Global Privacy Statement

**Last Updated: 17 May 2021 **

LeasePlan is committed to protecting the personal data collected or processed by it. Respect for privacy and data security practices are essential components of LeasePlan’s Services, corporate governance, principle of accountability and risk management. Therefore, LeasePlan only processes personal data necessary for its business activities and for the provision of its services (hereinafter “Services”).

LeasePlan Privacy Pledges

We process your data as follows:

Transparency: LeasePlan supports you in becoming aware of how your data are collected and used.
Privacy by default: LeasePlan provides Services that comply with personal data protection legislation.
Control: LeasePlan provides you with simple procedures for accessing, rectifying and erasing your personal data.
Security: LeasePlan has adopted adequate security measures. Data are forwarded to third parties when necessary and in compliance with suitable conditions.
Innovation and Responsiveness: LeasePlan always actively seeks new solutions to improve its Services and your privacy and is open to accepting suggestions and complaints.

This Privacy Statements informs you about our privacy practices. We invite you to view the local version of this Privacy Statement in the country where you are using LeasePlan’s services, which you may find on the local website of the LeasePlan leasing company.

Please read this Privacy Statement carefully to understand how we collect and use your personal data. Click here to download the Privacy statement.

1. Scope of this Privacy Statement

2. Data Controller

3. Personal Data Collection and Processing Methods

4. Personal Data Processing Purposes4.1 DATA PERTAINING TO WEBSITE VISITORS 4.2 DATA PERTAINING TO BUSINESS CLIENTS 4.3 DATA RELATING TO DRIVERS (our Clients’ employees) 4.4 DATA PERTAINING TO PRIVATE LEASE CLIENTS 4.5 DATA PERTAINING TO PRIVATE BUYERS OF USED VEHICLES 4.6 DATA PERTAINING TO PROFESSIONAL BUYERS OF USED VEHICLES (Traders) 4.7 DATA PERTAINING TO SUPPLIERS

5. Disclosure of Personal Data to Third Parties

6. International transfer of personal data

7. Security Measures and Personal Data Retention Period

8. Minors’ Privacy Protection

**9. Your Rights and How to Contact LeasePlan **

10. Changes to this Privacy Statement

1. Scope of this Privacy Statement

This global privacy statement (“Privacy Statement”) describes the Company’s practices concerning the personal data collected by it relating to:

I. Website visitors/users (“Website Visitors”); II. Business Clients (“Clients”); III. Clients’ Employees/Drivers (“Drivers”); IV. Private lease clients (including one-man businesses) (“Private Lease Clients”); V. Private buyers of used vehicles (“Buyers”); VI. Professional buyers of used vehicles (“Traders”); VII. Suppliers of goods and services (“Suppliers”).

(or prospects in relation to the above; individually or collectively also referred to as “you”)

LeasePlan collects and uses your personal data in the context of its long-term vehicle and fleet leasing, management and driver mobility services and during the course of our business activities, as further described in Section 1 (“Services”).

This Privacy Statement does not apply to the following affiliates and/or services:

Euro Insurances DAC trading as LeasePlan Insurance or other insurance-related activities;
PowerD, also operating as LeasePlan Energy;
CarNext BV and its affiliates;
LeasePlan Bank in The Netherlands or in Germany.

Specific privacy statements apply to the services provided by the above affiliates.

Specific services may be subject to separate privacy statements, to which reference is made in the respective terms, such as in the case of personal data processing using electronic devices, to which a specific Privacy Statement for Clear Box Services applies.

Therefore, please read our APP Privacy Statement, the Privacy Statement for credit information services, the Video Surveillance Privacy Statement, in order to learn about how we collect and use your personal data, available at the bottom of this Privacy Statement.

Client Responsibilities To the extent that the Clients (employers) have access to personal data, they act as Data Controllers with regard to the processing and use of the same. This Privacy Statement does not apply to the processing and use of personal data by Clients (employers).

2. Data Controller

LeasePlan Italia S.p.A., with registered office at Viale Adriano Olivetti 13, 38122, Trento (Italy), is the Data Controller of your personal data.

LeasePlan Italia S.p.A. may disclose your personal data to LeasePlan Corporation N.V. and LeasePlan Global B.V., which in such cases acts as joint Data Controllers:

Address: Gustav Mahlerlaan 360, 1082 ME Amsterdam, the Netherlands.

