E-Pace Car Leasing & Contract Hire

Nationwide Vehicle Contracts – Data Privacy Notice

The following data privacy notice explains the circumstances in which Nationwide Vehicle Contracts will collect personal data from you, why it is being collected, how we will use it and to whom we might disclose it to if necessary.

The data controller

Nationwide Vehicle Contracts is committed to complying with the UK’s Data Protection law and the UK General Data Protection Regulation (GDPR) for the protection of personal data, as well as the principles of data security in the configuration of our services. If you have any questions about this privacy notice or how we use your personal data, please contact our Data Protection Officer Keith Hawes:

In Writing:
Nationwide Vehicle Contracts Limited
Unit 9, Christie Way,
Christie Fields,
Manchester,
M21 7QY

By Phone: 0345 811 9595
By Email: [email protected]

What data is being collected and processed? 

In order to enter into a brokerage agreement with Nationwide Vehicle Contracts, we will collect, store and use elements of your personal data. The processing of this personal data is a contractual requirement and is necessary by Nationwide Vehicle Contracts in order to administer your account and to provide the products and services you have requested from us.

When you approach Nationwide Vehicle Contracts to engage in our brokerage services, we will ask your consent to collect and process your personal data. Failure to provide this consent and/or personal data may mean we will be unable to execute the contract and will result in termination of our services.

When engaging Nationwide Vehicle Contracts brokerage services, you will usually need to disclose to us the following:

• title
• first name(s), surname or company name (including representation as the case may be)
• address (street, street number, postal code, city and country/region)
• email address
• date of birth
• telephone and mobile number
• employment details (employer name, employer address, employment history)
• monthly income and expenditure
• bank details (account number, account holder and card number)
• VAT ID number (as the case may be)

We will also monitor, record, store and use any telephone, email or other electronic communications with you for training purposes so that we can check any instructions given to us and to improve the quality of our customer service.

As part of our commitment to enhance our service delivery and improve customer experience, we may employ predictive and generative AI technologies to process data. These are used for the following purposes:

1. Predictive AI: Utilises data to analyse leasing behaviours, preferences, and feedback, enabling us to anticipate your needs and make personalised vehicle leasing renewal recommendations.
2. Generative AI: Analyses anonymised patterns in customer service interactions to refine and enhance the effectiveness of our communication and customer support strategies.

When engaging with our services, we ask for your consent to collect and process your personal data, including for use in anonymised form within our AI systems. This data is used in a way that cannot identify you (anonymised) within our AI systems. All AI-involved data processing adheres strictly to the UK Data Protection Law and GDPR guidelines, ensuring your privacy and data protection rights are upheld.

If you do not want us to use your data in our AI systems, you can opt-out at any time by contacting our Data Protection Officer. This ensures that you have control over how your information is processed.

Any personal data we collect from you will not be transferred outside the European Economic Area without your explicit consent.

Website Cookies

When you access our website, temporary data about your visit is stored and processed in a protocol file for a certain period of time via the use of cookies. This information is anonymised and is used by us to better understand the use of our site, including the number of visitors we have, the pages viewed per session and time exposed to particular pages. This in turn helps us to provide you with a better experience, since we can evaluate the level of interest in the content of our website and tailor it accordingly.

The following data is collected and stored by Nationwide Vehicle Contracts until its automated deletion:

• IP address and location of the accessing computer/device
• Date, time and duration of your visit
• Name and URL of the accessed pages
• Identification data of the browser and operating system used
• Website from which the data was accessed
• Name of your internet access provider

The data listed above is only analysed for statistical purposes and for improving our internet presence, then it is deleted. We will not attempt to personally identify you from your IP address unless required to as a matter of law or regulation or in order to protect our, or our other customers’ rights.

The nature and content of the information collected via cookies differs, as does the period for which this information is retained. In line with our data protection obligations, we will ensure that this retention period is not excessive, and that the data is only retained for as long as is necessary for the purpose for which it was collected. 

If you wish to know more, or if you wish to identify the exact retention periods, please contact our Data Protection Officer:
 
In Writing:
Nationwide Vehicle Contracts Limited
Unit 9, Christie Way,
Christie Fields,
Manchester,
M21 7QY
 
By Phone: 0345 811 9595
By Email: [email protected]

Google Analytics

This website uses Google Analytics, a web analysis service provided by Google Inc, (hereafter referred to as “Google”). Google Analytics uses "cookies", or text files stored on your computer that permit analysis of your use of the website. Google will use this information on behalf of the operator of this website to evaluate your use of the website, compile reports about website activity and provide other services to the website operator related to the use of the website and internet usage.

