.com/legal/privacy-policy

Twitter                                    https://twitter.com/privacy

These social networks set cookies over which we have no control. Their use of these cookies will be dependent on the privacy settings you have chosen on the relevant networks.

Visitor Statistics Cookies

We use cookies to compile visitor statistics such as how many people have visited our site, how long they spend on the site and what pages they look at. This helps us to continuously improve our site. These analytics programs also tell us if how people reached this site (e.g. from a search engine) and whether they have visited our site before.

Cookie Name                        Further information

Google Analytics                    https://www.google.com/policies/privacy/

Web Analytics Plugin             https://yoast.com/privacy-policy/

How can I turn cookies off?

You may refuse to accept cookies from our site at any time by activating the setting on your browser which allows you to refuse cookies.

Please note that by disabling or blocking any or all cookies, some features of our site may not operate as intended and you may not have access to features or personalisation available on our site.