Short Term Car Leasing Ltd is a trading name of Cocoon Vehicles Ltd
Short Term Car Leasing Ltd registered in England No. 07367263. Registered Office: Cocoon Group Ltd, The Old Co-operative, 36 Holbrook Road, Belper, Derbyshire, DE56 1PA. A full list of companies can be requested but include; Cocoon Vehicles Ltd, Registered in England 6113683, Flexigo Cars UK Ltd, Registered in England 09464321, Short Term Car Leasing Ltd, Registered in England 07367263, Derby Sameday Couriers Ltd, Registered in England 07044190. Cocoon Vehicles Ltd is authorised and regulated by the Financial Conduct Authority No. 608180. Cocoon Vehicles Ltd is registered with the Information Commissioner’s Office on the Data Protection Register No. Z1350323
By choosing Short Term Car Leasing Ltd we understand that you have placed a great deal of trust in Short Term Car Leasing Ltd and the connected companies. We also know that you will want all personal information that you submit to us to be kept as private and as secure as possible. For your peace of mind, here’s how we will and will not use the personal information you give us.
For the purposes of the Data Protection Act (‘DPA’), we are the ‘Data Controller’ (i.e. the company who is responsible for, and controls the processing of, your personal data).
This Policy was last updated in January 2018 in line with the General Data Protection Regulation (GDPR) reform that is due to take effect from May 2018. The reform sets out more rights for individuals and greater transparency in how personal data is processed by Data Controllers, such as consent, distribution, marketing and deletion. As we are a credit intermediary, we undertake a number of financial tasks that relate to consumer credit. Our firm’s lawful basis for processing your personal data is done so under a Legitimate Interest – Article 6(1)(f) – “the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.”
Personal Information collection
By entering your personal information in the Short Term Leasing web site, you accept that we may retain your information and it may be held by Short Term Car Leasing Ltd and/or Cocoon Vehicles Ltd or by any third party company which processes it on our behalf.
We will obtain personal data about you (including your name, address, date of birth, contact information, interests, payment details, financial information and opinions) and those whose personal data you have with express authority disclosed to us (‘others’) whenever you complete an online form or make a telephone enquiry with us to receive our services. If you submit an online enquiry you will be required to agree to the terms of this Policy which include permitting us to contact you for the purposes of the finance related enquiry via the contact means of which you provide us with the details of. i.e. email address, telephone number, etc.
For example, we will obtain personal data when you (e.g. contact us for any reason, or purchase services). In certain circumstances, we may hold sensitive personal data if you provide us with such information if you feel that it is relevant for the purpose of your enquiry, but we will not ask for such information. Any sensitive personal data obtained and recorded will only be done so with your explicit consent.
What we collect and why
The information we gather from customers helps us to continually improve the service we offer to our customers.
When you use the Short Term Leasing service, there are different ways we gather information about you:
- When you register with us, we ask for information such as your name, e-mail address, contact numbers, etc and – if you place an order – your address, employment and bank details. We keep a record of this information. All this is necessary for us to recognise you as a registered customer and to fulfil the orders you place with us.
- We keep a record of the cars you lease through our service, which means we can deal a lot quicker with any problems you may experience with your contract(s) and/or vehicle(s).
- We may keep a record of e-mail correspondence you send us. This helps us keep track of your likes and dislikes and any problems or concerns you’ve had with our products or services.
- Telephone calls made to our Customer Service Helpline may be recorded for monitoring and quality control purposes.
How We Use Your Personal Information
All the information we collect via our website or through correspondence with you is used to operate and improve the service we offer you. We are committed to using your personal information only for:
- Dealing with orders and accounts for the supply of our services and related products.
- Monitoring and improving the Short Term Leasing website and our services.
- Planning and managing Short Term Leasing business activities, including analysing customers’ shopping habits and preferences.
- Enabling third parties to carry out technical, logistical or other functions on our behalf.
- Conducting market research including statistical analysis of customer behaviour which we may disclose to third parties in depersonalised, aggregated form.
- Providing you with information about the products and services we offer.
