Kinto

Personal Data means any information that relates to an identified or identifiable individual. 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 that 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, utility bill and other means of proving address.

Personal details: age, date of birth, 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, V5 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, ‘Benefit in Kind’ 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 explicit 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 collect information about criminal and fraudulent investigations and convictions where it is relevant and appropriate to do so.

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 our leased vehicles, we may be provided with information about you from external third parties, such as the DVLA, government enforcement agencies and insurance companies. We may also be required to provide information about you in relation to incidents or offences that have been committed when your vehicle or your company vehicle was / is in your custody.

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 vehicle registration and details of the offence itself.  We may need to pass on your details to the appropriate authorities when not all information is known to them.

Driving incident information: if you are involved in an incident in your vehicle, 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 / or any involved third party’s insurance company.

Service Providers: Some of our service providers collect your personal data directly from you. The service provider may then pass your personal data to us to enable us to manage your account.

Connected Services: Connected services and / or in-vehicle apps collect your personal data independently from us and do not pass the information gathered to us. The collection and processing of your personal data is subject to separate privacy policies that you will be asked to consent to through the connected service or in-vehicle app.

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 HR services, so 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 a job 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 and they are successful, we have a specific Employee Privacy Notice which we will provide to you 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 using the information under the ‘Contact Us’ heading on our website. We will take reasonable steps to make sure that any inaccurate or outdated Personal Data is deleted or amended 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 enquire 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 when a vehicle is serviced or you make an enquiry
• 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, DVLA, 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.  We will use your personal information in the following ways and on the grounds of the following lawful bases:

Performance of a contract

• Registering you as a new customer or user of our product or service and to register other relevant people such as indemnifiers, guarantors, and beneficiaries
• Assessing your creditworthiness, credit score and whether the finance product is suitable and affordable for you
• Administering fines, penalties, endorsements, and other driving offences on behalf of the authorities and private organisations
• Entering into, performing, managing, administering, and enforcing any product or service, your account, or any related contract(s), enquiries, or applications
• Sharing 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
• Verifying or enforcing compliance with KINTO UK’s policies and agreements, and notifying you about changes to all applicable terms
• Managing payments of fees and charges
• Updating your records and details and locating and contacting you about matters concerning your product or service
• Contacting you if there is an urgent safety or product recall notice and we need to tell you about it

Legitimate interests

• Processing necessary for us to support customers with sales, products, services, complaints, and other enquiries
• Undertaking 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
• For product development purposes (for example, to identify new service offerings and improvements to existing services)
• Analysing and improving our website, portals, services, and products and enhance and develop the customer experience
• Providing you with details of your employer’s company vehicle schemes and how to access our websites and driver portals
• Complying 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)
• Assisting 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
• Contacting 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
• Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively
• Contacting you regarding outstanding debt
• 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)
• Informing you of updates to our services, terms and conditions, privacy notices and relevant policies
• Using automated decision-making for personal finance agreements, although 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

Legal obligation

• To comply with the law, requests from authorities, court orders, legal procedures and obligations related to the reporting and filing of information with authorities
• To administer fines, penalties, endorsements, and other driving offences that are legal requirements (e.g., fixed penalty notices)
• To protect the rights, property, or safety of KINTO UK and/or its customers
• To comply with a request from you in connection with the exercise of your rights
• 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’s business

Consent

• To send some of our direct marketing communications via email, phone, SMS, or post about our products, services, offers, and events that may be of interest to you
• To collect dietary information when you attend a KINTO UK event

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.

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 for which 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;
• The law.

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 (6) 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.

We have implemented a set of technical and organisational security measures to protect your Personal Data against unlawful or unauthorised access, use, or modification, in addition to protection against accidental loss or damage.

We continue to be UKAS accredited to ISO 27001:2013 standard. 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 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

We also hold a Cyber Essentials Plus certificate, the UK Government-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 repairer network which you have indicated as preferred, or which are located near you or which you have been in contact with, or we have put you 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 (HMRC), the Information Commissioner’s Office (ICO) and the DVLA / DVA in Northern Ireland;
• Law enforcement and detection agencies including the Police;
• 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

To process applications for our products or services, we will perform credit and identity checks about you with one or more Credit Reference Agencies (‘CRAs’). The CRAs we currently use include Equifax and Experian.

