PRIVACY NOTICE
Who we are
Liberty Leasing Limited is a privately owned asset finance company, Company Registration Number 04302060. The terms ‘we’, ‘us’ ‘our’, ‘Liberty Leasing’ and ‘Company’ shall be construed as Liberty Leasing Limited.
This Privacy Notice applies where we are a data ‘controller’ for the purposes of data protection law (as defined below), i.e. to the extent that we determine the purposes and means of the processing of your personal data.
Data Protection Officer
Liberty Leasing’s Data Protection Officer can be contacted with any comments, queries or concerns about this Notice or about any information we hold about you:
Telephone: 02380 456565
Address:
Liberty Leasing Limited
Liberty House
Brook Avenue
Warsash
SO31 9HP
Email: [email protected]
About this Notice
This Notice explains how and when we use your personal information and for what reason(s) and related information, for example about your rights.
We refer in this Notice variously to ‘personal information’, ‘data’, ‘personal data’ and ‘personal details’. We use these terms interchangeably to mean information capable of identifying you.
Whilst you can visit our website without telling us who you are or providing any information about yourself which might identify you, if you do provide us with personal information about yourself for e.g. through submitting the contact form on our website or through an intermediary, we will only use this information in accordance with data protection law including in particular but not limited to the UK General Data Protection Regulation (‘UK GDPR’), Data Protection Act 2018 (‘DPA 2018’) and all applicable laws made under it.
What information do we collect and hold about you and how?
We may collect personal information about you in the following ways:
- through direct contact with Liberty Leasing – including but not limited to face to face contact, via email, the website, text messages, video call or telephone calls
- when you provide it through an intermediary such as a broker
- through a third party such as credit reference agencies (to perform credit and identity checks) and fraud prevention agencies.
The personal information you may be asked to provide, whether directly to Liberty Leasing or through an intermediary, is likely to consist of (but not limited to) your name; contact details i.e., address, telephone number, email address; date of birth; financial status (for e.g., income and expenditure, employment). This will also be the case when you apply for finance with Liberty Leasing.
There are several other types of personal data that may be processed by us which are necessary in order that we may fulfil our contractual and legal obligations, in particular as detailed in the table below.
| Type of personal information | Description |
| Financial | Your financial position, status and history. |
| Contact | Where you live and how to contact you. |
| Socio-Demographic | Details about your work or profession and nationality. |
| Transactional | Details about payments you make to our account and any insurance claims that may be made in relation to assets held under a facility you hold with us. |
| Contractual | Details about the Facilities entered into and / or any security provided by you or your associates. |
| Communications | Information contained within letters, emails or texts and discussed during conversations with us. |
| Social Relationships | Your family, friends and other relationships which have a bearing on your Facility held/ potentially held with us. |
| 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. |
| Documentary Data | Details about you that are stored in various documents or copies of them for e.g. your passport, driving licence or birth certificate. |
| Consents | Any permissions, consents or preferences that you give us. For e.g. 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 (this may be provided in the form of a social security benefit letter or pension letter issued by the government and provided to us for the purposes of anti-money laundering). |
| Other data | • Special category data for example details about your health and medical conditions or biometric data
• Criminal convictions and offences
Any other information relevant to our decision to grant a facility to you, including that provided by any credit reference or fraud prevention agency. |
What we use your personal information for
The protection of your personal information is very important to us, and we will only process your personal information for the following purposes:
- to allow us to deal with your enquiries
- to provide you with a service and to analyse and improve our service
- to authenticate your identity and verify other information you provide to us
- to manage our relationship with you
- to inform you about our products and services , including by direct marketing
- for administrative purposes
- for debt administration and factoring
- for purposes related to our proposed corporate activity, such as a sale or merger
- to maintain our own accounts and records
- to support and manage our employees
- where required to do so by law for e.g. sharing for crime prevention.
Legal basis for processing your personal information
At Liberty Leasing we rely on the following legal bases for the processing of your personal information, depending upon the purpose:
Contract: where necessary to perform a contract with you or to take steps at your request before entering into a contract with you.
Consent: in some cases, we may request your consent for processing, if so, this will be specific to the processing and we will inform you of the purpose and you can provide or refuse such consent at your discretion.
