Privacy Notice

June 2020

KINTO UK Limited (“we”) are committed to protecting and respecting your privacy.  On this page we describe how we may make use of any personal data that you may supply us when you visit this website and any KINTO UK mobile application.  Please read the following to carefully understand our views and practices regarding your personal data and how we will treat it.

KINTO UK Limited, respects your privacy. Whether you deal with KINTO UK Limited as a customer, an employee of one of our customers, a consumer, a member of the general public, a partner, supplier or staff member, you are entitled to the protection of your Personal Data.

KINTO UK Limited is owned by Toyota Fleet Mobility GmbH. Toyota Fleet Mobility was created in 2018 as a joint venture between Toyota Financial Services Corporation and Toyota Motor Europe to develop full service leasing products for customers in Europe and to progress towards becoming a mobility services provider.

KINTO UK offers a complete portfolio of fleet management and funding solutions for passenger and commercial vehicles across corporate, public, not-for-profit and SME sectors. We also offer contract hire services for individual consumers.  Where we provide financial products for new and used vehicles (for KINTO One from 15th June 2020 and for all other contract hire leases signed after 1st January 2020), credit underwriting services, and some administration services, are provided by Toyota Financial Services (UK) Plc on our behalf.

In the capacity of an insurance mediator we offer various types of insurance when providing our salary sacrifice products to business customers.

In this Privacy Notice (“Notice”) we describe how we collect, process, share and protect your data. We also describe why we process your personal data and the associated choices and rights you have with regards to your personal data.

This Policy applies to all the processing of your Personal Data across the services we deliver at KINTO UK Limited and all of the different platforms we use to deliver those services such as online applications, websites, portals, sales and marketing activity and social media platforms.  Data captured and processed if you visit a Toyota dealership (in relation to our KINTO One product) is managed separately, which is further described below.

We’ve taken a layered approach to inform you how we deal with your data, as we recognise it can all be a little confusing at times. Therefore, this Notice is separated into sections which provide you with more specific and concise information on that particular area. You may also receive a short version of a privacy notice when you provide us with information as a result of a specific transaction.

Capitalised terms refer to standard terms set out in within the General Data Protection Regulation (GDPR).

Who is responsible for the processing of your personal data?

KINTO UK Limited of Building 1000, Lakeside North Harbour, Western Road, Portsmouth, Hampshire, PO6 3EN

is a Data Controller and responsible for the processing of your data.

However, please note that we also process your data as a Data Processor, dependant on your relationship with us, on behalf of different Data Controllers, such as your employer (if you are a driver), other companies within the Toyota Group who are separate legal entities, the DVLA, authorities who process fines or take enforcement action, short rental companies (if you hire a vehicle on a temporary basis) and insurance companies.  These organisations will have their own processes and procedures for handling your data and will provide you with a copy of their privacy notice.

Below is a brief summary of when we are responsible for processing your Personal Data as Data Controllers:

  • When we provide for finance for a vehicle
  • When we provide risk management and driver license checking services
  • When we obtain your feedback about our products and services for continuous improvement and reporting

Who can you contact in case you have questions or requests?

KINTO UK Limited has appointed a Data Protection Officer (DPO) who is available to handle any questions or queries you may have relating to the processing of your data and our Privacy Notices.

The DPO can be contacted at DPO@kinto-uk.com or alternatively by writing to the Data Protection Officer, KINTO UK Limited,

Building 1000, Lakeside North Harbour, Western Road, Portsmouth, Hampshire, PO6 3EN

We may process, collect, use and store personal data, either from you directly or about you, in a variety of ways, depending on what services we interact with you for. We will only collect and use personal data that is relevant to the service or product that we are providing.

The types of personal information we collect and process are:

Identity and contact data: includes first name, maiden name, last name, title, residential address and status, billing address, delivery address, email address and telephone numbers, driving licence, passport, photographs.
Personal details: age, gender, marital status and date of birth.
Housing characteristics: address of housing, housing type, own house or leased, length of stay at this address, rent, charges, classification of housing, valuation details, names of key holders.