We also use the technical extension "Google Signals", which enables cross-device tracking. This makes it possible to assign an individual website visitor to different end devices. However, this only happens if the visitor has logged in to a Google service when visiting a website and has activated the option "personalized advertising" in his Google account settings at the same time. Even then, however, no personal data or user profiles are accessible to us; they remain anonymous to us.

If you do not want "Google Signals" to be used, you can disable the "Personalized advertising" option in your Google Account preferences. Should you wish to opt out of Google Analytic tracking across all websites please visit: http://tools.google.com/dlpage/gaoptout.  You can also prevent the collection of data generated by the cookie related to your use of the website (including your IP address) by Google, as well as the processing of this data by Google, by downloading and installing the browser plugin available through the following link: Browser add-on for disabling Google Analytics. Please note, you may find that some parts of the site will not function properly if you refuse cookies.

Google Remarketing

From time to time, Nationwide Vehicle Contracts may use remarketing, re-engagement or similar audiences via Google Ads. Both first- and third-party data can be used for these purposes, such as, but not limited to, information shared with Nationwide Vehicle Contracts in forms and browser-based cookies, respectively. This is largely on Google Search through the use of Remarketing Lists for Search Ads (RLSA) but could also include the Google Display Network where tailored adverts are shown to previous customers or site users as they browse other websites. All data collected and shared remains anonymous and is processed by Google, as per their data policy. 

Should you wish to, you can opt out of ad personalisation using Google’s Ad Settings. Further information on ad personalisation can be found here and information on controlling your device’s ad settings can be found here.

Microsoft Clarity

We have installed a Microsoft Clarity cookie on our site. Clarity captures the interactions on our website such as how the page has rendered and what interactions users undertake such as mouse movements, clicks, scrolls, etc. By default, any sensitive content such as passwords, usernames, etc. are masked before sending to Clarity. Clarity is GDPR complaint as a data controller.

Please read Microsoft's Clarity privacy policy for more information. 

Facebook Advertising

From time to time, Nationwide Vehicle Contracts may use Facebook Advertising, Facebook Custom Audience and Facebook Pixel Re-Marketing to display interest-based ads to you. This tool allows Nationwide Vehicle Contracts to understand and deliver ads that are more relevant to you, as well as monitor the effectiveness of our Facebook ads for purposes of statistics and market research. The collected data remains anonymous and Nationwide Vehicle Contracts cannot see the personal data of any individual user. However, this data is saved and processed by Facebook and Facebook can connect this data with your Facebook account and use it for its own advertising purposes, in accordance with Facebook’s Data Policy which can be found at https://www.facebook.com/about/privacy/.

You can opt-out of Facebook’s use of cookies and Facebook Pixel Re-Marketing through settings on your Facebook Account. https://www.facebook.com/settings/?tab=ads#_=_

Direct Marketing Communications

If you have chosen to opt-in to our direct marketing communications, we will use your information to tell you about products and services available from us which may be of interest to you. We may also use your information to tell you about products and services which we can introduce from selected businesses.

To help make our emails more interesting and relevant, we often receive a confirmation when you open an email from Nationwide Vehicle Contracts if your computer supports such capabilities.

From time to time, we may participate in Facebook's Custom Audience program which enables us to display personalised ads to persons on our email lists when they visit Facebook.com. This tool allows Nationwide Vehicle Contracts to upload your email address and/or phone number to Facebook to enable Facebook to determine if you are a registered account holder with Facebook in order for us to deliver ads that are more relevant to you.

You have a right to opt-out of our direct marketing communications and/or participation in our Facebook Custom Audience at any time. You can opt-out by following the Unsubscribe instructions at the bottom of the communication or by emailing [email protected]

Links to websites of other providers and third parties

Please note that this data privacy notice only applies to Nationwide Vehicle Contracts. Our service may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third-party's site. We have no control over and assume no responsibility for any information that is submitted to or collected by third parties, such as those where our website may provide links and banner advertisements to third-party sites. 

In some of our content, we may link to relevant and trusted affiliate partners like Confused.com, The AA, Amazon, Protyre etc. If you click on an affiliate link and purchase a product or service from any of these affiliate sites within a set amount of time, Nationwide Vehicle Contracts receives a small commission at no extra cost to you. 

Since we do not control these websites, you are responsible for reviewing and abiding by the privacy policies of these third-party sites to ensure they comply with the applicable data protection regulations. We strongly advise you to review the Privacy Policy of every site you visit.

How long will the data be stored for?

Where possible, Nationwide Vehicle Contracts will take steps to erase any personal data that is no longer necessary for the purposes for which it is collected or otherwise processed, or if you have withdrawn consent for its processing and retention.

