Privacy Statement
Last updated: 17-04-2024
Ayvens is committed to protecting the personal information processed by us. Compliant privacy and information security practices are therefore integral components of Ayvens's Services, corporate governance, risk management and overall accountability. We only process such personal information as is necessary for our business activities and the provision of the Ayvens Services.
Table of contents
1. Scope of this Privacy Statement
4. For which purposes we use your data4.1 Data pertaining to website visitors. 4.2 Data pertaining to business clients. 4.3 Data pertaining to drivers (Employees of our Clients). 4.4 Data pertaining to private lease clients (including sole traders and partnerships) and prospective clients 4.5 Data pertaining to private buyers of used vehicles 4.6 Data pertaining to professional buyers of used vehicles (traders)
5. Sharing data with third parties
6. International transfer of personal data
1. Scope of this Privacy Statement
This Privacy Statement (“Statement”) describes our policy regarding the processing of personal data collected from:
I. Website visitors/users (“Website Visitors”); II. Business Clients (“Clients”); III. Clients’ employees/Drivers (“Drivers”); IV. Private lease clients (including one-person businesses) (“Private Lease Clients”); V. Private buyers of used vehicles (“Private Buyers”); VI. Professional buyers of used vehicles (“Traders”); and VII. Suppliers of goods and services (“Suppliers”). (or individual and company prospects, in any of the above categories).
We collect and use your personal information we receive via registration on our website, our various vehicle and fleet leasing, management, and driver mobility services and in our business activities, as further described in Section 1 (“Services”).
This Privacy Statement does not apply to the following affiliates and/or services:
- Euro Insurances DAC or Ayvens Insurance;
- PowerD or Ayvens Energy;
Or to the services provided by these affiliates, which are governed by separate privacy statements.
Please also note that any processing of your personal information via our telematics services will take place under the applicable Telematics Privacy Statement. Other specific services may be subject to specific privacy statements.
Responsibilities of Business Clients Insofar as Clients in their capacity as employers have access to personal information of their employees, the Client is the data controller responsible for the processing and use thereof in such capacity. This Privacy Statement does not apply to the processing and use of personal information of employees by Clients (employers).
2. Who we are
Ayvens is the company responsible for the processing of your personal information (data controller):
Lease Plan Portugal – Comércio e Aluguer de Automóveis e Equipamentos Unipessoal, Lda., Lagoas Park, Edifício 6, 2740-244 Porto Salvo
LeasePlan Corporation N.V. and LeasePlan Global B.V., will sometime be joint data controllers: Address: Gustav Mahlerlaan 360, 1082 ME Amsterdam, the Netherlands. LeasePlan Portugal and LeasePlan Corporation N.V. and LeasePlan Global B.V. are jointly called “Ayvens” and “we”, “our” or “us”.
3. How we collect your data
Ayvens and our service partners collect personal data in various ways, which include
Offline
We collect personal information from you offline, e.g., when you visit our experience stores, place an order over the phone, or contact customer service.
Online
We collect your personal information when you visit our websites or social media channels: if your social media accounts are linked to your Services account, or you share information from our websites on your social media platforms, you share the data from your social media accounts with us, for example, your name, email address, photo, contacts list and any information that is accessible, or to which you have given us access.
We process your personal information when you initiate the procurement process via our online services by registering on our platform or on our business partners’ channels.
Information is gathered both online and offline that allows us to initiate the contract, particularly to evaluate and approve the leasing procedure, or to ensure compliance with the regulatory procedures to which Ayvens is subject.
Through the Services
Most of the data we collect are in relation to the vehicle management services we provide to you as the driver and to our Client, your employer, if you are using a company car. This starts with the registration of the contract and continues when we communicate with you about our Services, e.g., to arrange for periodic maintenance and repairs. We may also process your data when your vehicle inadvertently is involved in an accident, to ensure that we restore mobility and handle any damage, or where we receive are the recipient of traffic fines in relation to your leased vehicle. Next to our core-leasing activities, we also provide several other related services, such as e-mobility services, fuel card and EV recharge services, electrical chargers, car rental from rent-a-car companies, and roadside assistance. Another service we provide relates to sales of used vehicles.