For the purposes of this Privacy Statement, LeasePlan Italia S.p.A., LeasePlan Corporation N.V. and LeasePlan Global B.V. are jointly referred to hereunder as “LeasePlan” or “we, us”.

3. Personal Data Collection and Processing Methods

Personal data is acquired by LeasePlan and LeasePlan’s service providers in different ways, including:

Our Services A large part of the data we process relates to vehicle management services provided to drivers and, in case of company vehicles, to employers. Data processing begins with the registration of the leased vehicle (in some circumstances we may carry out some preliminary checks on creditworthiness) and continues with notifications sent by LeasePlan in relation to the services provided, such as the planning of regular maintenance work and repairs. Data may also be processed in the event of vehicles being involved in road accidents, in order to ensure that mobility is restored and any damage handled, or in the event of fines relating to the rental vehicle notified by the authorities to LeasePlan. Alongside our core-leasing activities, LeasePlan offers a wide range of related services, such as e-mobility services, fuel card, recharging services, short-term rental, roadside assistance, resale of used vehicles, sale of LeasePlan’s used vehicles.

Offline We also receive personal data when you interact with us on other occasions, for example when you visit our stores, place a telephone order, or contact our customer service.

Other sources We also receive your personal information from other sources, such as:

Employers of drivers, in the case of company cars;
Competent authorities (for example Police Authorities), when we are the recipients of fines relating to the leased vehicle;
Service providers who assist us in providing leasing services, including dealerships, garages, body repair shops;
Publicly available databases or public records, credit information service providers and other sources;
By visiting our website or our social media channels;
Shared marketing service providers, if they share information with us;
If you connect your social media accounts to our Services account, or if you share information from our Websites to your social media platforms, you share some personal information with us from your social media accounts, such as your name, email address, photos, contact list and any other information that may be accessed by connecting your social media accounts to the LeasePlan account.

Your personal data are collected by LeasePlan in order to provide you with the Services you have requested or to manage your requests, questions, comments and complaints relating to our Services. If you decide not to provide such data, LeasePlan may be unable to provide the Services. In the event that you provide LeasePlan or our suppliers with personal information of third parties for the provision of the Services, you warrant that you are entitled to forward such information to LeasePlan and that it can be used by LeasePlan in accordance with this Privacy Statement.