Employment data: employment details including employment status, job title, duration, employment address, telephone number, previous employer details, employee number.
Vehicle data: vehicle details including make, model, colour, maintenance and repair history, vehicle registration number, chassis number and insurance information.
Nationality: nationality or citizenship, length and / or right of residency.
Financial data: bank account and payment card details, sort code and bank statements, billing and invoice information, payment methods, tax and P11D details, BiK information.
Financial status: details of salary and other income, savings, money you owe, publicly available and shared credit history including County Court Judgments.
Transaction data: including information about payments to and from you and other details of products and services you have purchased from us.
Technical data: includes device identifiers such as internet protocol (IP) address, username or similar identifier, login data, browser type and version.
Other relevant people: joint product holders, beneficiaries of the product, guarantors and people acting as indemnifiers, other people who benefit from the product or service, emergency contact information/next of kin, additional drivers.
Contact with us: information and records created as a result of your contact with us such as telephone conversations, CCTV footage, postal mail, online contact, contact via app, and including information about how you use our website and apps and contact methods available for our other products and services, contact profiles such as your user name and passwords, purchases and orders made, your interests, preferences, feedback and survey responses.
Our and our partners’ products and services: information and details about your inquiry, application, purchase and use of our products and services or those of our business partners.
Marketing, communication: including information about your preferences to receive specific types of communication including marketing communication from us and any other of your communication preferences, use of media and means of communication, incl. Facebook account, Twitter account, LinkedIn account, Instagram.
Data obtained from third parties: money you owe, publicly available and shared credit history including County Court Judgments, information to check identity, current and historic financial situation including borrowings, loans and outstanding finance, information obtained from Credit Reference Agencies and Fraud Prevention Agencies.
Fraud and crime data: information about fraud or theft and related methods and media, criminal records, driving- related offences and convictions, allegations or advice of criminal activity.
Health: where relevant information about your health, for example if you are a vulnerable customer or you have medical restrictions on your driving licence.

Special categories of personal data
Special Categories of Personal Data include details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about health and genetic and biometric data.  We will process Special Categories of Personal Data only where relevant and if necessary and as we may be permitted under law, in particular in the following circumstances:

  • With your written consent.
  • Where we need to carry out our legal obligations.
  • Where it is needed in the public interest, or if you are a vulnerable customer, or for equal opportunities monitoring and in line with this Privacy Notice.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

Criminal convictions and investigation
We will only collect information about criminal and fraudulent investigation and convictions where it is relevant and appropriate to enter into a contract for a product or service or to perform any contract entered into.
We or fraud prevention agencies may enable law enforcement agencies to access and use your personal information including information about criminal activity to detect, investigate and prevent crime.

From other third parties.

As we are often the registered keepers of your company vehicle (where applicable), we may be provided with information about you from external third parties, such as the DVLA, government enforcement agencies and insurance companies.

Enforcement information: speeding, parking and other driving offence notifications are sent to us as the registered keepers of the vehicles. These notifications may contain information about you, including your company vehicle registration and details of the offence itself.

Driving incident information: if you are involved in an incident in your company vehicle (where applicable), we may be provided with information about you, and the incident itself, by insurance companies. This could be from both your employer’s insurance company, and any involved third party’s insurance company.

When you apply to work with us

If you apply for a job with us, your information will be shared with Toyota Financial Services (UK) PLC (TFS-UK). TFS-UK provide us with shared HR services, therefore it is necessary for them to process your data to facilitate job applications. We remain the Data Controller of this data and TFS-UK are appointed by us to provide these services as a Data Processor.

There may be third parties involved in the application process, such as recruitment agencies or job recruitment websites. They will have their own Privacy Notices and we advise you to visit their websites to check how they will use your personal data too.  When a candidate applies for a role with KINTO UK Limited and they are successful, we have a specific Privacy Notice for employees, which we will provide you with when you join us.

