2.4.3 Purpose of the processing of personal data
Dutch anti-money laundering legislation applies to the entire group by virtue of LeasePlan’s parent company's bank licence in the Netherlands.
Anti-money laundering legislation requires KYC as well as investigation, registration, notification and storage obligations. Before LeasePlan can enter into agreements with customers, we must carry out adequate KYC procedures. The obligations cover e.g. identification and legitimation of the our customers.
We are also required to investigate transactions if we suspect that they are related to money laundering or terrorist financing. If the investigations do not disprove the suspicion, we are obligated to notify the Money Laundering Secretariat in Denmark and the corresponding authority in the Netherlands and, if necessary, to terminate the customer relationship. This also applies if the customer cancels the transaction during the KYC procedure or refuses to submit identity information.
If we reject a potential or existing customer, we will record the name of the customer, the reason for rejection and the documentation reviewed.
In an ongoing customer relationship, we will contact you to ensure that our information and copies of identification documents are up to date.
In summary, the purposes are the following:
Compliance with anti-money laundering and anti-terrorist legislation in Denmark and the Netherlands, including
The Anti-Money Laundering Act in Denmark in relation to financial leasing
The EU’s and UN’s sanctions lists
Part 2 of the Dutch anti-money laundering act (Wet ter voorkoming van witwassen en financieren van terrorisme (Wwft))
Sanctiewet 1977 (the Dutch sanctions act)
to comply with orders from authorities
In addition to the above, we process personal data when necessary for the following purposes:
Registration - acceptance of you as lessee. We collect information when you apply for
registration as lessee. This processing of data is necessary for the conclusion
of the leasing contract, including identification and credit assessment
Marketing purposes. We process personal data to send you marketing material to keep you
updated about events, special offers or upcoming products and services from
LeasePlan. When we contact you with marketing, we will do so by e-mail
(newsletters/brochures/magazines) if you have given your consent. To understand
what is relevant to you, we may use information from cookies and/or pixels. If
you no longer wish to receive marketing communication from us, you can unsubscribe
via the link in the e-mails sent to you
To conduct surveys. In surveys we ask for feedback on our webinars
and/or satisfaction with LeasePlan's services/suppliers, e.g. repair shops.
When we contact you about surveys, we may do so e.g. by e-mail. If you do not
wish to receive such communications from us, you can use the opt-out options in
the communication or contact us via the rights form or the general contact
To communicate with you. When you contact us via an online contact form or by phone, e.g. when
you send us questions, proposals, compliments or complaints, or when you
request a quote
Repairs, service and tyres. We process data in connection with repairs,
maintenance and tyre replacements, as well as for planning maintenance and
repairs for the vehicle and settlement thereof
Incident management. We record and manage incidents, e.g. accidents,
that you and/or the vehicle may be involved in, in order to restore mobility
and handle claims, e.g. by (i) notification to customer service, (ii) roadside
assistance and/or replacement car, (iii) repair and other follow-up, (iv)
valuation of repairs according to claims management and excess rules
Traffic offences. The following may depend on the country in which
the driver may have violated road traffic legislation and/or parking rules. As
LeasePlan is the registered owner of vehicles, traffic fines and/or parking
fees incurred by the driver, will be sent to LeasePlan by the relevant
authority having issued the traffic fine or parking fee (e.g. the police or the
municipality). The purpose is to process and administer payment of the fine/fee
and obtain reimbursement from you
LeasePlan’s business purposes. We process personal data about you for various
business purposes, such as data analysis, audits, developing new products,
improving or modifying our services, identifying usage patterns, measuring the
effectiveness of our campaigns, and operating and expanding our business
To safeguard other legitimate purposes, including
‒ to provide a good service, e.g. responding to your inquiries and requests from third parties
‒ to enforce our terms, conditions and policies
‒ to protect our, your or third parties' rights, data protection, safety, security, business or property, including in relation to the implementation of security measures
‒ to comply with legal obligations or to comply with regulatory requests and orders
‒ to establish, exercise or defend legal claims, including e.g. limitation of potential damage.
‒ in connection with a sale or business transaction, e.g. to disclose or transfer personal data to third parties in the event of a reorganisation, merger, sale, joint venture, assignment, transfer, or other disposal of all or a portion of our business, assets, or stock (including in connection with bankruptcy or similar proceedings).