As a general rule, if you enter into or took steps to enter into a contract with Nationwide Vehicle Contracts, we will store the data for period of six years for compliance with our general legal obligations and for the exercise or defence of any legal claims.

Under the GDPR, you have the right to ‘block’ or request the deletion or removal of personal data to prevent further processing. This right to erasure is also known as ‘the right to be forgotten’. Specific circumstances in which you can request the deletion or removal of personal data includes:

• Where the personal data is no longer necessary for the purposes for which it is collected or otherwise processed
• Where you withdraw consent
• When you object to the processing and there is no overriding legitimate interest for continuing the processing
• Where the personal data was unlawfully processed (i.e. otherwise in breach of the GDPR)
• Where the personal data has to be erased in order to comply with a legal obligation
• In case a deletion is not possible due to legal, statutory or contractual retention periods, or if it requires disproportionate efforts or prejudices your legitimate interests, the data will be blocked instead of deleted.

Sharing of data with other data controllers

Here at Nationwide Vehicle Contracts we take your privacy seriously and the information we hold about you is confidential. We will only disclose it outside Nationwide Vehicle Contracts when:

• you have given us your consent to do so
• it is necessary for the performance of an agreement of which you will be made aware
• in order to obtain professional advice (e.g. legal advice)
• we or others need to investigate or prevent crime (e.g. to fraud prevention agencies)
• the law permits or requires it
• regulatory or governmental body requests or requires it, even without your consent, or
• there is a duty to the public to reveal the information

In order to administer your contract, we may need to share some of your personal information with other data controllers. This processing is necessary for the purposes of delivering specific services to you. You agree that we can share or use your personal data with any of our appointed agents or suppliers to allow us to provide you services and products you have asked us to provide you under this agreement, such as to facilitate delivery of your vehicle, to collect the vehicle from you or notify you of a vehicle safety recall. Other data controllers which we may share this information with may include:

• Credit reference agencies (to propose you for vehicle finance)
• The finance provider (to generate the finance agreement)
• The supplying dealer group or vehicle logistics partner (to order and deliver the vehicle)
• Electricity and energy suppliers (to supply you with home EV charging units if requested)
• Car or van hire providers (to supply you with a hire vehicle for agreements of up to 90 days)
• Claims handling and fraud prevention agencies (to investigate or prevent crime)
• Vehicle management companies (to administer maintenance and service plan agreements, if taken)
• Insurance companies (to administer insurance agreements such as GAP insurance, warranty and assist)

To enhance our services through advanced AI technologies, we may share your anonymised data with trusted third-party AI service providers. These partnerships are carefully managed under strict data protection agreements to ensure your data remains secure and confidential. If you have any concerns or require more information about these AI partnerships, please contact our Data Protection Officer.

Credit reference agencies

In considering your application, we will search your record at credit reference agencies. They will add to your record details of our search and your application and this will be seen by other organisations that make similar searches. If, after acceptance, a new credit proposal is required because your approval has expired, there was an error on your original application, the finance provider asks for it, or you wish to apply for finance with a new provider, another credit search may be made on your behalf.

Information held about you by the credit reference agencies may already be linked to records relating to other people with whom you have a financial association. In connection with your application you may be treated as financially linked with them and assessed with reference to any such associated records. Searches may also be made in respect of directors and partners of firms applying for credit.

If you are a joint applicant or if you have told us of some other financial association with another person, or a director of a firm which is applying for a facility you are declaring that you are entitled to:

• disclose information about your joint applicant, fellow directors and anyone else referred to by you
• authorise us to search, link or record information at credit reference agencies about you and anyone else referred to by you

The credit reference agency will use a credit scoring system when assessing your application. They will also add to your record details of your agreement with us, specifically the payments you make under it, any default or failure to keep to its terms and any change of address you fail to tell us about where a repayment is overdue. 

These records will be shared with other organisations and will be used by us and them to help make decisions about credit and credit related services such as insurance for you and members of your household, trace debtors, recover debt and to manage your accounts. We and the credit reference agencies will also use the records for statistical analysis about credit.

You have a legal right to know the details of credit reference and fraud prevention agencies we use and to whom we pass information about you. To obtain this information, please contact our Data Protection Officer on 0345 811 9595.

Fraud Prevention

If you give us false or inaccurate information and fraud (in any form) is identified, details will be passed to the fraud prevention agencies. We and other organisations may also share, access and use this information to prevent fraud and money laundering, for example when:

• checking details on applications for credit and credit related or other facilities
• managing credit and credit related accounts or facilities
• recovering debt
• checking details on proposals and claims for all types of insurance
• checking details of job applicants and employees

In addition, law enforcement agencies may access and use this information.