Keeping your personal data accurate and up-to-date

It is important for us to maintain accurate and up-to-date records of your Personal Data. Please inform us of any changes to or errors in your Personal Data as soon as possible by contacting us at the Data Protection Contact Point (see section 3 “Who can you contact in case you have questions or requests?”). We will take reasonable steps to make sure that any inaccurate or outdated Personal Data is deleted or adjusted accordingly.

We collect personal information about you in the following situations:

  • From you when we are in direct contact with you and from other relevant people such as a person who is a joint product holder or a person who provides indemnity, guarantees or who benefits from the product or service that we provide.
  • From your employer when we are required to provide services to you on their behalf
  • When you contact us or inquire about, apply for or take a product or service of ours.
  • When you create an account with us.
  • When you subscribe to a service or publication of ours.
  • When you request marketing or other communications to be sent to you.
  • When you apply to work for us.
  • From a service provider, interested party or intermediary who facilitates the provision or delivery of our product or service.
  • From a franchised vehicle dealership network or from other relevant companies
  • From the Toyota group of companies if you receive a product or service from them, currently or in the past, or if they provide financial, IT, HR or administration services on our behalf.
  • From other sources that are relevant to our products or services including Credit Reference Agencies, HM Revenue & Customs, law enforcement and detection agencies including the Police service, parking enforcement authorities, Congestion, DART charge and other toll or road charges providers, Fraud Prevention Agencies, debt recovery agents and publicly available resources such as those that are available on the internet

We will only use and process your personal data when the law allows us to. Most commonly we will use your personal information on the grounds of the following legal basis:

Your consent

Where you have provided your consent, we may use and process your information to contact you from time to time about our products, services, offers and events that we think might be of interest to you. We will send these communications by email, phone, SMS or post.

For the avoidance of doubt, you will always have the right to withdraw your consent at any time by contacting us at DPO@kinto-uk.com or, in relation to any marketing messages you receive, by using the unsubscribe option included in those messages.

Contractual performance

Where you have agreed a contract directly with us to provide you with services (such as KINTO One, LeaseMyCar, or if you are purchasing your company vehicle at the end of the lease), we will process your personal data in order to perform our obligations under the contract. We also process your personal data in order to fulfil our obligations to your employer where we are contractually providing them with services which you are impacted by. This may include:

  • To assess, process, manage and administer your inquiry or application for a product or service;
  • To register you as a new customer or user of our product or service and to register other relevant people such as indemnifiers, guarantors and beneficiaries;
  • For assessing your creditworthiness, credit score and whether the finance product is suitable and affordable for you;
  • To enter into, perform, manage, administer and enforce any product or service including any related contract;
  • To share your personal data with our service providers and partners, other Toyota group companies and (in relation to KINTO One) the Toyota and Lexus franchised vehicle dealership network during the application process or during any contract for any product or service;
  • To manage your account and assist you about any matters when you contact us;
  • To manage payments of fees and charges;
  • To notify you about changes to all applicable terms of supply or use, and our privacy policy or specific privacy notices;
  • To update your records and details and to locate and contact you about matters concerning your product or service;

Legitimate Interests

We may use and process your personal data, as set out below, where it is necessary for us to carry out activities for which it is in our legitimate interests as a business to do so. We will always ensure this legitimate interest is not outweighed by your privacy rights and that the use of your personal data is duly communicated to you in the privacy notice related to that processing.

