Data Protection & Privacy Policy

This is a notice with respect to the handling of your personal data

This privacy policy sets out how Adept Vehicle Solution Ltd T/A Adept Vehicle Management uses and protects any information that is provided to us whilst using our services. We are registered with the Information Commissioner’s Office (ICO) in the UK and we are basing our policies on the General Data Protection Regulation (GDPR).

Our data protection license can be found on the ICO register using reference – Z7532052.
Our appointed data processing officer can be contacted via email
here [email protected].

Our interpretation of the current Data Protection regulations is that we should be very clear with all of our customers with regards to how we process and store any relating personal data and with whom we share your data with when it is provided as part of our processes. We also aim to be very clear on who our finance partners are and who we work closely with to provide our services.

Earning your trust

As a proud and established family business with over sixteen years of trading history we are keen to build trust with our customers as a number one priority. Through our Financial conduct authority (FCA) approval as a credit brokerage, ICO registration as a data handler and BVRLA trade body membership we are bound by a number of customer focussed regulatory and guidance-based principles. All of these areas are there to help us abide by all of the key practices that a company offering financial services should cover in the UK. On any occasion where you feel that we have not got things right, our leadership team would really appreciate it if you can let us know either via the email address above or via our complaints process.

How we operate and the relation with the handling of your data.

Our company, like many in the motor industry, have approval to act as a credit brokerage. This essentially means we offer a service and act as the middle man between you (the customer), the finance company (the lender), the manufacturer (the OEM or original equipment manufacturer) and the supply dealership (the supplier). Ultimately, the finance company sets their credit policy and they dictate the information required to assess you or your company’s credit profile. We will collect a standard amount of information to satisfy the requirements of our finance partners and to assist in ensuring that affordability and responsible lending guidelines are achieved. As you go through our customer journey we will seek your authority to share your information with those parties that are directly linked to the supply of our services such as the finance company and the supplying dealership.

 

The data controller

Adept Vehicle Management is committed to complying with the UK’s Data Protection law and the EU General Data Protection Regulation (GDPR) for the protection of personal data, as well as the principles of data security in the configuration of our services. If you have any questions about this privacy notice or how we use your personal data, please contact our Data Protection Officer, Mike Somers:

In Writing:
Adept Vehicle Management 
Independent House, Apedale Road
Chesterton, Newcastle-under-Lyme
Staffordshire,
ST5 6BH

By Phone: 01782 562246
By Email: [email protected]

What data is being collected and processed?

In order to enter into a brokerage agreement with Adept Vehicle Management, we will collect, store and use elements of your personal data. The processing of this personal data is a contractual requirement and is necessary by Adept Vehicle Management in order to administer your account and to provide the products and services you have requested from us.

When you approach Adept Vehicle Management to engage in our brokerage services, we will ask your consent to collect and process your personal data. Failure to provide this consent and/ or personal data may mean we will be unable to execute the contract and will result in termination of our services.

When engaging Adept Vehicle Management brokerage services, you will usually need to disclose to us the following:

  • title
  • first name(s), surname or company name (including representation as the case may be)
  • address (street, street number, postal code, city and country/region)
  • email address
  • date of birth
  • telephone and mobile number
  • employment details (employer name, employer address, employment history)
  • monthly income and expenditure
  • bank details (account number, account holder and card number)
  • VAT ID number (as the case may be)

We will also monitor, record, store and use any telephone, email or other electronic communications with you for training purposes so that we can check any instructions given to us and to improve the quality of our customer service.

Website Cookies

When you access our website, temporary data about your visit is stored and processed in a protocol file for a certain period of time via the use of cookies. This information is anonymised and is used by us to better understand the use of our site, including the number of visitors we have, the pages viewed per session and time exposed to particular pages. This in turn helps us to provide you with a better experience, since we can evaluate the level of interest in the content of our website and tailor it accordingly.

The following data is collected and stored by Adept Vehicle Management until its automated deletion:

IP address of the accessing computer/device
Date, time and duration of your visit
Name and URL of the accessed pages
Identification data of the browser and operating system used Website from which the data was accessed

Name of your internet access provider

The nature and content of the information collected via cookies differs, as does the period for which this information is retained. In line with our data protection obligations, we will ensure that this retention period is not excessive, and that the data is only retained for as long as is necessary for the purpose for which it was collected.

The data listed above is only analysed for statistical purposes and for improving our internet presence, then it is deleted. We will not attempt to personally identify you from your IP address unless required to as a matter of law or regulation or in order to protect our, or our other customers’ rights.

Most browsers automatically accept cookies but you can set your browser options so that you will not receive cookies and you can also delete any existing cookies from your browser. Should you wish to opt out of Google Analytic tracking across all websites please visit: http:// tools.google.com/dlpage/gaoptout. Please note, you may find that some parts of the site will not function properly if you refuse cookies.