Protecting your privacy

In order to protect the personal data collected from you by Nationwide Vehicle Contracts against accidental or deliberate manipulation, loss, destruction or the access of unauthorised persons, technical and organisational security measures are constantly improved as part of our technological development. In addition, our employees, subcontractors and other support staff are obligated to observe confidentiality and data privacy.

Any access to your data that is stored at our company only takes place through an encrypted connection. By using the most up-to-date firewall systems, we provide the best possible protection for your data. Our website, as well as our internal Customer Management System (CMS) is encrypted using a SSL/TSL (Secure Sockets Layer/ Transport Layer Security) connection. SSL is an industry standard and is used by millions of websites in the protection of their online transactions with their customers.

Wherever possible, we have tried to create a secure and reliable website for our users. However, you recognise that your use of the Internet and our website is entirely at your own risk and we have no responsibility or liability for the security of personal information transmitted via the Internet.

All passwords and usernames allocated to you must be kept secret and must not be disclosed to anyone without our prior written authorisation. You must not use any false identity in email or other network communications and you must not attempt or participate in the unauthorised entry or viewing of another user’s account or into another system.

You must not use the services and/or network systems or any part thereof for fraudulent activities, or to breach another organisation’s security (cross-network hacking). This is an illegal act and prosecution under criminal law may result. You must not use any computers, computer equipment, network resources or any services provided by us for any illegal purpose, or for accessing, receiving or transmitting any material deemed illegal, indecent, offensive or otherwise unacceptable under UK law.

We will monitor network traffic from time to time for the purposes of backup and problem solving and in order to ensure that you are not misusing any of the services provided to you.

Breaches

If at any time we become aware that your data has been compromised, or that a breach of our systems and controls has occurred, which has an impact on the security of your data, we will notify the Information Commissioner’s Office, and you, without undue delay.

Subject Access Requests

You have the right to request access to a copy of the personal information that we hold about you. This is also known as a ‘Subject Access Request’. This information is provided to you free of charge however, we can refuse to respond or charge a ‘reasonable fee’ of £10 inc. VAT when a request is manifestly unfounded, excessive or repetitive.

We will provide this information in a structured, commonly used and machine readable form such as a CSV file. This allows you to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without hindrance to usability. Where possible, we will provide this information via remote access to a secure self-service system, such as our Customer Account area, which would provide you with direct access to your information.

If you would like to submit a Subject Access Request, please contact our Data Protection Officer in writing or by telephone to:

Data Protection Officer
Nationwide Vehicle Contracts Limited
Unit 9, Christie Way
Christie Fields, Manchester, M21 7QY

Telephone: 0345 811 9595

Email: [email protected]

We will response to your request without delay and at the latest, within one month of receipt of your request.

Rectifying or updating personal data

If you believe the personal data we hold about you is inaccurate or incomplete, you have the right to rectification. Where possible, we will also inform any third parties to whom we have disclosed the personal data in question to so they can rectify their records.

We will typically respond to your request within one month, although this can be extended by two months if your request for rectification is complex, such as a Novation or Transfer of Lease.

Withdrawing Consent

You have the right to withdraw your consent for us to collect, process and store your data at any time. If you wish to withdraw your consent, please confirm this in writing to our Data Protection Officer:

By Post:
Nationwide Vehicle Contracts Limited
Unit 9, Christie Way,
Christie Fields,
Manchester,
M21 7QY

By Email: [email protected]

Please note, by withdrawing consent, Nationwide Vehicle Contracts may be unable to execute the contract that you have entered into with us and will result in termination of our services. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

Right to complain

If you have a complaint about any aspect of data protection or if you feel your privacy has been breached by us, we would like to hear from you. To help us investigate and resolve your concerns as quickly as possible, please contact our Data Protection Officer:

Nationwide Vehicle Contracts Limited
Unit 9, Christie Way,
Christie Fields,
Manchester,
M21 7QY

By Phone: 0345 811 9595
By Email: [email protected]

If you are unhappy with the final response you have received from Nationwide Vehicle Contracts, you have the right to complain to the supervisory authority, the Information Commissioner’s Office (ICO). You can call the ICO on 0303 123 1113 or by visiting their website: https://ico.org.uk/.

Changes to the Privacy Policy

Due to the further development of our website, government regulations or the implementations of new technologies, this policy will be reviewed, and may change, from time to time. Nationwide Vehicle Contracts reserves the right to change this data protection information at any time with effect for the future. The revised policy will be posted to this page so that you are always aware of the information we collect, how we use it and under what circumstances we disclose it. We therefore recommend you read the current data protection information again from time to time.

Last updated: 09 May 2024