4. Personal Data Processing Purposes

4.1 DATA PERTAINING TO WEBSITE VISITORS

4.1.1 WEBSITES **4.1.1.a Notifications** *Description* LeasePlan collects your personal data when you use our online contact forms, for example to ask us questions, make suggestions, compliments or complaints, or when you request a quote for our Services. Processing is based on the performance of the contract that LeasePlan has entered into with you, to give a response to your requests or based on your consent. *Personal data processed for these purposes* For this purpose, LeasePlan collects your full name, gender, job title, company contacts (including email address, telephone number, your company’s name), license plate or registration number, as well as any other information you enter into the fields of the contact form, where you may, for example, pose questions, make suggestions, appreciations or complaints. *Disclosure of collected data to third parties* See section ‘[Sharing data with third parties’](targetSelf:#Paragraph14). **4.1.1.b Surveys or other marketing communications** *Description* LeasePlan processes your personal data when you complete the periodic satisfaction surveys on our website and/or relating to the Services, in relation to which we process your data on the basis of your consent or of a legitimate interest. With your express consent or on the basis of LeasePlan’s legitimate interest, you may receive commercial communications, updates on present and future events, special offers, happenings, products and services offered by LeasePlan. For surveys or commercial communications, LeasePlan contacts you by email or by sending newsletters / brochures / magazines (by postal service). If you no longer wish to receive surveys or commercial communications, you may contact LeasePlan using this form. Based on your visits to LeasePlan’s website, you may also receive personalized advertising offers outside LeasePlan’s website via cookies. To understand what you are interested in, LeasePlan may use manual or automated tools to analyse your personal data. *Personal data processed for these purposes* For this purpose, LeasePlan collects your name, your address, email address and the topics of your interest (possibly stated by yourself on LeasePlan’s website). *Disclosure of collected data to third parties* See section ‘[Sharing data with third parties’](targetSelf:#Paragraph14). 4.1.2 SOCIAL MEDIA **4.1.2.a Sharing on Social Media** *Description* LeasePlan websites may contain features to share data on social media, such as the Facebook, Twitter or LinkedIn buttons, which, with your consent, enable the sharing of information on LeasePlan’s sites with the social media of your choice. LeasePlan’s websites may also contain links to LeasePlan’s social media pages, such as LeasePlan’s Facebook page, LinkedIn or Twitter feeds, which you may use for your comments. Likewise, various social media websites, such as Instagram, Facebook, or LinkedIn, may display LeasePlan’s advertisements containing links to our websites. These social media websites may, with your consent, share the information you have provided with us once you choose to follow a link to one of our websites. LeasePlan does not accept any responsibility for the collection, use and disclosure policies and practices (including personal data security practices) of third parties, such as Facebook, Apple, Twitter, Google, Microsoft, RIM or other developers and app suppliers, social media platform and wireless service providers, operating system suppliers or device manufacturers; LeasePlan does not accept any responsibility for personal data disclosed to third parties due to LeasePlan’s social media features. The privacy policies and practices of such third parties apply to any personal data processing in such regard. *Personal data processed for these purposes* For this purpose, LeasePlan processes your name, email address, IP address, photos, social media contact list and any other information that may be accessible through the use of LeasePlan’s social media features. *Disclosure of collected data to third parties* See section ‘[Sharing data with third parties’](targetSelf:#Paragraph14). 4.1.3 COOKIES AND SIMILAR TECHNOLOGIES Your personal data are processed by means of cookies and/or similar technologies in accordance with the [Cookie Privacy Statement.](targetBlank:https://www.leaseplan.com/it-it/cookie-policy/).4.1.4 LEASEPLAN BUSINESS PURPOSES **4.1.4.a Management reporting** *Description* LeasePlan processes any personal data acquired in the pursuit of various internal business purposes on the basis of LeasePlan’s legitimate interest in the processing of such data, such as data analysis, checks, development of new products, enhancement, improvement or modification of websites and services, identification of usage trends, assessment of the effectiveness of promotional campaigns, as well as the development and expansion of its business operations. To facilitate your use of our online services or your requests, LeasePlan may analyse the data it collects when you use digital pages and associate them with information collected via cookies. For example, to better understand which digital channel (Google search engine, email, social media) or IT tool you prefer (desktop, tablet or mobile phone), we may optimize or limit our communication or marketing activities by channel or IT tool. *Personal data processed for these purposes* For this purpose, LeasePlan may process your name, email address, IP address, gender, date of birth, place of residence, postcode and any other information described in this Privacy Statement or otherwise provided by you, where required, for one of the purposes stated in the preceding paragraph. *Disclosure of collected data to third parties* See section ‘[Sharing data with third parties’](targetSelf:#Paragraph14). **4.1.4.b Compliance with Legal Provisions and Obligations and Protection of LeasePlan’s Assets and Rights ***Description* To comply with legal provisions or when we have a legitimate interest, LeasePlan processes personal data as appropriate or necessary, as follows: (a) pursuant to applicable legislation, including enforcement laws of countries other than your country of residence and recommended industry practices (e.g. counterparty due diligence, anti-money laundering and anti-terrorist financing and other offences); (b) in compliance with legal procedures; (c) in order to meet the demands of public and state authorities, including those of countries other than your country of residence; (d) in order to apply LeasePlan’s applicable conditions and policies; (e) in order to protect LeasePlan’s transactions; (f) in order to protect your rights, privacy, security or property, those of LeasePlan or of any third parties; (g) in order to allow LeasePlan to use any available remedies or contain any damage suffered. *Personal data processed for these purposes* For this purpose, LeasePlan processes data relating to your name, contact details, company correspondence, Services used or any other information specified in this Privacy Statement or otherwise provided by you, where required, for one of the purposes stated in the preceding paragraph. *Disclosure of data to third parties*Where required by law or industry best practices to which LeasePlan is subject, personal data may be disclosed to regulatory institutions, tax authorities and judicial bodies. See also section ‘[Sharing data with third parties’](targetSelf:#Paragraph14).