To do this, we will supply your personal information to the 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/

We also utilise agencies to assist us with searching the Claims and Underwriting Exchange Register and may share your Personal Data to facilitate such searches.

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 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 endeavour to store and process Personal Data within the EEA.

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 Japan and/or the United States.

If we transfer Personal Data to countries outside of the EEA, we will do so in a lawful way and may rely on:

• An adequacy decision which says that the recipient country provides an adequate level of protection of Personal Data
• Appropriate safeguards to protect the Personal Data (for example, the approved Standard Contractual Clauses or International Data Transfer Agreement)
• A lawful exception to the rules relating to overseas data transfers (for example, the transfer is necessary to perform a contract with you, which is in your interests)

To obtain a copy of these safeguards or if you have any questions about how your Personal Data is used, please contact DPO@kinto-uk.com.

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 UK privacy laws, please use the information found in the ‘Contact Us’ section on the KINTO UK website.

Your choices on how you want to be contacted

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 settings on the relevant device, updating your user or account profile, or by following the unsubscribe instructions included in the communication, or by contacting us directly by phone or e-mail.

You have certain rights in relation to your Personal Data, such as the right to access and the right to erasure. Please be aware that these rights do not apply in all circumstances, but we will always look to fulfil your request where possible.

Informed

A right to be informed about the Personal Data we hold about you.

Access

A right to access the Personal Data we hold about you.

Rectifications

A right to require us to rectify any inaccurate Personal Data we hold about you.

Erasure

A right to ask us to delete the Personal Data we hold about you. This right will only apply where, for example;

• We no longer need to use the Personal Data to achieve the purpose we collected it for.
• Where you withdraw your consent if we are using your Personal Data based on your consent.
• Where you object to the way we process your data (see the right to object described below).

Restrict Processing

In certain circumstances, you have a right to restrict our processing of the Personal Data we hold about you. This right will only apply where, for example;

• You dispute the accuracy of the Personal Data held by us.
• Where you would have the right to ask us to delete the Personal Data but would prefer that our processing is restricted instead.
• Where we no longer need to use the Personal Data to achieve the purpose that we collected it for, but you need the data for the purposes of establishing, exercising, or defending legal claims.

Data Portability

In certain circumstances, you have a right to receive the Personal Data you have given us, in a structured, commonly used and machine readable format. You also have the right to require us to transfer this Personal Data to another organisation, at your request.

Objection

A right to object to our processing of the Personal Data we hold about you where our lawful basis is for the purpose of our legitimate interests, unless we are able to demonstrate, on balance, legitimate grounds for continuing to process the Personal Data which override your rights or which are for the establishment, exercise, or defence of legal claims.

Automated decision-making and profiling

A right for you not to be subject to a decision based solely on an automated process, including profiling, which produces legal effects concerning you or similarly significantly affects you. For the avoidance of doubt, KINTO UK does not undertake automated decision-making of this kind.

Withdraw consent

A right to withdraw your consent, where we are relying on it to use your Personal Data.

Making a Complaint

If you wish to make a complaint, please contact us at DPO@kinto-uk.com or alternatively by writing to us at Data Protection Officer, KINTO UK Limited, Building 1000, Lakeside North Harbour, Western Road, Portsmouth, PO6 3EN.

If you are unhappy with the response from the Data Protection Officer then you have the right to submit a complaint to the Information Commissioner’s Office (ICO): 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

If you would like to contact us with any queries or comments, request further information or exercise any of your available rights set out above, please email us at: DPO@kinto-uk.com. If you would like this notice in another format, please contact us using the details above.

We may occasionally make changes 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 remains and that we protect your information and uphold your rights. If significant or material changes are made to this Notice or the way in which we process your Personal Data, we will draw your attention to this either through updates to this Notice on our website, through our service lines or by another means of communication, such as email.