Tuskerdirect Limited trading as Tusker and Tuskercars, is an appointed representative of Howden UK Group Limited (FRN309639) for insurance mediation activities and Product Partnerships Limited (FRN 626349) for the regulated consumer credit activities detailed below. Both companies are authorised and regulated by the Financial Conduct Authority.
Tusker offers an "end of contract finance scheme" for customers who would like to keep their car when their hire agreement ends. This product is only offered through BMW Financial Services (GB) Limited trading as Alphera Financial Services (FRN 312578). Tuskerdirect Limited acts as a credit broker not a lender for this scheme and receives a fixed commission payment based on the amount financed if an agreement is entered into with the product provider. You can ask for details of how much this commission payment will be.
Tusker also operates a regulated consumer hire scheme on behalf of National Grid group companies and Cadent Gas Limited. This scheme is only available to employees of these companies.
If you would like to know how complaints are handled for these schemes, you can ask for a copy of our complaints handling process. You can also find information about referring a complaint to the Financial Ombudsman Service (FOS) at financial-ombudsman.org.uk. You may be able to obtain finance facilities for your vehicle requirements from other lenders and you are encouraged to seek alternative quotations.
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 visitors to our website and individuals who contact us by telephone, e-mail or other electronic means as well as visitors to our Personal Contract Leasing (PCL) website, including individuals who have logged into our website and created accounts to quote or order PCL products and services from us.
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 2018 (DPA) and the General Data Protection Regulation (GDPR).
How to contact us
If you have any questions about this privacy notice or our data protection policies generally, please contact us:
By post: Data Protection Officer, Building 4 Hatters Lane, Croxley Green Business Park, Watford, Hertfordshire, United Kingdom, WD18 8YF
By email: firstname.lastname@example.org
By phone: 0333 400 2020
Visitors to the website
3.1. What information do we collect and process?
When you visit our website (as hosted via any domain name registered in our name), we use third party services to automatically collect information about your computer, including your IP address, information about your visit, your browsing history, and how you use our website.
If you receive an e-mail from us and you either click on a link in such e-mail or download any pictures contained in such e-mail, we can track information about your subsequent visit to our website and link this to your e-mail address.
If you contact us via our website, please see the "People who contact us" section below.3.2. How is your information used?
Where information collected includes contact details, we may also use this information to send you communications of products or services that may be of interest to you. Please see the "Marketing" section below for further details of our direct marketing policy.3.3. Who has access to your information?
Our Marketing team have access to analytics platforms and tools that collect and process website visitor information. We may share statistical or aggregated data with our group companies and relevant third parties such as companies which undertake market research on our behalf.3.4. Lawful processing
When we process your personal data for the purposes of improving our website, we do so on the basis of our legitimate interests in maintaining a relevant and functioning website and improving customer experience.
We only use personal data obtained from our website to contact you if we feel we have a legitimate interest in informing you of the products and services we offer.3.5. How long do we retain your data?
We retain personal data collected automatically from our website for as long as it is valid, accurate and up to date or until such time that you choose to unsubscribe. Where we hold Personal Data for the fulfilment of a contract we will hold this for a period of seven years from the termination of the contract.
People who contact us by phone, e-mail, LiveChat or other means
4.1. What information do we collect and process?
We receive information from you when you register an account with us (data available to view in the My Account area of our website), 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, username & password, internet protocol (IP) Address, title & marital status, NI Number, Driver Licence number, vehicle details, Payroll / Employee ID, digital signature (via DocuSign), financial and payment information, employment history, credit history, identification records and other information about you. 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.
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 the services which we may provide to you.
We also collect information from Driving Licence agencies when assessing your application. Information may include details of any points on your licence.We may also receive personal data about you from various third parties and public sources such as:
- from your business or from third party references or from professional advisors.
- from publicly available sources such as Companies House or your business's website.
4.2. How is your information used?
How we use your personal data and the lawful basis for doing so.
