Privacy Policy

Who is Icon Automotive Group Limited?

We are a leasing company and we providing deals to our customers. We work with a number of dealerships and manufacturers to get the best possible deal for our customers.

Icon Automotive Group Limited is authorised and regulated by the Financial Conduct Authority (FRN 936998). We are also members of the British Vehicle Rental and Leasing Association. Our company number is SC661331 and our registered office is at:

Icon Automotive Group
Unit 3, 851 London Road, Glasgow, G40 3RX

What do we use Personal Data for?

We will use the Personal Data you disclose to us for the purposes described in our terms. These purposes include:

• To assist us in processing your enquiries and obtaining the services which you require
• To help us identify you and any accounts that you hold with us
• Undertaking credit checks
• Administration
• Research, statistical analysis and behavioural analysis
• Customer profiling and analysing your preferences
• Marketing
• Fraud prevention and detection
• Billing and order fulfilment
• Customising our website and its content to your particular preferences
• To notify you of any changes to our website or to our services which may affect you
• Security vetting
• Improving our services.

What Personal Data do we collect?

We will obtain personal data about you including:

• Your name
• Address
• Date of birth
• Contact information
• Interests
• Payment details
• Financial information
• Opinions

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 or insurance enquiries via the contact means of which you provide us with the details of.

In certain circumstances, we may hold sensitive Personal Data. Any sensitive personal data obtained and recorded will only be done so with your explicit consent.

If you give us information about others, you confirm that the third party has appointed you to act on his/her behalf. 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Such authorisation will remain in place until this has been revoked, either by verbal or written communication.

Why do we handle Personal Data?

It is necessary for us to handle Personal Data in order to provide a service and fulfil our obligations as follows

• Legitimate interests
• Compliance with a legal or regulatory obligations
• Fulfilment of a contract

As we are a credit intermediary, we undertake a number of financial tasks that relate to consumer credit and insurance mediation.

Who do we share your Personal Data with?

If you have opted-in to receive our marketing material, we will ensure that it is to your requirements and granular. We or our marketing partners 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.

When acting as a credit intermediary for vehicle finance and associated insurance products, there would be a reasonable expectation for us to share your personal data with finance houses and funding partners for the purposes of arranging finance for your new vehicle(s).

We may disclose personal data which you provide to us to:

• Our agents and service providers (e.g. providers of web hosting, maintenance services or potential lenders)
• When using the part-ex valuation area of the website (www.iconautomotivegroupltd.com), the personal data that you submit which includes your full name, telephone number, post code, email address as well as the make, model and registration of your vehicle and the vehicle mileage will be securely transferred to Motorway Online Ltd. This transfer is for the purposes of providing you with a purchase price quotation on the vehicle. For further information on how they will use your personal data, please read their Privacy Policy.
• Advise you on insurance products which we are authorised and regulated to do so. These relate to add-on products of your finance agreement with our approved insurance partners; Look After My Car and lookaftermycar.co.uk Trading As Premia Solutions Limited (read their Privacy Policy here) and Tobell Automotive Limited (read their Privacy Policy here).
• When using the website (www.iconautomotivegroupltd.com) online chat facility, the chat message content is relayed to a third-party, The Chat Shop Limited that provide this service on our behalf, 24 hours a day. For the purposes of being transparent, your personal data may be transferred outside of the European Economic Area (EEA) when using this service, however adequate safeguards are in place to ensure its protection. Please also see ‘International Transfers’ below.
• Law enforcement agencies in connection with any investigation to help prevent unlawful activity;
• Our business partners in accordance with the ‘Marketing and opting-in’ section above, specifically being:
  
  • our group companies (as defined in the Companies Act 2006);
  • finance companies with whom we deal for the purposes of providing our services to you;
  • Insurance companies with whom we deal for the purposes of providing our services to you and to verify information provided to us by you; and
  • other third parties with whom we deal with in the course of providing our services to you; and
• Any regulators within whose jurisdiction we operate within from time to time.

Where is Personal Data Stored?

We currently safeguard personal data by storing it on a Customer Relationship Management system 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.

How long is Personal Data stored for?

The retention period for your Personal Data will be up to a total of six years from the end data of the credit agreement. If you do not proceed with an enquiry for finance, or, you do not obtain a finance agreement under which we have arranged for you with our panel of lenders, your personal data is likely to be subject to a shorter retention period and in line with Article 5(1)(c) of the GDPR – “adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’).”

What rights do I have under Data Protection Regulation?

You have the following rights:

• Right to be informed
  About how we collect and use your personal data
• Rights relating to automated decision making
  And/or profiling that has legal or similarly significant effects on you
• Right of access
  To your Personal Data and supplementary information held by us
• Right to data portability
  To obtain and reuse your data for your own purposes across different services
• Right of rectification
  To have inaccurate data rectified or completed
• Right to object
  To the processing of your Personal Data
• Right of erasure
  To request the deletion or removal of your data
• Right to restrict processing
  To supress the processing of your data

Further to your right to access, please contact us either by telephone, email or letter and specify the Personal Data you wish to access including any account or reference numbers where applicable. As detailed above, you have the right to require us to correct any inaccuracies in your data. If you wish to exercise this right, you should:

• Either speak to us via telephone or put your request in writing;
• Provide us with 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 compliance@leasingoptions.co.uk 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.

Please note, there may be some restrictions and limitations as to the extent of the rights you may have depending on the circumstances of the processing of your data.

What automated decisions are made about me?

Google Analytics Advertising

We use Google Analytics Advertising Features (‘GAAF’) through our website, which means that certain information about the traffic on our website is collected. In light of using GAAF, We will not facilitate the merging of personally-identifiable information with non-personally identifiable information collected through GAAF unless we receive your express consent to that merger.

Furthermore, we are hereby notifying you that:

• The specific GAAF feature(s) which we have implemented are:
  
  • Remarketing with Google Analytics
  • Google Display Network Impression Reporting
  • Google Analytics Demographics and Interest Reporting
• We use first-party cookies (such as GAAF cookies) or other first-party identifiers, and third-party cookies (such as advertising cookies) or other third-party identifiers together and that this is done in the ways detailed under the sub-heading ‘Use of First & Third Party Cookies and Identifiers’ below; and
• You can opt-out of the GAAF you use, including through Ads Settings, Ad Settings for mobile apps, or any other available means such as the Google Analytics currently available opt-outs accessible via https://tools.google.com/dlpage/gaoptout/

International Transfers

In the normal course of business there may be a need for Icon Automotive Group Limited 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.

Icon Automotive Group 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.

Who can I complain to if I am unhappy about the use of my Personal Data?

We would like to reassure you that we take our obligations relating to your Personal Data very seriously. However, we understand that you may have concerns or questions from time to time.

Please see our Complaints Procedure here for details as to who to contact if you are unhappy and how we endeavour to resolve your concerns.

You can also refer your concerns to the Information Commissioner’s Office (ICO) by:

• Phone on 0303 123 1113
• Writing to ICO, Wycliffe House, Water Lane, Wilmslow, SK9 5AF
• Visiting their website at www.ico.org.uk

Please note, we may monitor and record communications with you (such as telephone conversations and emails) for the purpose of quality assurance, training, fraud prevention, compliance or charity.

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.