Volkswagen Financial Services | Rent-a-Car is a trading style of Volkswagen Financial Services (UK) Limited (VWFS), a company registered in England and Wales with company registration number 2835230 and VAT registration number GB 745 9638 83, whose registered office is at Brunswick Court, Yeomans Drive, Blakelands, Milton Keynes, MK14 5LR (“we“) are committed to protecting and respecting any personal information you share with us.
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, 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 Volkswagen Financial Services (UK) Limited.
If you are a finance customer, this policy is supplemental to the data protection privacy notice provided to you before your proposal for finance was submitted to us.
Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it. By visiting this website you are accepting and consenting to the practices described in this policy.
We will always give you the option to opt out of receiving marketing communications from us. We will never send you unsolicited ‘junk’ email or communications, or share your data with anyone else who might. We do not sell your information to third parties, but we do work closely with our Group companies, companies that provide services to us and our franchised retailers (known collectively as our selected third parties) who help us to provide you with the information, products and services that you request from us.
Our site 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. Please check these policies before you submit any personal information to these 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.
What information do we collect?
The information we collect includes some or all of the following:
- Full name (including title);
- Phone number;
- Date of birth;
- Email address;
- Vehicle information (including registration number, VIN, service reminders, mileage and warranty repair information);
- The date and time you used our services;
- The pages you visited on our website and how long you visited us for;
- Device identifiers such as your IP address;
- Your GPS location (where you have permitted access to this);
- The internet browser and devices you are using;
- The website address from which you accessed our website;
- Details of any transactions between you and us or any franchised retailer;
- Where you engage with us in a business context, we may collect your job title, company contact details (including email addresses), fleet size and company details (some of which we may obtain from an online or public business directories);
- Voice recordings of calls you make to our customer service centre;
- “Live chat” records;
- Any information within correspondence you send to us;
- Credit Reference Data;
- Financial and employment details;
- Banking and credit card details;
- Documentation relating to your identification; and
We only collect information which is necessary, relevant and adequate for the purpose you are providing it for.
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 or other online applications;
• VWFS’s websites and applications, including 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 or your vehicle from our franchised retailers, insurance companies and repairers does 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. You will always have the option to opt out of receiving marketing communications from us and you can withdraw your consent or object at any time. We will never send you unsolicited ‘junk’ email or communications, or share your personal information with anyone else who might.
There are various ways in which we may use or process your personal information. We list these below:
Processing necessary for us to understand customers’ needs
1. To analyse, evaluate and improve our products and services so that your visit and use of our website and applications are more useful and enjoyable (we will generally use data gathered from many people so that it 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
2. 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;
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 operate the administrative and technical aspects of our business efficiently and effectively
5. 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;
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 who may in turn process your information?
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 (such as marketing, events and market research etc.) In addition, we may have a legal or other regulatory obligation to share your personal information.
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) in order to fulfil orders, transactions, handle complaints or provide you with a service or information that you have requested or for audit, statistical analysis, risk management and product and service development purposes and to comply with legal requirements. For example we will share information with branded trading divisions of Volkswagen Group United Kingdom Limited (“VWG”) where you enquire about their services through us or where you make a complaint to us and later make the same or similar complaint to them.
VWG may also use your information to:
- provide you with information about their own products or services (in ways the law allows). You have the right to object to receiving this information at any time; and
- carry out their obligations arising from contracts you enter into with them.
In addition, both VFWS and VWG utilise the Customer Engagement Platform (CEP) for the purposes of:
- personalising marketing material, including offers and information regarding products and services which may be of interest to you;
- enhancing your online journeys.
For CEP to operate effectively, VWFS and VWG share certain personal data and cookie data relating to customers and/or websites users. The information shared between VWFS and VWG is the minimum required to fulfil the purpose. Both VWFS and VWG are committed to protecting and respecting any personal data and cookie data shared in accordance with data protection laws. For data protection purposes, VWFS and VWG are independent data controllers of the personal and cookie data utilised by CEP.
For more information regarding VWG’s data protection policy or to object to VWG’s use of your information, please visit the brand’s website and/or the VWG Privacy Statement available at http://www.volkswagen.co.uk/privacy
We will also share your personal information with third parties and/or other companies within our Group if we have a duty to do so, e.g. to register your car with the DVLA, to assist an authorised authority, regulatory body or court, or to enforce or protect our legal rights or to establish, bring or defend legal claims.
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 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 other third parties who have a business need to know. They will only process your personal information on our instructions and they 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?
We do not retain personal information in an identifiable format for longer than is necessary.The only exceptions to the periods mentioned above are where:
• The law requires us to hold your personal information for a longer period, or delete it sooner;
• You have raised a 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 further How can you manage the information we hold about you?);
How can you manage the information we hold about you?
You have the right 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 30 days (unless there are exceptional circumstances) after we have received any request (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 further How do we use your 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: Rent-a-car Volkswagen Financial Services (UK) Limited, One Delaware Drive, Tongwell, Milton Keynes MK15 8HG
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 Authority 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 Authority in the UK, are below:
Information Commissioner's Office
Call: 0303 123 1113