Direct Marketing Communications

If you have chosen to opt-in to our direct marketing communications, we will use your information to tell you about products and services available from us which may be of interest to you. We may also use your information to tell you about products and services which we can introduce from selected businesses.

To help make our emails more interesting and relevant we often receive a confirmation when you open an email from Adept Vehicle Management, if your computer supports such capabilities.

You have a right to opt-out of our direct marketing communications at any time. You can opt-out by following the Unsubscribe instructions at the bottom of the communication or by
emailing [email protected]

 

Links to websites of other providers third parties

Please note that this data privacy notice only applies to Adept Vehicle Management and we are not responsible for, and have no control over, information that is submitted to or collected by third parties, such as those where our website may provide links and banner advertisements to third party sites. Since we do not control those websites, you are responsible for reviewing and abiding by the privacy policies of these third-party sites to ensure they comply with the applicable data protection regulations.

How long will the data be stored for?

Where possible, Adept Vehicle Management will take steps to erase any personal data that is no longer necessary for the purposes for which it is collected or otherwise processed, or if you have withdrawn consent for its processing and retention.

As a general rule, if you enter into or took steps to enter into a contract with Adept Vehicle Management, we will store the data for a period of six years for compliance with our general legal obligations and for the exercise or defence of any legal claims.

Under the GDPR, you have the right to ‘block’ or request the deletion or removal of personal data to prevent further processing. This right to erasure is also known as ‘the right to be forgotten’. Specific circumstances in which you can request the deletion or removal of personal data includes:

  • Where the personal data is no longer necessary for the purposes for which it is collected or otherwise processed
  • Where you withdraw consent
  • When you object to the processing and there is no overriding legitimate interest forcontinuing the processing
  • Where the personal data was unlawfully processed (i.e. otherwise in breach of the GDPR)
  • Where the personal data has to be erased in order to comply with a legal obligation
  • In case a deletion is not possible due to legal, statutory or contractual retention periods, or if it requires disproportionate efforts or prejudices your legitimate interests, the data will be blocked instead of deleted.Sharing of data with other data controllersHere at Adept Vehicle Management we take your privacy seriously and the information we hold about you is confidential. We will only disclose it outside Adept Vehicle Management when:
  • you have given us your consent to do so
  • it is necessary for the performance of an agreement of which you will be made aware
  • in order to obtain professional advice (e.g. legal advice)
  • we or others need to investigate or prevent crime (e.g. to fraud prevention agencies)
  • the law permits or requires it
  • regulatory or governmental body requests or requires it, even without your consent, or
  • there is a duty to the public to reveal the information

In order to administer your contract, we may need to share some of your personal information with other data controllers. This processing is necessary for the purposes of delivering specific services to you. You agree that we can share or use your personal data with any of our appointed agents or suppliers to allow us to provide you services and products you have asked us to provide you under this agreement, such as to facilitate delivery of your vehicle, to collect the vehicle from you or notify you of a vehicle safety recall. Other data controllers which we may share this information with may include:

Credit reference agencies (to propose you for vehicle finance)
The finance provider (to generate the finance agreement)
The supplying dealer group (to order and deliver the vehicle)
Claims handling and fraud prevention agencies (to investigate or prevent crime) Insurance companies (to administer insurance agreements such as GAP insurance)

Credit reference agencies

In considering your application, we will search your record at credit reference agencies. They will add to your record details of our search and your application and this will be seen by other organisations that make similar searches. On occasion, we may request a credit check with more than one finance provider.

Information held about you by the credit reference agencies may already be linked to records relating to other people with whom you have a financial association. In connection with your application you may be treated as financially linked with them and assessed with reference to any such associated records. Searches may also be made in respect of directors and partners of firms applying for credit.

If you are a joint applicant or if you have told us of some other financial association with another person, or a director of a firm which is applying for a facility you are declaring that you are entitled to:

disclose information about your joint applicant, fellow directors and anyone else referred to by you

authorise us to search, link or record information at credit reference agencies about you and anyone else referred to by you

The credit reference agency will use a credit scoring system when assessing your application. They will also add to your record details of your agreement with us, specifically the payments you make under it, any default or failure to keep to its terms and any change of address you fail to tell us about where a repayment is overdue.

These records will be shared with other organisations and will be used by us and them to help make decisions about credit and credit related services such as insurance for you and members of your household, trace debtors, recover debt and to manage your accounts. We and the credit reference agencies will also use the records for statistical analysis about credit.

You have a legal right to know the details of credit reference and fraud prevention agencies we use and to whom we pass information about you. To obtain this information, please contact our Data Protection Officer on 01782 562246.