Processing necessary for us to support customers with sales, products, services and other enquiries

  • To respond to correspondence you send to us and to fulfil the requests you make to us (for example: service requests, brochure requests or information about specific products);
  • To provide service, maintenance and warranty information and reminders, unless you object;
  • To undertake market analysis and research (including contacting you with customer surveys) so that we can better understand you as a customer and provide tailored offers, products and services. We will only send marketing communications to you if you have provided your consent for us to do so or (if you are an employee of one of our customers) where your employer has instructed us do so.
  • For product development purposes (for example to identify new service offerings and improvements to existing services);
  • To advise you of any issues regarding your vehicle (such as manufacturer safety issues) or to remind you of when it is due for a service;
  • To analyse and improve our website, portals, services and products and enhance and develop the customer experience;
  • To provide you with details of your employer’s company vehicle schemes and how to access our websites and driver portals;
  • To comply with your employer’s instructions regarding vehicle services even if you do not drive a vehicle that has been leased by us (such as recording mileage information);
  • To advise you of vehicle lease renewal;
  • To assist you with making an application for finance and securing funding on your behalf, which shall include introducing you to financial services organisations, such as companies and banks which provide funding for leases;
  • To administer fines, penalties, endorsements and other driving offences.

Processing necessary for us to promote our business, brands and products and measure the reach and effectiveness or our campaigns

  • To contact you from time to time with marketing information (unless you object) if you have expressly indicated to us that you are acting on behalf of a business or where we have obtained business contact details from the wider Toyota group;
  • To identify and record when you have received, opened or engaged with our website or electronic communications (please see our Cookie Policy for more information).

Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively

  • To verify the accuracy of information that we hold about you and create a better understanding of you as a customer;
  • To comply with a request from you in connection with the exercise of your rights (for example, where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);
  • For network and information security purposes i.e. in order for us to take steps to protect your information against loss, damage, theft or unauthorised access;
  • To inform you of updates to our services, terms and conditions, privacy notices and relevant policies.

Processing necessary for us to recruit job candidates

To process job applications, obtain references and conduct background checks and screening when a candidate applies for a vacancy.

Automated Decision Making (for personal finance agreements)

The decision to accept your application for a finance product may be conducted by automated means without human intervention. If your application is not accepted in this way it will be referred for analysis and assessment by a person in our relevant application assessment team.

Any other decisions that are made about you using an electronic system that uses personal information to make a decision without human intervention will be made if it is necessary for entering into or performing a contract or if we are allowed to by law, or if you give your explicit consent to us.

Our Legal Obligations

We may need to process your personal data in order to:

  • Comply with the law, requests from authorities, court orders, legal procedures and obligations related to the reporting and filing of information with authorities;
  • Verify or enforce compliance with KINTO UK Limited’s policies and agreements;
  • Protect the rights, property or safety of KINTO UK Limited and/or its customers;
  • In connection with corporate transactions: in the context of a transfer or divestiture of all or a portion of its business, or otherwise in connection with a merger, consolidation, change in control, reorganisation or liquidation of all or part of KINTO UK Limited’s business.

To protect the vital interests of you or another person

Sometimes we will need to process your personal data to contact you if there is an urgent safety or product recall notice and we need to tell you about it.

We retain your personal information for as long as we consider is necessary for the purposes for which we are processing it.

In retaining your personal data we consider:

  • The duration of the purposes that we collected it for, importantly the duration that we are obliged to provide the relevant product or service;
  • Fulfilling, managing and concluding our relationship with you;
  • The time periods within which we have rights to claim against and pursue you and the time periods within which you have the right to claim against and pursue us.

We also retain personal data for the purposes of satisfying any legal, regulatory, accounting or reporting requirements and guidance. Typically this is a period of six years after you cease to have a contract or relationship with us.

We may irreversibly anonymise your personal data so that it can no longer be associated with you, in which case we may use this anonymous information indefinitely without further notice to you.

