Knowles Associates Total Fleet Management Ltd and Ensure UK Ltd are committed to ensuring your privacy and personal information is protected. Knowles Associates Total Fleet Management Ltd and Ensure UK Ltd are the data controllers of your personal information and are responsible for complying with data protection laws. For the purposes of this Privacy Policy, references to "we" or "us" shall refer to Knowles Associates Total Fleet Management Ltd and Ensure UK Ltd.

This Privacy Policy should be brought to the attention of any additional parties included in your Contract (such as additional drivers).

By providing your personal information or the personal information of someone included in your contract, you acknowledge that we may use it in the ways set out in this Privacy Policy. We may provide you with further notices highlighting certain uses we wish to make of your personal information.

From time to time we may need to make changes to this privacy policy, for example, as the result of government regulation, new technologies, or other developments in data protection laws or privacy generally. You should check the Knowles Fleet website periodically to view the most up to date privacy policy.

Our Privacy Principles

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1. Personal information you provide is processed fairly, lawfully and in a transparent manner.

2. Personal information you provide is collected for a specific purpose and is not processed in a way which is incompatible with the purpose which we collected it.

3. Your personal information is adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed.

4. Your personal information is kept accurate and, where necessary kept up to date.

5. Your personal information is kept no longer than is necessary for the purposes for which the personal information is processed.

6. We will take appropriate steps to keep your personal information secure.

7. Your personal information is processed in accordance with your rights.

8. We will not transfer your personal information to another country or an international organisation outside the European Economic Area unless required to do so by law. Where this is necessary we will take the required steps to ensure that your personal information is protected. Such steps may include placing the party we are transferring information to under contractual obligations to protect it to adequate standards.

9. We do not sell your personal information and we also do not permit the selling of customer data by any companies who provide a service to us.

How do we collect your personal information?

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• Via online registration
  
  
• Through quotes and application forms
  
  
• Via online Grey fleet registration process
  
  
• Via expenses claim forms
  
  
• Via mileage claim forms
  
  
• Via feedback forms
  
  
• When you fill out a survey
  
  
• Via cookies. You can find out more about this in our cookies policy;
  
  
• Via our telephone calls with you, which may be recorded
  
  
• When you provide your details to us either online or offline
  
  
• Through Dash Cam footage supplied in the event of an accident
  
  
• Via your Driving Licence
  

We also collect your personal information from:

• Your employer
  
  
• Insurers

What personal information do we collect?

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The information that we collect will depend on our relationship with you. Where other people are named on your contract, we may ask you to provide the information below in relation to those people too, if this is relevant to your contract.

Where we are the data controller of personal information we may collect the following:

• Contact details such as name, email address, postal address and telephone number.
  
  
• Details of any other persons included on the contract.
  
  
• Identification information such as your date of birth, national insurance number and payroll number.
  
  
• Driving licence details including details of convictions.
  
  
• Salary Information including but not limited to Gross Salary, Hours Worked, Pension Status.
  
  
• Information relevant to use of a car at work such as insurance information, MOT and Road Fund Licence details, details of usage.
  
  
• Information relevant to any insurance claim or your involvement in the matter giving rise to a claim.
  
  
• Information obtained through our use of cookies. You can find out more about this in our cookie policy.
  
  
• Your marketing preferences.
  
  
• Images and voice recordings from dash cam footage

How do we use your personal information?

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We may process your personal information for several different purposes and these are set out in more detail below. Under data protection laws we need a reason to use and process your personal information and this is called a legal ground. We have set out below the main reasons why we process your personal information and the applicable circumstances when we will do so.

• Processing is necessary for us to provide you with quotes for a lease vehicle, administer your lease contract, manage complaints, process mileage and expense claims, manage accident claims, undertake driving licence checks and verify your own vehicle for use at work. If you do not provide such information, we will be unable to offer you a lease vehicle, you will not be able to use your own vehicle at work and/or you will not be able to use Pool Cars/Business Use only vehicles.
  
  
• Where we have a legal or regulatory obligation to use such personal information, for example, when our regulators, the Financial Conduct Authority (FCA) and our data protection regulator, the Information Commissioner's Office (ICO) wish us to maintain certain records of any dealings with you.
  
  
• Where we need to use your personal information to establish, exercise or defend our legal rights, for example when we are faced with any legal claims or where we want to pursue any legal claims ourselves.
  
  
• We will only ask for your consent when signing up for a new or replacement lease car, when registering your own car for use at work and to be able to provide you with marketing information (including information about other products and services). Without your consent, we cannot supply a lease car, enrol you in Grey fleet or be able to supply you with details of our services and offers.
  
  
• Where we have appropriate legitimate business need to use your personal information such as maintaining our business records, developing and improving our products and services, all whilst ensuring that such business need does not interfere with your rights and freedoms and does not cause you any harm.

Legal Grounds

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Who do we share your personal information with?

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We disclose your information to the third parties listed below for the purposes described in this Privacy Policy.

This might include:

• Where you have named an alternative contact (such as a PA) to speak with us on your behalf. Once you have told us your alternative contact, this person will be able to discuss all aspects of your contract with us and make changes on your behalf.
  
  
• Your Employer
  
  
• A dealership or lease company in respect of delivering your vehicle.
  
  
• A dealership or lease company in respect of setting up In-Car Connected services.
  
  
• A lease company or other maintenance provider in respect of vehicle maintenance.
  