Legitimate Interests: where necessary for our legitimate interests or those of third parties which are not overridden by your interests, rights or freedoms. These comprise providing our services, direct marketing, fraud prevention, ensuring network and information security, indicating possible criminal acts or threats to public security, processing employee or customer data and administrative transfers within our group of companies.
Legal Obligation: where Liberty Leasing is under any legal obligations, e.g. with respect to anti-money laundering or other regulatory matters, which requires us to process or share personal data.
Ordinarily the lawful basis relied on by Liberty Leasing is that of contract, legitimate interests or legal obligation depending on the purposes of the processing. However, for transparency and good housekeeping, we may also request your specific consent from time to time, but where one of the other bases above applies, we do not rely on that as the sole legal basis of processing.
If you have provided consent to our processing of your personal data, your consent can be withdrawn at any time by contacting the Data Protection Officer. This will not affect processing before withdrawal, or which is based on another lawful basis of processing.
Monitoring of communications
We may monitor and record calls, emails, text messages or other communications in accordance with applicable laws for the processing purposes and legal bases detailed above. We will do this to help improve our internal policies and procedures, for crime prevention and detection, to protect the security of our communication systems and procedures, for quality control and staff training, to help us address any issues you may have and when we need to see a record of what has been communicated.
Recipients
We may provide your personal data to the following recipients:
- credit reference agencies (‘CRAs’) – for more detailed information concerning for e.g. the data they hold, their role as fraud prevention agencies, your data protection rights with the CRAs etc. please refer to the CRA information notice (CRAIN) accessible from each of the three CRAs: experian.co.uk/crain, www.equifax.co.uk/crain, www.transunion.co.uk/crain
- fraud prevention agencies, law enforcement
- persons who may provide goods and services that we believe would be relevant to you
- our service providers, including anyone we appoint as a data processor
- financiers, including block discounters, banks and other financial institutions
- professional advisers for e.g. solicitors, accountants, auditors, enforcement / tracing agents and valuers
- consultants / contractors
- insurance providers
- prospective purchasers of our business or company and their advisers
- other members of our group of companies
Please note that if a recipient is located outside of the European Economic Area (EEA) and the UK in countries which have not been designated as ensuring an adequate level of protection for personal data, please see below.
Transfer of your personal data outside of the EEA and the UK
If it is necessary to transfer your personal information outside the EEA and UK for further processing or by the recipients described above, we will ensure that suitable safeguards are in place prior to your personal information being transferred, as required by law.
If you would like further information concerning the relevant safeguard(s) please email us at [email protected].
Use of closed-circuit television (“CCTV”)
We use CCTV in and around our offices which may collect photos or videos of you. No sound is recorded on the current system. This is used solely for the purposes of security and crime prevention.
Retention of personal information
We keep your personal information for the following periods:
- where you have proceeded in doing business with us for six years after termination of the business relationship, except where the law requires us to keep it for longer
- in other cases, we retain data for as long as the law requires us to do so, or we deem necessary.
Personal information will not be held for longer than is necessary for the purposes for which it was processed and will be periodically reviewed to determine whether retention is still required.
Your rights as a data subject
You may have a right to the following:
- Right to be informed
- Right of access
- Right to rectification
- Right to erasure
- Right to restrict processing
- Right to data portability – for e.g. you may be able to request for your personal data to be transferred from one data controller to another in certain circumstances
- Right to object
- Right not to be subject to automated decision making
- Right to lodge a complaint with our supervisory authority, namely the Information Commissioner’s Office (‘ICO’):
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone: 0303 123 1113
www.ico.org.uk.
To exercise any of these rights, please contact Liberty Leasing’s Data Protection Officer.
Withdrawing consent
As mentioned above, where processing of your personal data is based only on your consent, you have the right to withdraw that consent at any time. Your withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.
How to complain
Complaints can be made to us at any time, free of charge in person, by telephone (including text message), email, letter, fax or via the website to any member of staff at Liberty Leasing. This is without prejudice to your right to complain to our supervisory authority, the ICO.
Our use of Cookies
Please refer to Liberty Leasing’s Cookie Policy on our website.
Links to other websites
Our website may contain links to other sites and personal information may be collected through those other websites, however, this Privacy Notice does not apply to those websites.
Changes to our Privacy Notice
We keep this Notice under regular review and, as such, the Notice may change from time to time. We recommend that you read this Notice before submitting any personal information to us through our website and regularly thereafter for any changes.
This Notice was last updated in November 2023.