From Other Sources
We receive your personal information from other sources, for example:
Drivers’ employers if you use a company car;
The relevant authorities (e.g., police) where we receive received traffic fines in relation to your leased vehicle;
From business partners who sell Ayvens services or products or our independent Service Partners who assist us in providing our leasing and other services to you, including car dealerships, car maintenance providers, body repair shops;
Publicly available databases, credit reference agencies and other sources;
Visiting our websites or social media channels;
Joint marketing partners when they share the information with us.
We need to collect personal information to start the contract provide the requested Services to you or to handle queries, questions, comments, complaints related to our Services. If you do not provide the information requested, we may not be able to start the contract, provide the Services or respond to your request. If you disclose any personal information relating to other persons directly to us or to our service providers, you represent that you have the authority to do so and to permit us to use the information under this Privacy Statement.
Monitoring of communications Subject to applicable laws, we will monitor and record calls, email, text messages and other communications we have with you. We do this for compliance with regulatory rules, self-regulatory practices, or procedures relevant to our business, to prevent or detect crime, to protect the security of our communication systems and procedures, and for quality control and staff training purposes. According to the legislation in force, telephone calls, emails, text messages and any other communications with us, will be recorded and monitored to ensure compliance with regulatory requirements and procedures relevant to our business, to prevent and detect crime, protect the security of our communications systems and procedures, and for quality control and staff training purposes. For example, where we are required by a regulator to record certain telephone lines () we will do so. In addition, where appropriate and having regard to data protection law, our monitoring will be to check for inappropriate content in communications. In limited and specific circumstances we may conduct short term carefully controlled monitoring of your activities where this is necessary for our legitimate interests or to comply with a legal obligation. We may do this for instance where we think fraud or other crime is being committed, where offenses are suspected and where the monitoring is proportionate to the disciplinary offense, or where we suspect non-compliance with anti-money laundering regulations to which we are subject. Telephone calls may be recorded for these purposes.
4. For which purposes we use your data
4.1 Data regarding website visitors
4.1.1 Websites **4.1.1.a To communicate with you** *What does this purpose entail*? We collect your information when you contact us via one of our online contact forms, for example, when you send us questions, suggestions, compliments, or complaints, or when you request a quote for our Services. This processing is done for the performance of an agreement you have with us, to respond to a request or with your consent. *Which personal information do we process for this purpose?* For this purpose, we collect your full name, gender, title, (business) contact details (including your email address, telephone number, name of your company) license plate and any other information you provide to us in the open field entry of the contact form, where you can, for example, pose your question, describe your suggestion, make a compliment or share a complaint. *With whom do we share your personal information?* See the section ‘[Sharing data with third parties](targetBlank:#Paragraph14)’. **4.1.1.b Digital onboarding** *What does this purpose entail?* We collect your personal information via our online contact forms, to initiate the business relationship, collect financial and other information and to formalize the contract and validate the regulatory requirements to which we are subject. *Which personal information do we process for this purpose?* For this purpose, we process the name, gender, title and address, contact information (including email and telephone number), national and tax identification numbers, civil status, data for evaluating the financial capacity to make the contract; the date, place and country of birth of the effective beneficiary of the counterparty with which Ayvens wishes to initiate a business relationship, we may also process the name, address, date, place and country of birth of the representatives of the counterparties. and the national and tax identification numbers; driver information, name, gender, email, telephone number, delivery address or vehicle collection location, data regarding transactions (with references, amounts payable, payment date), bank account number and direct debit authorization given to Ayvens . *With whom do we share your personal information?* See the section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’. **4.1.1.c For surveys or other (marketing) communication** *What does this purpose entail?