- Providing you with periodic communications (this may be by post, telephone, SMS, email, twitter, facebook or as part of your Short Term Car Leasing Ltd vehicle delivery) about features, products, services, events, promotions and special offers. Such communications from Short Term Leasing might include advertising for or offers from third parties. If you wish to withdraw your consent from receiving these communications you can do so by informing us in writing.
- Enabling our debt collection agency/solicitors to collect payment from you should that be necessary.
- Preventing and detecting fraud or abuses of our website.
- Allowing us to comply with any requirements imposed on Short Term Car Leasing Ltd/Cocoon Vehicles Ltd by law or court order.
When we share your personal information
Information about our customers is an important part of our business and we do not sell or rent your information to anyone else to enable them to send you direct marketing unless you agree otherwise. However, there are circumstances where it is necessary for us to share personal information in order for us to provide our customers with the Short Term Car Leasing Ltd service. At all times where we use or disclose your information it will remain secure.
Marketing and opting-in
We may share your personal data with organisations as set out in the ‘Disclosure of personal data’ section below. If you have opted-in to receive our marketing material, we will ensure that it is to your requirements and granular. We or they may contact you or others (unless you have asked us or them not to do so) by mail, telephone, text message, email, (each contact method requires its own consent via an opt-in selection) The nature of these marketing communications relate to information on products, services, promotions and special offers which we believe may be of interest to you or others. If you or others would prefer not to receive any further direct marketing communications from us or our business partners, it is possible to opt out at any time. See further ‘Your rights’ below.
The circumstances where we may share some of your information with others are described below:
Third Party Service Providers
We use a number of other companies and individuals to perform functions on our behalf. For example we engage companies to analyse customer information, provide marketing assistance, process credit card payments. We also engage agents including credit reference agencies, fraud prevention and detection agencies and debt collection agencies that we use to process the orders you place with us or who assist us in the service we provide to you. In these instances, we provide them with only the information they need to perform their function.
Sometimes we send offers to selected groups of Short Term Car Leasing Ltd customers on behalf of other businesses. We will not permit other businesses to contact Short Term Car Leasing Ltd customers directly and all such promotional offers will come via Short Term Car Leasing Ltd. If you wish to withdraw your consent from receiving these communications you can do so by informing us in writing.
Protection of Short Term Car Leasing Ltd and others
We release account and other personal information when we believe release is appropriate to comply with the law, to enforce our Terms and Conditions and other agreements or protect the rights, property or safety of Short Term Car Leasing Ltd, our trading brands, our customers or others.
Cookies and Online Marketing Management Tools
Cookies are small text files that web sites can send to your computer. A cookie can be thought of as an internet user’s identification card, which tells a web site when the user has returned. Cookies are not computer programs, and can’t read other information saved on your hard drive. They cannot be used to disseminate viruses, or get a user’s e-mail address etc. They only contain and transfer to the web site as much information as the users themselves have disclosed to that web site.
The European Union Directive on Privacy and Electronic Communications (the “Directive”), which came into force on 31st July 2002, recognises that cookies are a “legitimate and useful tool” for many activities, including verifying the identity of web site users. The Directive makes it compulsory for web sites to inform users if cookies are being used, and to provide some information on how cookies are used. You can find more information on this subject at aboutcookies.org. Finally, the Directive places an obligation on web sites to make users aware that they can set their computers to reject cookies. You will find the instructions on how to do this at aboutcookies.org. However, you should be aware that the Short Term Leasing website may not work correctly without cookies.
Security and Data Retention
Security is very important to Short Term Car Leasing Ltd and we use sophisticated technology to ensure that your information is protected at all times. Secure Socket Layer (SSL) encryption technology is used for protection of information in transit for any sensitive transactions such as bank details. Additional security procedures are in place to protect the confidentiality and integrity of your information.
We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personally identifiable customer information. Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you.
It is important for you to protect against unauthorised access to your password and to your computer. Be sure to sign off when using a shared computer.
