Privacy Policy

Volkswagen Financial Services Rent-a-Car is a trading style of Volkswagen Financial Services (UK) Limited (“VWFS”, “we”, “us”), a company registered in England and Wales with company registration number 2835230 whose registered office is at Brunswick Court, Yeomans Drive, Blakelands, Milton Keynes, MK14 5LR.

VWFS is committed to protecting and respecting any personal information you share with us. This policy describes what types of information we collect from you when you use our Rent-a-Car website(s) how it is used by us, how we share it with others, how you can manage the information we hold and how you can contact us. For data protection purposes, the data controller is of this information is VWFS. Please note, if you are a finance customer, this policy is supplemental to the privacy information provided to you when your proposal for finance was submitted to us, you can find this information here: https://customer.vwfs.co.uk/privacy-policy.html.

The location (named on the rental agreement) is the data controller of your personal data (and that of any named additional drivers) processed for the purposes of the rental agreement.

Please read the following carefully to understand our practices regarding your personal information and how we will treat it. By visiting this website, you are accepting and consenting (where relevant) to the practices described in this policy.

Our website(s) may, from time to time, contain links to and from the websites of these selected third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Therefore, please check these policies before you submit any personal information to these third-party websites.

The contents of this policy may change from time to time so you may wish to check this page occasionally to ensure you are still happy to share your information with us. Where possible, we may also contact you directly to notify you of these changes.

This version of our Privacy Policy is live from July 2024.

What information do we collect?

We only collect information which is necessary, relevant and adequate according to the purpose you are providing it for. Generally, the information we collect includes some or all of the following:

1. Full name (including title);
2. Address;
3. Phone number;
4. Date of birth;
5. Email address;
6. The date and time you used our services;
7. The pages you visited on our website and how long you visited us for;
8. Device identifiers such as your IP address;
9. Your GPS location (where you have permitted access to this);
10. The internet browser and devices you are using;
11. Cookie, Pixels or Beacon information (for more information please see our Cookie Policy);
12. The website address from which you accessed our website;
13. Where you engage with us in a business context, we may collect company name, address, and email address; and
14. Banking and credit card details (however please note VWFS do not store this information).

How is your personal information collected?

We may collect information about you (from:

• You, including if you contact us (including any email address, Internet Protocol (IP) address or telephone number supplied by your electronic service provider) or if you use our products or services, or engage with our website;
• Our franchised retailers (some of this information does not identify you personally, but provides us with information about how you use our services and engage with us and we use this information to improve our services and make them more useful to you); and/or
• Other companies who provide services to us, such as insurance companies.

We may also collect information about you when you use VWFS’s websites and applications. This online information includes some or all of the following:

• Information you provide when you register to use the sites, browse content on the sites or use other functionality;
• Details of your visits to the sites including, but not limited to traffic data, location data and other communication data, and the resources that you access; and/or
• Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform (please see further our Cookies Policy);

Some of the information that we may obtain about you from our franchised retailers, insurance companies do not identify you personally but provides us with information about how you use our services and engage with us (we use this information to improve our services and make them more useful to you).

How do we use your information?

VWFS will only process information that is necessary for the purpose for which it has been collected. There are various ways in which we may use or process your personal information. We list these below:

Consent

Where you have provided your consent, we may use and process your information (including cookie data) to contact you from time to time about promotions, events, products, services or information which we think may be of interest to you. For further information on our use of cookie data, please see our Cookie policy. You can withdraw your consent at any time by contacting us on the details stated below or, in relation to any marketing messages you receive, by using the unsubscribe option included in those messages.

Legitimate Interests

We may use and process your personal information as set out below where it is necessary for us to carry out activities for which it is in our legitimate interests as a business to do so.

Processing necessary for us to support customers with enquiries

To respond to correspondence which you send to us and fulfil the requests you make to us (for example, when you raise queries to us via our website).

Processing necessary for us to respond to, or understand, customers’ needs

To analyse, evaluate and improve our products and services so that your visit and use of our website, applications, and dealer network are more useful and enjoyable (generally, the information gathered doesn’t identify you personally.

Processing necessary for us to promote our business, brands and products and measure the reach and effectiveness of our campaigns

1. To contact you with targeted advertising delivered online through social media and other platforms operated by other companies, unless you object. You may receive advertising based on information about you that we have provided to the platform or because, at our request, the platform has identified you as having similar attributes to the individuals whose details it has received from us. To find out more, please refer to the information provided in the help pages of the platforms on which you receive advertising from us;
2. To identify and record when you have received, opened or engaged with our website or electronic communications (please see our Cookie policy for more information);
3. To contact you when your local franchised retailer opens, closes or moves premises; and
4. To obtain analytics including those received from search engine providers that assist us in the improvement and optimisation of the site.

Processing necessary for us to assess and respond to complaints, claims and regulators

1. To respond to queries, complaints or claims and to manage legal and regulatory requests and requirements; and
2. To enforce or protect our legal rights or to establish, bring or defend legal claims.

Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively

1. To verify the accuracy of information that we hold about you and create a better understanding of you as a customer;
2. For network and information security purposes i.e. in order for us to take steps to protect your information against loss, damage, theft or unauthorised access;
3. To comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request); and
4. To inform you of updates to our terms and conditions and policies, where possible.

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Sharing Your Personal Information

Why might we share your personal information with third parties?

We do not sell your information to third parties, but we do work closely with our franchised retailers and third-party service providers who fulfil business activities for us (e.g. roadside assistance) In addition, we may have a legal or other obligation to share your personal information.

Which third parties may process your personal information?

From time to time, we may disclose your information to companies or organisations:

• Where the law says we may or must do so;
• To companies that provide services to us so we can perform activities relating to your contract and/or to enforce any contract we have with you and/or to protect our rights and/or property;
• To our franchised retailers to provide you with information about your rental booking or to manage any request or complaint you have made to us; or
• To our advisors, and investors and their advisors for corporate finance purposes, for example, in the event that we sell or buy any business or assets, or if VWFS or substantially all of its assets are acquired by a third party.

When might we share your personal information with other entities in the Group?

There are circumstances where we share your information with our parent company (or other companies within our Group), where necessary, in order to:

• Handle complaints;
• Provide you with service(s) or information that you have requested;
• Facilitate audit, statistical analysis, risk management and product and service development purposes; and/or
• Comply with legal requirements.

How secure is your information with third-party service providers and other entities in our group?

We take steps to ensure that any third-party partners who handle your information comply with data protection legislation and protect your information just as we do. We only disclose personal information that is necessary for them to provide the service that they are undertaking on our behalf. We will aim to anonymise your information or use aggregated none-specific data sets wherever possible.

Due to the international nature of our business, there may be some instances where your information is processed or stored outside of the United Kingdom and/or the EU. In those instances, we will ensure that appropriate safeguards are in place for that transfer and storage as required by applicable law.

How do we keep your information secure?

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and/or other third parties who have a business need to know it. They will only process your personal information on our instructions and are subject to a duty of confidentiality. Details of these measures may be obtained from the Data Protection Officer (please see contact details below).

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

Finally, we have established procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

How long do we keep your information for?

Once collected via our website, VWFS pass the information (including personal data) to the rental location(s) who facilitate the reservations and subsequently, (where entered into) the rental agreement(s). As stated above, where a rental agreement is entered into, the location (named on the rental agreement) is the data controller of your personal data (and that of any named additional drivers) processed for the purposes of the rental agreement. As such, please refer to the locations’ privacy policies to understand how long they will retain your personal data for.

If we have a relationship with you (e.g. you are also a finance customer of ours), we hold your personal information for 6 years from the date our relationship ends. We hold your personal information for this period to establish, bring or defend legal claims.

In some circumstances, there may be exceptions to the periods mentioned above are, for example where:

• the law requires us to hold your personal information for a longer period, or delete it sooner;
• you have raised a query, complaint or concern regarding a product or service offered by us, in which case we will retain your information for a period of 6 years following the date of that complaint or query; or
• you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law (see How can you manage the information we hold about you?) for further information.

How can you manage the information we hold about you?

You have the right as an individual to access the personal information that we hold about you and make corrections if necessary. You also have the right to withdraw any consent you have previously given us and ask us to erase information we hold about you. You can also object to our use of your personal information (where we rely on our business interests to process and use your personal information).

You have a number of rights in relation to your personal information under data protection law. In relation to most rights, we will ask you for information to confirm your identity and, where applicable, to help us search for your personal information. We will respond to you within one month of receipt of the request (unless there are exceptional circumstances) or after we have received any information requested (including any identification documents requested).

You have the right to:

1. Ask for a copy of the information that we hold about you;
2. Correct and update your information;
3. Withdraw your consent (where we rely on it). Please see How do we use your information? for further information
4. Object to our use of your information (where we rely on our legitimate interests to use your personal information) provided we do not have any continuing lawful reason to continue to use and process the information. When we do rely on our legitimate interests to use your personal information for direct marketing, we will always comply with your right to object;
5. Erase your information (or restrict the use of it), provided we do not have any continuing lawful reason to continue to use and process that information; and/or
6. Transfer your information in a structured data file (in a commonly used and machine readable format), where we rely on your consent to use and process your personal information or need to process it in connection with your contract.

You can exercise the above rights and/or manage your information by contacting us using the details below:

• Post: Volkswagen Financial Services (UK) Limited, One Delaware Drive, Tongwell, Milton Keynes MK15 8HG
• Email: DPO@vwfs.co.uk

Who can you contact if you have a question or a complaint?

If you have any specific data protection concerns or a complaint, you can address it to our Data Protection Team at DPO@vwfs.co.uk.

You also have the right to lodge a complaint with a data protection regulator in Europe, in particular in a country you work or live or where your legal rights have been infringed. The contact details for the Information Commissioner’s Office, the data protection regulator in the UK, are below:

Post:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Call: 03031 231 113

If you wish to raise a complaint to the ICO, you can do so via their website under ‘Make a complaint’ on the attached link https://ico.org.uk/make-a-complaint/.