Protecting your personal data
We have implemented a set of technical and organisational security measures to protect your personal data against unlawful or unauthorised access, use of modification, in addition to protection against accidental loss or damage.
We have held an UKAS accredited ISO 27001:2013 certificate for a number of years. ISO 27001 is a set of global standards that focuses on information security best practice.
If we share personal information with third parties, we require that they take appropriate security measures to protect your personal information. We do not allow third party service providers to use your personal information for their own irrelevant purposes, they are only allowed to use and process your personal information for specified purposes and in accordance with our instructions.
Appropriate security means ensuring controls are in place to protect the confidentiality, integrity and availability of your personal data:

  • Confidentiality: we will protect your personal data from unlawful disclosure to third parties;
  • Integrity: we will protect your personal data from being modified by unauthorised third parties;
  • Availability: we will ensure that authorised parties are able to access your personal data when needed.

We also hold a Cyber Essentials Plus certificate, the UK Governments approved standard for cyber security configuration.

We use cookies on our websites. This helps us to provide you with a better experience when you browse our website and also allows us to make improvements to our site.

We have put together specific information on how we process cookies in a policy document for you, which is available here.

We may have to share your personal data with the other parties set out below for the uses, purposes and situations described in this Notice, where we are required to under law, to enter into, manage and administer any contract with you (or your employer where applicable), and in particular for the uses and purposes described in the “Why we process personal data” section above.

 

Who we may share your personal data with

 

Within our organisations and within the brand environment:

  • Our authorised employees and contractors;
  • Relevant Toyota group companies;
  • Members of our authorised retailers and authorised repairers network which you have indicated as preferred or which are located near you or which you have been in contact with.

 

Third party business partners:

  • Research, advertising, marketing and promotional agencies;
  • Our service providers who fulfil or support our products and services systems (including IT systems) and processes, or who analyse and improve our products and services and related systems and processes, these include:
    • Roadside assistance providers;
    • Accident management service providers;
    • Service, maintenance and repair providers;
    • Vehicle movements, disposals and re-marketing;
    • Risk management, driver training and licence checking providers;
    • Relief and hire vehicle providers;
    • Tyre & glass providers;
    • Building facilities and security providers;
  • Providers of IT related services;
  • Our professional advisers;
  • Financial institutions or other leasing companies who provide funding or other financial services to us for the purpose of fulfilling our obligations to you;
  • Insurance companies we may introduce or who may provide insurance if you decide to have insurance with them.

 

Other third parties:

  • Official bodies and regulators including the Financial Conduct Authority (FCA), HM Revenue & Customs (HMR&C), the Information Commissioner’s Office (ICO) and the DVLA / DVA in Northern Ireland;
  • Law enforcement and detection agencies including the Police service;
  • Credit reference and fraud prevention agencies, please see the ‘Credit reference and fraud prevention agencies’ section below.

 

Please be aware that third party recipients – especially service providers who may offer products and services to you through in-vehicle services, applications or via their own channels – may separately collect Personal Data from you. In such case, these third parties are solely responsible for the control of such Personal Data and your dealings with them will fall under their terms and conditions.

Credit reference agencies and the Credit Reference Agency Information Notice
In order to process applications for our products or services, we will perform credit and identity checks about you with one or more Credit Reference Agencies (‘CRA’). These CRAs are Equifax and Experian.

To do this, we will supply your personal information to CRAs and they will give us information about you. This will include information from your credit application and about your financial situation and financial history. CRAs will supply to us both public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information.

We may continue to exchange information about you with CRAs while you have a relationship with us. We may also inform the CRAs about your settled accounts. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt. This information may be supplied to other organisations by CRAs.

When CRAs receive a search request from us they will place a search footprint on your credit file that may be seen by other lenders.

If you are making a joint application, or tell us that you have a spouse or financial associate, we will link your records together, so you should make sure you discuss this with them, and share with them this information, before lodging the application. CRAs will also link your records together and these links will remain on your and their files until such time as you or your partner successfully files for a disassociation with the CRAs to break that link.

If we share your personal information with a CRA your personal information will be used and processed by the CRA in accordance with the provisions of the CRA’s Credit Reference Agency Information Notice (referred to as the ‘CRAIN’).