  
• A dealership in respect of obtaining any applicable government grant on your chosen vehicle.
  
  
• Pod Point in respect of electric vehicle charging points
  
  
• A lease company or collection agent in respect of collecting your vehicle.
  
  
• An Insurer/Broker, Solicitors and Recovery Agents in respect of an accident claim.
  
  
• A body repairer in respect of repair works following an accident.
  
  
• A hire car company in respect of a replacement vehicle while your vehicle is off road.
  
  
• An Insurance Company in respect of your private policy where you have given us permission to do so.
  
  
• The DVLA in respect of obtaining your driving licence details.
  
  
• The police, government agencies, councils, parking authorities or other third parties in respect of Parking fines, Speeding fines, Bus Lane Contravention, Dart charge or other applicable fines or charges.
  
  
• A third-party mileage/expenses provider where your employer has specified the use of such.
  
  
• The police and other third parties or law enforcement agencies where reasonably necessary for the prevention or detection of crime.
  
  
• Our third-party services providers such as IT suppliers, auditors, lawyers, document management providers and tax advisers.
  
  
• Regulatory authorities such as the Financial Conduct Authority and the Information Commissioner’s Office.
  
  
• Selected third parties in connection with the sale, transfer or disposal of our business.

How long do we keep records for?

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We will only keep your personal information for as long as reasonably necessary to fulfil the relevant purposes set out in this Privacy Policy and to comply with our legal and regulatory obligations. The time we retain your personal information for will differ depending on the nature of the personal information and what we do with it. How long we keep personal information is primarily determined by our regulatory obligations. We typically keep quote information for 3 years, and contract records for up to 7 years from the end of our relationship with you. In some cases, such as if there is a dispute or a legal action we may be required to keep personal information for longer.

Your rights

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The right to access your personal information:

You are entitled to a copy of the personal information we hold about you and certain details of how we use it. There will not usually be a charge for dealing with these requests. Your personal information will usually be provided to you in writing.

The right to rectification:

We take reasonable steps to ensure that the personal information we hold about you is accurate and complete. However, if you do not believe this is the case, please contact us and ask us to update or amend it.

The right to erasure:

In certain circumstances, you have the right to ask us to erase your personal information, for example where the personal information we collected is no longer necessary for the original purpose or where you choose not to proceed with a contract or use your vehicle at work. However, this will need to be balanced against other factors, for example according to the type of personal information we hold about you and why we have collected it, there may be some legal and regulatory obligations which mean we cannot comply with your request.

Right to restriction of processing:

In certain circumstances, you are entitled to ask us to stop using your personal information, for example where you think that the personal information we hold about you may be inaccurate or where you think that we no longer need to process your personal information.

Right to data portability:

In certain circumstances, you have the right to ask that we transfer any personal information that you have provided to us to another third party of your choice. Once transferred, the other party will be responsible for looking after your personal information.

Right to object to direct marketing:

You can ask us to stop sending you marketing messages at any time.

The right to withdraw consent:

For certain uses of your personal information, we will ask for your consent. Where we do this, you have the right to withdraw your consent to further use of your personal information. Please note in some cases we may not be able to provide a contract, or you may not be able to use your vehicle at work if you withdraw your consent.

The right to lodge a complaint:

You have a right to complain to the ICO at any time if you object to the way in which we use your personal information. More information can be found on the Information Commissioner’s Office website: https://ico.org.uk/ You can make any of the requests set out above using the contact details provided to you. Please note that in some cases we may not be able to comply with your request for reasons such as our own obligations to comply with other legal or regulatory requirements. However, we will always respond to any request you make and if we can't comply with your request, we will tell you why. In some circumstances exercising some of these rights will mean we are unable to continue providing you with a service which may result the termination of your contract, you will be liable for any termination fees or you will be unable to continue using your own vehicle at work.

Marketing

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We may use your information to provide you with details of products and services that may be of interest to you, but we will only do this where you have provided your consent. You can always change your mind by contacting us and telling us you no longer wish to be contacted.

We would like to use ‘push notifications’ to provide you with news, updates and offers. You will only receive these notifications if you opt-in by clicking ‘allow’ via the pop-up when first accessing our site.

If you would like to unsubscribe at any time and don’t know how to, please call us on 01206 252300 option 6 for assistance. Push notification subscriptions are controlled by your internet browser and device.

We do store any identifiable data about you or your device as a result of push notifications.

If you have any questions or require additional assistance regarding our push notifications then please contact us info@knowlesfleet.com or 01206 252300 option 6

We are committed to only sending you marketing communications that you have clearly expressed an interest in receiving. If you wish to unsubscribe from emails sent by us, you may do so at any time by following the unsubscribe instructions that appear in all emails. Otherwise you can always contact us to update your contact preferences. In such circumstances, we will continue to send you service related (non-marketing) communications where necessary.

Please note that we may retain any data provided to us on our websites for a limited period, even if you do not complete your quote. The information may be used to enquire as to why you did not complete your quote or for us to better understand your needs but only if you have agreed for us to contact you.

Contact Details

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If you wish to contact us about Data Protection, the details are below:

Knowles Associates
Red Lion House
The Green
Great Bentley
CO7 8QG

Email: dp@kafleet.com

If you would like to contact the UK’s Information Commissioner’s Officer direct; please write to the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, Telephone: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number https://ico.org.uk /global/contact-us/email/