Introduction

This privacy statement applies to L.O.P Commercial LTD, in the UK and any of its associated or subsidiary undertakings and affiliates which control and make use of any visitor information collected.

If you have any questions regarding this privacy statement or do not feel that your concerns have been addressed, please direct your questions to our director via jon@lopcommercial.co.uk

Data Protection Controller and Contact Details

L.O.P Commercial Ltd is a “Data Controller” and as such it is required to notify you how your information is held and used pursuant to relevant data protection laws. Questions and queries about this privacy policy and or about or how we as an organisation use your personal data can be sent to our privacy officer by email via jon@lopcommercial.co.uk.

Information Collection

In the event that you choose to supply personal information either through the website, email or by telephone we will collect, use, share and store this personal data. We collect this information when we speak to you on the telephone, and from documents, email or other correspondence that you send to us.

Where personal and financial information relating to another person or your partner is supplied by you, you confirm that you have their consent or are otherwise entitled to provide this information to us and for us to use it.

We will collect further information if you contact us with comments or specific requests which may include requests to be contacted for marketing purposes or by social media in which case, in addition to the data set out above, we may also hold, use, share and store marketing preferences, payment details, engagement details, likes, retweets, shares, reactions, comments.

For training purposes, any calls with us may be recorded. Where calls are recorded you will be advised of this at the outset of the call. Details of any call will be monitored and recorded. Such details will include (but not be limited to) the caller identification telephone number, the number called, the time, date and duration of the call and the disposition of the call (please note that call monitoring excludes the actual call recording).

Information Use

We will only use any personal information which you supply to us through this website or on the telephone when the law allows us to. The law states that we must identify the purpose and basis upon which we use your personal data. We rely on a number of lawful basis for processing your personal data:-

1. Where you have given your informed, unambiguous and specific consent;

2. Where we need to comply with a lawful obligation;

3. Where we need to perform a contract that we have entered into with you; and

4. Where it is necessary for us to use your personal information to pursue our legitimate interests (or those of a third party).

We have stated below the purposes for which we use your personal data

We will use your information to comply with our lawful obligations to prevent and detect fraud, money laundering and other crimes, carry out regulatory checks and meet our obligations to any relevant regulatory authority; to assist us in providing our services to you; to arrange finance and or refinancing facilities for you and to improve and develop our services to you and other customers; and to market to you and we may periodically send promotional emails about new services or other information which we think you may find of interest, using the information you have provided and we will ensure that any such marketing activities comply with applicable law, as well as ensuring that we implement procedures to obtain necessary consents before sending you emails containing information about L.O.P Commercial Ltd (and its parent company’s other service lines) and their service offerings so that we can pursue our legitimate interest in creating lasting relationships with our clients. You may at any time request that we discontinue sending you such materials.

We will use information you supply to inform our decision making when arranging finance facilities on your behalf and we may combine this information with other information you give us and information we collect about you.

In relation to the website and social media platforms only, the personal identifying information you submit is used to process your enquiry and the information gathered from telephone calls allows us to track the source of the call. The cookies information is used pursuant to your consent and to pursue our legitimate interest and to help us understand more about how our website is used and to improve our site.

Disclosure of Information to Third Parties

We may share your personal information with banks, funders, specialist finance houses, and insurance brokers, for the purpose of arranging the most competitive tailored finance facility for you, as well as for the detection and prevention of fraud.

We may share your information with selected third parties including:

• Business partners, suppliers, and sub-contractors for the performance of any contract we enter into with them or you, including without limitation to any data processor we engage.

• Analytics and search engine providers that assist us in the improvement and optimisation of

our site.

We may disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.

• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Use or terms and conditions of supply and other agreements; or to protect the rights, property, or safety of L.O.P Commercial Ltd, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

• In the event we are subject to audit by a regulatory body or inspectorate, including but not

limited, to the British Vehicle and Rental Leasing Association, the Financial Conduct Authority, or the Information Commissioner’s office, your information may be reviewed.

Examples of where your personal information will be supplied to third parties are circumstances where we would need to engage those third parties to provide public relations and marketing, IT support, document management systems, case management systems, printing, reprographic support, event hosting, email marketing management systems and market insight services. In these scenarios all third parties will be required to take appropriate security measures to protect your personal information in line with our engagement with them and in accordance with the laws. We do not allow third parties to use your personal data for their own purposes.