 

Fraud Prevention

If you give us false or inaccurate information and fraud (in any form) is identified, details will be passed to the fraud prevention agencies. We and other organisations may also share, access and use this information to prevent fraud and money laundering, for example when:

  • checking details on applications for credit and credit related or other facilities
  • managing credit and credit related accounts or facilities
  • recovering debt
  • checking details on proposals and claims for all types of insurance
  • checking details of job applicants and employees
    In addition, law enforcement agencies may access and use this information.Sharing your informationAdept Vehicle Management does not share your information with any other company for marketing purposes. It is only at point of order, with your full permission that we share your information to trigger the credit agreement. We will also provide information to the supplying dealership as they will be involved in the supply of your vehicle.By using our services and accepting our terms you are consenting to us using and storing your dataBy accepting our terms & conditions you will be agreeing that: –
  1. We will hold your relevant personal and company data on our internal systems.
  2. If it has changed, we will update your personal data each time you transact with us.
  3. As we are a credit broker we will share your personal data with relevant partners such as the finance company or the supplying dealership.
  4. We may use your personal data to contact you with regards to service related matters, however we will not share your data with any third party for marketing purposes.
  5. If you specifically choose to opt-in to our regular email marketing then your contact information will be held with our email marketing partner. You will have the opportunity to unsubscribe at any time.
  6. We may also use your personal data in an analytical way to improve our customer experience, website journey and/or the services that we offer.
  7. We will use web browser cookies when you visit our website (see more detail below).
  8. We will use a customer review partner who will contact you on our behalf to seek feedback on our services.

9. When speaking with us on the telephone our lines will record calls for training and monitoring purposes. We will not retain this information for longer than necessary. We will treat your personal information as confidential and have a number of internal policies to make this central to our company culture. We should also make you aware of the circumstances where we would be obliged to disclose your information. These circumstances include requests from fraud prevention agencies, law agencies, regulatory bodies or government bodies.

 

Information Security

As a business we are committed to keeping our systems, policies and procedures up-to-date in order to protect your information. All information that you enter into our website via the internet is transferred with encryption via a secure certificate or https connection (see the green padlock in your web browser). We have also undertaken cyber security testing to help keep our website up to the very latest standards. Our internal office IT systems are monitored by our technology partner and all hardware / software is kept up to date in order to meet the latest standards. Further to this all of our staff go through induction and annual training to make them aware of their obligations with regards to customer data.

 

Subject Access Requests

You have the right to request access to a copy of the personal information that we hold about you. This is also known as a ‘Subject Access Request’. This information is provided to you free of charge however, we can refuse to respond or charge a ‘reasonable fee’ of £10 inc. VAT when a request is manifestly unfounded, excessive or repetitive.

We will provide this information in a structured, commonly used and machine-readable form such as a CSV file. This allows you to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without hindrance to usability. Where possible, we will provide this information via remote access to a secure self-service system, such as our Customer Account area, which would provide you with direct access to your information.

If you would like to submit a Subject Access Request, please contact our Data Protection Officer in writing to:

Data Protection Officer
Adept Vehicle Management 
Independent House, Apedale Road
Chesterton, Newcastle-under-Lyme
Staffordshire,
ST5 6BH

Email: [email protected]

We will response to your request without delay and at the latest, within one month of receipt of your request.

Rectifying or updating personal data

If you believe the personal data we hold about you is inaccurate or incomplete, you have the right to rectification. You can let us know about any changes to. Where possible, we will also inform any third parties to whom we have disclosed the personal data in question to so they can rectify their records.

We will typically respond to your request within one month, although this can be extended by two months if your request for rectification is complex, such as a Novation or Transfer of Lease.

Withdrawing Consent

You have the right to withdraw your consent for us to collect, process and store your data at any time. If you wish to withdraw your consent, please confirm this in writing to our Data Protection Officer:

By Post:
Adept Vehicle Management 
Independent House, Apedale Road
Chesterton, Newcastle-under-Lyme
Staffordshire,
ST5 6BH

By Email: [email protected]

Please note, by withdrawing consent, Adept Vehicle Management may be unable to execute the contract that you have entered into with us and will result in termination of our services. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

Right to complain

If you have a complaint about any aspect of data protection or if you feel your privacy has been breached by us, we would like to hear from you. To help us investigate and resolve your concerns as quickly as possible, please contact our Data Protection Officer:

Adept Vehicle Management 
Independent House, Apedale Road
Chesterton, Newcastle-under-Lyme
Staffordshire,
ST5 6BH

By Phone: 01782 562246
By Email: [email protected]

If you are unhappy with the final response you have received from Adept Vehicle Management, you have the right to complain to the supervisory authority, the Information Commissioner’s Office (ICO) within three months of your last meaningful contact with us. You can call the ICO on 0303 123 1113 or by visiting their website: https://ico.org.uk/.

Changes to the Privacy Policy

 

Due to the further development of our website, government regulations or the implementations of new technologies, this policy will be reviewed, and may change, from time to time. Adept Vehicle Management reserves the right to change this data protection information at any time with effect for the future. The revised policy will be posted to this page so that you are always aware of the information we collect, how we use it and under what circumstances we disclose it. We therefore recommend you read the current data protection information again from time to time.

Last updated: 06 May 2018 Date of Next Review: May 2019