Fraudsters create authentic looking, but false or “spoof” websites. Their purpose is to tempt users to enter personal information to be re-used to try and access your bank accounts. Fraudsters are increasingly turning to email to generate traffic to these websites. Recently customers of several financial institutions have received such emails and this activity is only likely to increase. Such emails typically contain a link to a spoof website and advise account holders to enter user names and passwords so that security details can be updated or passwords changed.
If you get any email containing an embedded link and a request for you to enter any personal details, treat it as suspicious and do not input any personal information, even if the page appears legitimate. No reputable company ever sends emails of this type.
Data over the Internet
The internet is a global network – therefore there are cases where your data travels internationally, which may include places outside the European Union. We want you to know that if you visit or order a car through the Short Term Car Leasing Ltd service, you’re agreeing and authorising us to process data this way.
Keeping data secure
We currently safeguard personal data by storing it on a cloud based CRM protected by password and shall ensure that from time to time we use no lesser technical and organisational measures to safeguard personal data which is disclosed to us. Whilst we will use all reasonable efforts to safeguard such personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data which are transferred from you or to you via the internet.
We may monitor and record communications with you (such as telephone conversations and emails) for the purpose of quality assurance, training, fraud prevention or compliance purposes.
Information about other individuals
If you give us information about others, you confirm that the other third party person has appointed you to act on his/her behalf. This is also relevant where others are concerned if you indeed ask another person to act on your behalf as a third party.
Under the third party authorisation, the other person can:
- Give consent on his/her behalf to the processing of his or her personal data for the purposes and reasons set out in this Policy; and
- Receive on his/her behalf any data protection notices.
Such authorisation will remain in place until this has been revoked, either by verbal or written communication.
You have the right to request access to your personal data which we process. This formal request is made under the DPA and is referred to as a Subject Access Request. If you wish to exercise this right and make a Subject Access Request, you should;
- Put your request in writing; either by Email or by letter.
- Include proof of your identity and address (e.g. a copy of your driving licence or passport, and a recent utility or credit card bill);
- Specify the personal data you want access to, including any account or reference numbers where applicable.
You have the right to require us to correct any inaccuracies in your data free of charge. If you wish to exercise this right, you should:
- Either speak to us via telephone or put your request in writing;
- Provide us with enough information to identify you (e.g. account/order number, username, registration details); and
- Specify the information that is incorrect and what it should be replaced with.
You also have the right to ask us to stop processing your personal data for direct marketing purposes. If you wish to exercise this right you should:
- put your request in writing (an email sent to firstname.lastname@example.org with a header that says ‘unsubscribe’ is acceptable);
- provide us with enough information to identify you (e.g. account/order number, username, registration details);
- if your objection is not to direct marketing in general, but to direct marketing by a particular channel (e.g. email or telephone) please specify the channel you are objecting to.
We will only process your personal data providing you have given your consent for us to do so. Under the provisions of the DPA, our firm’s lawful basis for processing personal data is based on a Legitimate Interest.
The legitimate interest relates to a legal requirement for the firm to hold your personal data and financial information on record for up to a total of six years. This six year period satisfies the requirement of our regulator, The Financial Conduct Authority and is also in line with other financial industry retention periods.
In the normal course of business there may be a need for Short Term Car Leasing Ltd or any other firm associated to the business, usually when processing an application for credit, personal data would have to be transferred outside of the European Economic Area (EEA) where those countries do not typically have the same protections and safeguards in place for the protection of personal data to those countries within the EEA.
Short Term Car Leasing Ltd deal with a number of large, international corporations where data is likely to be transferred in this way. Assurances and processes will always be put in place and considered before any international transfer to a non-EEA country is undertaken to ensure the protection and security of the personal data.
Our contact details
We welcome your feedback and questions. If You wish to contact us, please send an email to email@example.com or you can write to us at The Old Co-operative, 36 Holbrook Road, Belper, Derbyshire, DE56 1PA or call us on 0330 330 9425. We may change this Policy from time to time. You should check this policy occasionally to ensure you are aware of the most recent version which will apply each time you deal with us.