Where appropriate, personal information may be disclosed to law enforcement, regulatory or other government agencies or third parties where necessary or desirable to comply with legal or regulatory obligations or requests or for the purposes identified above.

In cases where legislation requires us to carry out an identification check, we will validate your name, address and other personal information supplied by you against an appropriate third party database. You should advise us if you do not consent to such a check being made. In performing these checks personal information provided by you may be disclosed to a registered Credit Reference Agency which may keep a record of that information. The checks are only to confirm your identity. A credit check is not performed and your credit rating will be unaffected.

Credit Reference Agencies

In order to process any finance application, we will supply your personal information to credit reference agencies (CRAs) and they will give us information about you, such as about your financial history. We do this to assess creditworthiness and product suitability, check your identity, manage your account, and prevent criminal activity. CRAs will share your information with other organisations. The identities of the CRAs, and the ways in which they use and share personal information, are explained in more detail at https://www.experian.co.uk/legal/crain/.

Retention of Personal Data

We will only retain your personal information for as long as necessary to fulfill the purpose for which we collected it in line with statutory and professional rules of retention. In the majority of

instances, the period for retaining your personal data shall be 6 years from the date of closure of contact which you may have with us. In the event that the basis on which we are holding your personal information requires this information to be kept for a reduced period of time then it shall

be retained in accordance with our retention policies in place from time to time. Examples of this are:-

1. Marketing information – the retention period shall be the period of our relationship with you and for a period of 6 years afterwards.

2. Social media information – for a period during which we are connected with you on any given social media platform.

3. Client matters (including where you are taken on as a client and have an engagement for services with us) – 6 years from the date on which the matter has been closed or has ended.

4. Information required by law when commencing a client engagement – period of 6 years from the date on which the relevant matter has ended.

Access to Information

We are dedicated to providing reasonable access to visitors who wish to review the personal information retained, if any. In all cases we will treat requests to access information or change information in accordance with applicable legal requirements and a charge may be levied to cover the administration costs of such requests. Please contact jon@lopcommercial.co.uk should you wish to access your personal information.

Your rights in respect of your personal information Under certain circumstances, by law, you have the right to:-

1. Request access to your personal information as stated above.

2. Request correction of any personal information that we hold about you. We have an obligation to ensure that the information we hold about you is complete and accurate;

3. Right to deletion – you have a right to ask us to delete or remove personal information where there is no good reason for us to continue to hold/process it;

4. Object to processing – you can object to the processing of your personal information (where we are relying on a legitimate interest or those of a third party) and remove your right to consent in certain circumstances;

5. Request for transfer – you may request for your data to be transferred to another party and/or put in place a restriction on the processing of such data;

6. Withdrawal to consent – where you have provided your consent to the collection, processing and transfer of your personal information for a specific purpose you have the right to withdraw your consent for that specific processing. To withdraw your consent please email jon@lopcommercial.co.uk and put in the subject line “withdrawal of consent” and state in the body of the email the nature of the processing to which you wish your consent to be withdrawn.

7. The right to restrict processing, for example while we are reviewing the accuracy or completeness of data or deciding on whether any request for erasure is valid. In such cases we shall continue to store the data, but not further process it until such time as we have resolved the issue.

8. The right to data portability which, subject to a number of qualifying conditions, allows individuals to obtain and reuse their personal data for their own purposes across different services.

9. Rights in relation to automated decision making and profiling. Information Security

Changes to our Privacy Policy

L.O.P Commercial Ltd, in the UK, reserves the right to modify or amend this privacy statement at any time and for any reason. Nothing contained herein creates or is intended to create a contract or agreement between L.O.P Commercial Ltd and any user visiting the website or providing identifying information of any kind.

Complaints

If you have any concerns over how we have used or are using your data then please contact jon@lopcommercial.co.uk in the first instance.

If you are still not satisfied that we have addressed your concerns adequately you have a right to lodge your complaint with the Information Commissioners Office, the details of which are available at www.ico.org.uk.

Policy updated: 25/02/2024