Website & Communication Privacy Policy

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.

 

1.0 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).

2.0 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: compliance@tuskerdirect.com
By phone: 0333 400 3696

3.0 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.We use cookies within our website. You can read more about how we use cookies in our separate Cookies Policy.If you contact us via our website, please see the “People who contact us” section below.

3.2. How is your information used?
We use your information collected automatically from our website to improve the customer experience and functionality of our website. We use analytics platforms, including Google Analytics, a service which transmits website traffic data to Google servers in the United States. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. We use reports provided by Google Analytics to help us understand website traffic and webpage usage. Any data collected will only be used in accordance with our own privacy policy and Google’s Privacy Policy. Should you not wish for your website visits to be recorded by Google Analytics, you are able to opt-out with the addition of a browser add-on: https://tools.google.com/dlpage/gaoptout/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.

 

4.0 People who contact us by phone, e-mail, LiveChat or other mean

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?

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

 

4.3 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.

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
  • DVLA
  • 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 auditors.

4.4 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

5.0 Marketing

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 (see section 4.1 for definition of business contact), 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 specifically consented to receive 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 of 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).

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.  We will only use this data for the purposes of marketing our products and services to you if you have explicitly consented to this as part of providing your contact details, providing a link to this Privacy Policy.

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 customerservices@tuskerdirect.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.

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 in and out of any particular type of marketing communication.

  • If you have consented to receive marketing, you may opt out at a later date.

5.3 Who has access to your information?

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.

When we process your personal contact data for marketing purposes, we do so on the basis of your consent or in limited circumstances on the basis of our legitimate interests in pursuing sales leads or for discussing renewals.

 

6.0 Retention of data generally

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

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.

Personal data contained within a cookie is retained for as long as it is valid, accurate and up to date or until such time that you choose to unsubscribe.

When we anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes we may use this information indefinitely without further notice to you.

In some circumstances you can ask us to delete your data: see your right to request erasure below for further information.

 

7.0 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: customerservices@tuskerdirect.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.  It would be helpful if any such request indicates what information you are seeking and any time periods.  All requests for access to personal data should either be sent by email to: compliance@tuskerdirect.com or by post to: Data Protection Officer, Tuskerdirect Limited, 4 Hatters Lane, Croxley Green Business Park, Watford, Herts.  WD18 8YF or by telephone: 0333 400 2020

 

8.0 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 256-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.

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.

 

9.0 Data transfers

We do not transfer any personal data outside of the European Economic Area (EEA).

 

10.0 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 compliance@tuskerdirect.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.

 

11.0 Your rights

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 request the transfer of your personal data to you or a third party; 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.

 

12.0 Children

Our website is not intended for children, and we do not knowingly collect data relating to children.

 

13.0 What we may need from you

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.

 

14.0 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.

 

15.0 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.

 

 

Last Updated: 09/01/2024