* We process your personal information when you complete a survey on our website for feedback on our websites and/or Services, with your consent or for which we have a legitimate interest to process these data. With your consent or where we have a legitimate interest, we may send you marketing communication, to keep you updated on events, special offers, possibilities and current and future products and services of Ayvens. When we contact you regarding surveys or marketing communication, we will do so either by email, phone, or by postal mailings (newsletters/brochures/magazines). If you would no longer like to receive surveys or marketing communication from us, please contact us by using the contact form in this Statement. Based on your visit to a website of Ayvens, we can show you personalized advertisements outside the Ayvens website. To understand what relates to you, we may use manual and automatic tools to analyze your personal information. To facilitate your use of our online Services or applications, we may analyze data we collect when using our digital media and combine it with information collected via cookies. For example, to better understand which digital channel (Google search, email, social media) or device (desktop, tablet or mobile) you prefer, we can optimize or limit our communication and marketing activities by channel and by device. *Which personal information do we process for this purpose?* For this purpose, we process your name, your address, your email address, and topics you may be interested in (as indicated by you on our website). *With whom do we share your personal information?* See the section ‘[Sharing data with third parties](targetBlank:#Paragraph14)’.4.2 Data regarding clients
4.2.1 Client account management **4.2.1.a To provide, manage and administer the Client account** *What does this purpose entail?* We collect your personal information to handle day-to-day management and administration of the Client accounts, such as complying with contracts and keeping you informed of all important developments about the Services and other information relevant for the Client contract and account. This processing is based on a legitimate purpose within the ambit of the performance of the lease agreement we have with you or based on a legal obligation. *Which personal information do we process for this purpose?* For this purpose, we may process business contact details and log-in details for our Client online accounts. *With whom do we share your personal information?* See the section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’. **4.2.1.b To communicate with you** *What does this purpose entail?* You can contact us by various means (such as email or telephone, or via our website). In this case, we will use your personal information to respond to your question/request. We can also contact you, for example, regarding day-to-day management and administration of your Client account. This processing is based on our legitimate business interest and relates to the performance of the lease agreement we have with you, or with your consent. *Which personal information do we process for this purpose?* For this purpose, we may process your name, your business contact details, your correspondence with Ayvens regarding your question/request and all other personal information you provide to us and/or which is necessary to appropriately respond to you. Telephone calls to our customer support service will be recorded for quality monitoring and training purposes, based on our legitimate interest. *With whom do we share your personal information?* See the section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’. **4.2.1.c For surveys or other (marketing) communication** *What does this purpose entail?* We process your personal information to send you surveys, for which we have a legitimate interest to process these data. We will send you these surveys by email or SMS and ask you to give us your feedback regarding our Services and other services used with the vehicle. With your consent or where we have a legitimate interest, we may send you marketing communication, for example, to keep you updated on events, special offers, possibilities and current and future products and services of Ayvens. We may also send you postal mailings (newsletters/brochures/magazines). To understand what relates to you, we may use manual and automatic tools to analyze your personal information. If you would no longer like to receive surveys or marketing communication from us, please contact us by using the contact form in this Statement. To facilitate your use of our online Services or applications, we may analyze data we collect when using our digital media and combine it with information collected via cookies. For example, to better understand which digital channel (Google search, email, social media) or device (desktop, tablet or mobile) you prefer, we can optimize or limit our communication and marketing activities by channel and by device. *Which personal information do we process for this purpose?* For this purpose, we may process your name and your business contact details and the interests (as indicated by you). *With whom do we share your personal information?* See the section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’.4.3 DATA PERTAINING TO DRIVERS (Employees of our Clients).