4.2 DATA PERTAINING TO CLIENTS

4.2.1 CLIENT ACCOUNT MANAGEMENT **4.2.1.a Provision, Management and Administration of the Client Account** *Description* LeasePlan collects your personal information to deal with the routine management and administration of its Client accounts, such as contractual management and notification of the main news and information regarding the Services, contract and Client accounts. Such processing is carried out on the basis of the performance of the rental agreement that LeasePlan has entered into with you or on the basis of a legal obligation. *Personal data processed for these purposes* For this purpose, LeasePlan may process your company contact details and access data to the Client accounts. *Disclosure of collected data to third parties* See section ‘[Sharing data with third parties’](targetSelf:#Paragraph14). **4.2.1.b Notifications** *Description* You may contact LeasePlan by various means (for example, by email, telephone or through the website). In such circumstances, LeasePlan uses your personal data to answer your questions / requests. LeasePlan may also contact you for notifications relating, among other things, to the management and ordinary administration of your Client account. Such processing is carried out on the basis of LeasePlan’s legitimate interest and concerns the performance of the rental agreement that LeasePlan has entered into with you or with your consent. *Personal data processed for these purposes* For this purpose, LeasePlan may process your name, your company contact details, correspondence with LeasePlan regarding questions / requests you submit, as well as any other personal data you provide or needed in order to adequately reply to your questions / requests. *Disclosure of collected data to third parties* See section ‘[Sharing data with third parties’](targetSelf:#Paragraph14). **4.2.1.c Surveys or other Marketing Communications** *Description* LeasePlan processes your personal data to send you satisfaction surveys in relation to which we process your data on the basis of a legitimate interest. With your express consent or on the basis of LeasePlan’s legitimate interest, you may receive commercial communications, updates on LeasePlan’s present and future events, special offers, happenings, products and services. LeasePlan sends you such surveys by regular email or email message asking for your opinion on our Services or other vehicle services provided. LeasePlan may also send newsletters / brochures / magazines (mailing). To understand what you are interested in, LeasePlan may use manual or automated tools to analyse your personal data. If you no longer wish to receive surveys or commercial communications, you may contact LeasePlan using the following [form](targetSelf:https://privacyportal-eu-cdn.onetrust.com/dsarwebform/396c853c-7bbe-43bb-9c80-0001fd327955/204d5d03-adf8-4c9d-a105-0ad329845acf.html). To facilitate your use of our Services or online applications, LeasePlan may analyse the data it collects when you use digital pages and may associate them with information collected via cookies. For example, to better understand which digital channel (Google search engine, e-mail, social media) or IT tool you prefer (desktop, tablet or mobile phone), we may optimize or limit our communication and marketing activities by channel or IT tool. *Personal data processed for these purposes* For this purpose, LeasePlan collects your name and your company details. *Disclosure of collected data to third parties* See section ‘[Sharing data with third parties’](targetSelf:#Paragraph14). 4.2.2 LEASEPLAN PREMISES **4.2.2.a Access to LeasePlan’s Premises and Security Checks** *Description* In order to ensure adequate access and security controls, LeasePlan may process your personal data when you visit our premises, based on LeasePlan’s legitimate interest in processing such data (protection and security of our assets). *Personal data processed for these purposes* For this purpose, LeasePlan collects your name, your contact details and the name of the person you are meeting within the premises. *Disclosure of collected data to third parties* See section ‘[Sharing data with third parties’](targetSelf:#Paragraph14). 4.2.3 CLIENT REPORTING **4.2.3.a MyFleet** *Description* LeasePlan provides the online reporting tool “MyFleet”. Clients’ contact person can access these tools to be always updated on the status of their fleet, claims reporting, contract management and to use additional fleet features such as dashboards, i.e. summary information and trends on the most relevant car fleet management analyses. This processing is carried out on the basis of LeasePlan’s legitimate interest and in relation to the performance of the lease agreement that LeasePlan has in place with the Client. *Personal data processed for these purposes* For this purpose, LeasePlan collects contact details and professional title (e.g. international Fleet Manager) of the Client’s contact, as well as access data (e.g. username and password). *Disclosure of collected data to third parties* See section ‘[Sharing data with third parties’](targetSelf:#Paragraph14). 4.2.4 LEASEPLAN BUSINESS PURPOSES **4.2.4.a Management reporting description** *Description* LeasePlan processes personal data acquired for various internal business purposes, on the basis of LeasePlan’s legitimate interest in the processing of these data, such as data analysis, checks, development of new products, enhancement, improvement or modification of Services, identification of usage trends, assessment of the effectiveness of promotional campaigns, as well as the development and expansion of its business operations. To facilitate your use of our online services or your requests, LeasePlan may analyse the data it collects when you use digital pages and associate them with information collected via cookies. For example, to better understand which digital channel (Google search engine, email, social media) or IT tool you prefer (desktop, tablet or mobile phone), we may optimize or limit our communication or marketing activities by channel or IT tool. *Personal data processed for these purposes* For this purpose, LeasePlan may process various pieces of information collected in the context of the provision of our Services (for example your name, contact details, fleet information etc.), as necessary for the purposes described above. *Disclosure of collected data to third parties* See section ‘[Sharing data with third parties’](targetSelf:#Paragraph14). **4.2.4.b Compliance with Legal Provisions and Obligations and Protection of LeasePlan’s Assets and Rights ***Description* To comply with legal provisions or when we have a legitimate interest, LeasePlan processes your personal data as appropriate or necessary, as follows: (a) pursuant to applicable legislation, including enforcement laws of countries other than your country of residence and recommended industry practices (e.g. counterparty due diligence, anti-money laundering and anti-terrorist financing and other offences); (b) creditworthiness investigations; (c) in compliance with legal procedures; (d) in order to meet demands from public and state authorities, including those of countries other than your country of residence; (e) in order to enforce LeasePlan’s terms and conditions; (f) in order to protect LeasePlan’s operations; (g) in order to protect your rights, privacy, security or property, those of LeasePlan or of any third party; and (h) in order to allow LeasePlan to use any available remedies or to contain any damage suffered. *Personal data processed for these purposes* For this purpose, LeasePlan processes data relating to the name, contact details, date, place and country of birth of the beneficiary / beneficial owner of the counterparty with whom LeasePlan entertains business relations. LeasePlan may also process the name, address, date, place and country of birth of the person(s) representing the company before LeasePlan; your correspondence with LeasePlan, your use of the Services and any other information specified in this Privacy Statement, where required, for one of the purposes stated in the preceding paragraph. *Disclosure of data to third parties*Where required by law or industry best practices to which LeasePlan is subject, personal data may be disclosed to regulatory institutions, tax authorities and judicial bodies. See section ‘[Sharing data with third parties’](targetSelf:#Paragraph14).