Where we are relying on a basis other than consent, we may rely on one or more of the following legal bases when processing your personal data for the following purposes:
To assist in the prevention and reduction of fraud and other financial crime. The processing is necessary for us to comply with the law and our legal requirements.
Purposes for which we process your personal data The basis on which we can do this (this is what the law allows) In order to perform our contractual obligations to you. The processing is necessary in connection with any contract that you may enter into with us In order to perform our legal obligations to you. This would include funding of the lease agreement The processing is necessary in connection with any contract that you may enter into with us To administer your account, including financial transactions for the product or service we have provided you The processing is necessary in connection with any contract that you may enter into with us In the interests of security and to improve our service, telephone calls you make to us may be monitored and/or recorded The processing is necessary to pursue our legitimate interest in the management and operation of our business To let you know about similar products and services that may be of interest to you The processing is necessary to pursue our legitimate interest in the management and operation of our business
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.
We share your personal information with Credit Providers for them to carry out affordability and credit checking, provide finance and manage any late or defaulted payments for the PCL product. In carrying out such processing Credit Providers will share your information with credit reference agencies, details of which are set out at the end of this notice.
We may also share your information with other 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 they will not use it for direct marketing purposes. 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 and services
- vehicle valuation
- vehicle dealerships
- vehicle insurance
- vehicle tracking (for vehicles that have factory fitted trackers)
- 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
- direct debit and 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 party controllers:
- 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; or
- vehicle funders
- 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; or
- for credit brokering activities. Tusker is an appointed representative of Product Partnerships Limited (PPL), who are authorised and regulated by the FCA. We may disclose personal data to PPL to help investigate and mediate customer complaints.
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 auditors4.4. Lawful processing
When we process your personal data in connection with telephone calls, LiveChat sessions, e-mails or social media, we do so on the basis of our legitimate interests in discussing our products and services with you, in creating and retaining records of such communications for training purposes and for evidentiary purposes or to respond to customer queries.
Where you are a recipient of our products and services (either directly or via your employer), we process your personal data arising from telephone calls, LiveChat sessions, e-mails or social media on the basis of performance of a contract relating to you where such communications are relevant to such a contract.
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 with you or taking steps with the intention of entering into a contract with you for our products and services. If no contract is in place and you are using the website to carry out quotations, we will use your personal data to contact you and discuss quotations as a legitimate interest.
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 defending our legal rights.4.5. How long do we retain your data?
We retain recordings, transcripts, e-mails and other copies of communications for a maximum period of 7 years from the end date of your contract with us
We would like to send you information about products and services we offer which may be of interest to you, as well as other information which may be relevant to you such as special offers or promotions.5.1. Marketing communications
If you have provided us with business contact details, we will send you marketing information by post, telephone, e-mail, text or other electronic instant messages where it is in our legitimate interests in pursuing sales leads to do so (provided that you have not opted out of such communications and provided that it constitutes fair processing of your personal data to do so).
If you have provided us with personal contact details, we will only send you marketing e-mails or texts or other electronic instant messages where you have not opted out of receiving such communications. We may also provide you with marketing information by post or by telephone where it is in our legitimate interests to do so in pursuing sales leads or for discussing renewals or informing you of an event we are holding at your place pf work (provided that you have not opted out of such communications and provided that it constitutes fair processing of your personal data to do so).5.2. Marketing preferences
You can opt out of any marketing communications by:
- clicking on the "unsubscribe" links in any marketing e-mails;
- emailing us at email@example.com;
- calling us on 0333 400 2020; or
- if you have signed up to receiving marketing from us by text, replying STOP to the last message you received from us.
- If you have consented to receive marketing, you may opt out at a later date. You can set your marketing preferences in the My Account area of our website, including opting out of any particular type of marketing communication. If you have not opted out of receiving marketing, you may opt out at a later date.
- Where you are a registered user of our website, you can set your marketing preferences within the registered user area of our website, including opting out of any particular type of marketing communication.