4.3.1 DRIVER CONTACT. **4.3.1.a To communicate with you.** *What does this purpose entail?* You can contact us by various means (such as email or telephone, or via our website). In this case we will use your personal information to answer your question/request. We can also contact you in relation to your vehicle or other relevant driver-related issues. This processing is done based on our legitimate interest (the performance of the lease agreement that we have with your employer) or with your consent where this is required. *Which personal information do we process for this purpose?* For this purpose we process your name, your contact information, your correspondence with Ayvens pertaining to your question/request and all other personal information you provide to us and/or which is necessary to appropriately respond to you, including your license plate number. *With whom do we share your personal information?* See section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’. **4.3.1.b For surveys or other (marketing) communication.** *What does this purpose entail?* We process your personal information when we send you periodic surveys to request your feedback on our Services and other services performed on the vehicle, for which we have legitimate interest to process these data. With your consent (where this is required) or where you have provided your business contact details and we have a legitimate interest we may send you marketing communication, to keep you updated on events, special offers, possibilities and current and future products and services of Ayvens. When we contact you in regard of surveys or marketing communication, we will do so either by email or by postal newsletters/brochures/magazines (postal mailings). If you would no longer like to receive marketing communication from us, please contact us via the [contact form](targetBlank:https://app-eu.onetrust.com/app/ #/webform/72945227-736f-45b6-b207-a2897f3f26b4). This would mean that you have withdrawn your consent and we cannot contact you again for these reasons unless you resubscribe and give us a new consent. *Which personal information do we process for this purpose?* For this purpose we process your name, your address, your email address, your license plate number and your interests (as indicated by you). *With whom do we share your personal information?* See section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’. **4.3.1.c Portals and apps** *What does this purpose entail?* We will (soon) offer you online portals or apps. Via these portals or apps you can find practical information on your lease car, your contact information and other personal data, report changes thereto, report damage to your vehicle, record appointments for repairs, maintenance or tire change, contact our customer service, consult and pay fines. This processing is done based on our legitimate interest (the performance of the lease agreement that we have with your employer) or with your consent. *Which personal information do we process for this purpose?* For this purpose we collect your name and email address to send you a temporary password, which you will need to use the platform and apps. *With whom do we share your personal information?* See section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’.4.4 DATA PERTAINING TO PRIVATE LEASE CLIENTS (INCLUDING SOLE TRADERS AND PARTNERSHIPS) AND PROSPECTIVE CLIENTS.
4.4.1 SIGN UP. **4.4.1.a To be able to accept you as a client** *What does this purpose entail?* We will collect information when you sign up (via our website or otherwise ) as a client or as a prospective client. This processing is required for the conclusion and performance of the lease agreement, including assessment, acceptance of you as a client and to adhere to guidance and best practice issued by the regulators and regulatory regime to which part of our business is subject. Which personal information do we process for this purpose? For this purpose we collect your name, gender, title, address, contact details (including your email address, telephone number, driver’s license, delivery address or pick-up location, transaction data (such as order, amount(s) to be paid, date of payment), your bank account number and the authorization you give to Ayvens. With whom do we share your personal information? We share your information with a third party with whom we have an agreement for making online payments, such as the deposit payment and the monthly payments of the lease amount. We only share information that is necessary for the execution of the payments. See also section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’. Credit Reference Checks This section is only relevant to you if you are an individual, sole trader or partnership who applies to have a vehicle from us. Credit reference checks are conducted to assess your financial position, to verify the accuracy of the data you have provided to us and to meet our regulatory expectations in respect of financial crime and integrity and conduct risk management. This process may include personal data. The information used for these checks is the information, including any personal data, you have provided to us in the vehicle application process. Furthermore we may use external credit reference agencies to conduct these checks for us and thus supply your data to them or to have you supply your data directly to them. External credit reference agencies will also use publicly available information about you. Anti-Money Laundering Screening The personal information we have collected from you may be shared in accordance with Ayvens compliance polices, to conduct know your counterparty due diligence and anit-money laundry screening. During this process, we may engage third parties such as fraud prevention agencies or use compliance screening software tools. If the outcome of these screenings is negative and do not meet Ayvens requirements, you could be refused a contract or business relationship or have this terminated. For further details of how your information will be used by in this respect, please contact us via the contact form. This is necessary for our own legitimate interests of protecting our business from compliance and integrity risk and it is also necessary for our compliance with legal obligations. **4.4.1.b Portals and apps** *What does this purpose entail?* We will (soon) offer you online portals or apps. Via these portals or apps you can find practical information on your lease car, your contact information and other personal data, report changes thereto, report damage to your vehicle, record appointments for repairs, maintenance or tyre change, contact our customer service, consult and pay fines. This processing is required for the performance of the lease agreement or with your consent where this is required. *Which personal information do we process for this purpose?* For this purpose we collect your name and email address to send you a temporary password, which you will need to use the platform and apps. *With whom do we share your personal information?* See section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’.4.5 Data pertaining to private buyers of used vehicles.