The identities of the CRAs, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRAs are explained in more detail in their respective CRAINs.
The CRAINs are accessible from each of the CRAs on their websites. Their websites and CRAINs are located at the following web addresses:

Equifax: www.equifax.co.uk
Equifax CRAIN: www.equifax.co.uk/crain.html

Experian: www.experian.co.uk
Experian CRAIN: www.experian.co.uk/crain/

Fraud prevention agencies
Cifas is the data controller of the Cifas National Fraud Database.
Personal information that we collect from you may be shared with Cifas and fraud prevention agencies who will use it to prevent fraud and money laundering and to verify your identity. If fraud or a money laundering risk is detected, you could be refused certain services, finance or employment.

Further details of how your information will be used by Cifas and these fraud prevention agencies, and your data protection rights, can be found on the Cifas website located at: www.cifas.org.uk/

We do not routinely transfer your personal data outside of the European Economic Area (“EEA”) and we select suppliers who provider assurances that personal data is stored and processed within the EEA.

However, as we are part of the wider Toyota group, your Personal Data may be stored and processed by other Toyota companies or third-party service providers in multiple countries, including countries other than your country of residence. Your Personal Data may, for example, be transferred to the United Kingdom, Japan and/or the United States.

Your Personal Data will only be transferred to countries located outside of the European Economic Area (“EEA”), where there are appropriate safeguards in place such as the EU-US Privacy Shield framework and the Standard Contractual Clauses adopted by the European Commission.

We want to be as transparent as possible with you, so that you can make meaningful choices about how you want us to use your Personal Data. To exercise your Rights under Data Protection Law, please use the DPO Contact Details.

Your choices on how you want to be contacted and withdrawing consent

You can make a variety of choices about how you want to be contacted by us, through which channel (for example, email, mail, SMS, phone), for which purpose and how frequently. This can be done by adjusting the privacy setting on the relevant device, updating your user or account profile or by following the unsubscribe instructions included in the communication.

Your Personal Data and Right to Access

You have the right to know whether or not we are processing your personal data, to access that information and additionally specified information regarding how we process your information.

Your Right to Rectification

If you find any mistakes in your personal data, you find it incomplete or incorrect, you may also ask us to correct or amend it. This can be done by providing details of your request to us, using the contact details provided.

Restriction of Processing

You have the right to ask us to restrict the Processing of your personal data. This may be whilst we check the accuracy of the information we hold on you. This can be done by providing details of your request to us, using the contact details provided.

Right to Object to Processing

You may also object to the use of your personal data for direct marketing purposes or, if you prefer, you can tell us through which channel and how frequently you prefer us to contact you. You may also object to us sharing your personal data with a third party for the same purpose. Opting Out – If we are using your consent to process your data, you may withdraw that consent at any time. You may withdraw your consent by unsubscribing to an email, changing your preferences in your account, visiting our Opt-Out form or using the contact details provided.

Your Right to Erasure

You may want us to delete your personal data. If you do, please provide details of your request to us, using the contact details provided. We will assess your request and if we are able to erase your data we will inform you of the outcome.

Your Right to Data Portability

You have the right to request that data you have provided is sent to you in a structured, commonly used and machine-readable format and have the right to transmit that data to another organisation. This can be done by providing details of your request to us, using the contact details provided.

No fee usually required
You will not have to pay a fee to access your personal information or to exercise any of your other rights. We may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

Making a complaint

If you wish to make a complaint, please contact our Data Protection Officer. If you are unhappy with the response from the Data Protection Officer then you have the right to lodge a complaint with the Information Commissioners Officer (ICO) whose contact details are: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. Email: casework@ico.org.uk  Live Chat: https://ico.org.uk/global/contact-us/live-chat

We may occasionally make alterations to this policy, which will reflect how we process and look after your data. This is to ensure our commitment to being transparent with you, protecting your information and upholding your rights. If significant changes are made to this Policy or the way in which we process your personal data, we will draw your attention to this either through updates to this Policy on our website, through our service lines or by another means of communication, such as email.