Our marketing staff have access to any personal data obtained for marketing purposes. We will not sell or rent your information to third parties. We will not share your information with third parties for marketing purposes.We may also use the services of third party marketing companies and platforms, including;
- Customer surveys and feedback
- Product and service reviews
- Analytics platforms
- SMS services
- Emailing services
- Marketing printing and postal services
5.4. Lawful processing
When we process your business contact data for marketing purposes, we do so on the basis of our legitimate interests in pursuing sales leads to inform you of the services and products that we offer or for discussing renewals.5.5. How long do we retain your data?
We will retain any marketing data for a maximum of 7 years.
Retention of data generally
We retain personal data for as long as necessary to provide the products and services you have requested, or for other essential purposes such as complying with our legal obligations, resolving disputes and enforcing our agreements. Because these needs can vary for different data types in the context of different products, actual retention periods can vary significantly. We therefore categorise data and review the retention periods for each set of data. This ensures that we never hold any personal information for longer than is required to provide our products and services to you, or for longer than we are legally bound to or otherwise have a legitimate interest to. We review our retention periods on a regular basis to ensure they are up to date.
How you can access and update your information
The accuracy of your information is important to us.
You can contact us requesting an update to your information by email: firstname.lastname@example.org 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 and it would be helpful if any such request also indicates what information you are seeking. All requests for access to personal data should either be sent by email to: email@example.com or by post to: Data Protection Officer, Tuskerdirect Limited, 4 Hatters Lane, Croxley Green Business Park, Watford, Herts. WD18 8YF, or by telephone on 0333 400 2020
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 safeguard and protect your information. We are also fully accredited members of the Direct Marketing Association (DMA) and subscribe to their Code of Practice.
We do not transfer any personal data outside of the European Economic Area (EEA).
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 firstname.lastname@example.org 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.
Your personal data is protected by legal rights, which include your rights to:
11.1. object to our processing of your personal data;
11.2. request that your personal data is erased or corrected;
11.3. request that any automatic decision-making or profiling is reviewed;
11.4. request access to your personal data;
11.5. data portability; or
11.6. 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.
Time to respond
We try to respond to all legitimate requests within one month. Occasionally it may 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.
Modern Slavery Statement
TUSKERDIRECT LIMITED (“Tusker”) - Modern slavery statement for 2021
We are committed to understanding modern slavery risks and to improving our practices to combat slavery and human trafficking.
Our business and supply chains
We are a full service vehicle leasing business for the UK, with a core focus on Car Benefit schemes. In addition to Car Benefit schemes, our other main services are contract hire and fleet management services.
Our supply chain is primarily comprised of organisations within the UK. Our activities are undertaken in the UK and Ireland, and we do not operate directly outside of these countries.
Our policies and principles
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.
We operate a number of internal policies to ensure that we are conducting our business in an ethical and transparent manner. These include:
- Anti-slavery policy. This policy sets out our stance on modern slavery and explains how employees can identify any instances of this and where they can go for help.
- Recruitment policy – we operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees.
- Whistleblowing policy – we operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or about practices within our business or supply chain, without fear of reprisals.
- Environmental policy – we have a duty to ensure good environmental performance in all of our business operation and to provide the necessary organisation, commitment and training to fulfil this obligation, as set out in this policy.
Due diligence processes for slavery and human trafficking
As part of our initiative to identify and mitigate risk we have systems in place to:
- Identify and assess potential risk areas in our supply chains.
- Mitigate the risk of slavery and human trafficking occurring in our supply chains.
- Monitor potential risk areas in our supply chains.
- Protect whistle blowers
- As part of continuous improvement, this policy and our supply chain will constantly be reviewed
- Annual audits of this policy will be undertaken
Our effectiveness in combating slavery and human trafficking
We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:
- No reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.
Approval for this statement
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the year ending 2021. This statement is reviewed annually.
Name (CEO): Paul Gilshan
Date: 1st January 2021