4.5.1 PURCHASE. **4.5.1.a Purchase of a Used Ayvens.** *What does this purpose entail?* We process your information in relation to your (potential) purchase of a Used Ayvens, if applicable, the trade in of your vehicle and other related Services. This includes the execution of the purchase agreement, the delivery of Services and the settlement of the payment transaction. This processing is required for the conclusion and performance of the agreement, including assessment, acceptance of you as a client. *Which personal information do we process for this purpose?* For this purpose we collect your name, gender, title, (business) contact details (including your email address, telephone number, name of your company), information related to your trade in vehicle and details needed to complete the transaction, including bank account details. *With whom do we share your personal information?* We may share this information with trade in parties or financial services partners. See also section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’.4.6 Data pertaining to professional buyers of used vehicles (Traders).
4.6.1 REGISTRATION AND PURCHASE. **4.6.1.a Registration as a professional trader.** *What does this purpose entail?* To be able to purchase Used Ayvens traders need to be registered with Ayvens as a professional trader. This processing is done based on our legitimate interest (the performance of an agreement, including assessment, acceptance) or based on a legal obligation. *Which personal information do we process for this purpose?* For this purpose we collect your name, contact details (including your email address, telephone number), your ID and information related to your company including Chamber of Commerce document and VAT certificate, *With whom do we share your personal information?* See section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’. **4.6.1.b Purchase of Used Ayvens.** *What does this purpose entail?* We process your information in relation to your (potential) purchase of (a) Used Ayvens (s) and other related Services via an auction or via the website www.carnextmarketplace.com. This includes the execution of the purchase agreement, the delivery and the settlement of the payment transaction. This processing is based on legitimate interest (the conclusion and performance of the purchase agreement). *Which personal information do we process for this purpose?* For this purpose we collect your name, contact details (including your email address, telephone number), your ID and information related to your company including Chamber of Commerce document and VAT certificate, details needed to complete the transaction, including bank account details. *With whom do we share your personal information?* See section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’.7. Security and retention
How we secure personal data
We seek to use organizational, technical and administrative measures to protect personal information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the Contact details provided in this Statement.
How long we retain personal data
We will retain your personal information for as long as necessary or permitted in light of the purposes outlined in this Statement and consistent with applicable law.
The criteria used to determine our retention periods include:
- Retention for our business relationship. The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you use a Ayvens vehicle);
- Retention in case of legal obligation. Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
- Retention to protect our legal position. Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
- Retention in case of claims. We will retain your personal information for the period in which you might legally bring claims against us (as relevant).
- Retention in accordance with regulatory requirements. We will retain your personal information where we are required to do so by regulatory regimes and regulations applicable to us (in the UK this includes the FCA regulatory regime).
- Prospects. We will retain your contact details for our marketing purposes (as above) for a maximum of two years unless you tell us within that period that you wish to unsubscribe or withdraw your consent.
- Retention of CCTV images. We apply a separate criteria to retention of these records, as follows. We retain CCTV images for three months and after that they will be erased because we will not need to retain them for the purposes listed (above).
8. Children’s privacy
Our Services are not directed at individuals under the age of 18.
9. Your rights and contacting us
Your rights
If you would like to request to review, correct, update, suppress, restrict or delete your personal information processed by us, object to the processing of personal information, to object to automated decision making or if or if you would like to request to receive an electronic copy of your personal information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact us via the contact form. We will respond to your request in accordance with the applicable law.
In your request, please make as clear as possible what personal information your request relates to. For your protection, we will only implement requests with respect to the personal information associated with the particular email address as you indicated in the contact form, and we may request you to provide verification of your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and in any event within any applicable legally required timeframes.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that began prior to requesting such change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed.
Questions? If you have any questions or complaints about this Statement, please contact us via the contact form.
Because email communications are not always secure, please do not include sensitive information in your emails to us.
Additional information regarding the EEA You may also:
- Contact our Data Protection Officer (DPO) via the contact form or via: Ayvens at Portugal, attn. Data Protection Officer, Lagoas Park, Edifício 6, 2740-244 Porto Salvo
- Lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection law occurs. The supervisory body in Portugal is the Portuguese data protection authority, click here to access its website.
10. Changes to this Privacy Statement
We may change this Statement at any time. Please take a look at the “Last Updated” legend at the top of this page to see when this Statement was last revised. Any changes to this Statement will become effective when we post the revised Statement on the Services. Your use of the Services following these changes means that you accept the revised Statement.