4.3 DATA RELATING TO DRIVERS (our Clients’ employees)

4.3.1 DRIVER CONTACT DETAILS **4.3.1.a Notifications.** *Description* You may contact LeasePlan by various means (for example, by email, telephone or through the website). In such circumstances, LeasePlan uses your personal data to answer your questions / requests. LeasePlan may also contact you with regard to the leased vehicle or other relevant matters concerning the driver thereof. Such data are processed on the basis of LeasePlan’s legitimate interest and of the provision of the Services referred to in the rental agreement between LeasePlan and the driver’s employer or on the basis of the consent given. *Personal data processed for these purposes* For this purpose, LeasePlan processes your name, contact details, correspondence with LeasePlan regarding your questions / requests, as well as any other personal data you provide, including your license plate number, or needed in order to give an adequate reply to your requests.*Disclosure of collected data to third parties* See section ‘[Sharing data with third parties’](targetSelf:#Paragraph14). **4.3.1.b Surveys or other marketing communications ***Description* LeasePlan processes your personal data when you complete periodic satisfaction surveys relating to the Services or other services provided on the vehicle, in relation to which we process your data on the basis of a legitimate interest. With your express consent or on the basis of LeasePlan’s legitimate interest, you may receive commercial communications, updates on LeasePlan’s present and future events, special offers, happenings, products and services. For surveys or commercial communications, LeasePlan contacts you by email or by sending newsletters / brochures / magazines (by postal service). To understand what you are interested in, LeasePlan may use manual or automated tools to analyse your personal data. If you no longer wish to receive surveys or commercial communications, you may contact LeasePlan using this [form](targetSelf:https://app-eu.onetrust.com/app/#/webform/204d5d03-adf8-4c9d-a105-0ad329845acf). *Personal data processed for these purposes* For this purpose, LeasePlan processes your name, address, email address, your license plate and your interests (as stated by yourself). *Disclosure of collected data to third parties* See section ‘[Sharing data with third parties’](targetSelf:#Paragraph14). 4.3.2 VEHICLE SERVICES **4.3.2.a Management of the vehicle** *Description* LeasePlan processes your data as part of the leased vehicle’s routine administration and management on the basis of LeasePlan’s legitimate interest and of the provision of the Services under the agreement between LeasePlan and your employer. *Personal data processed for these purposes* For this purpose, LeasePlan processes your name, address, (company) email address, rental category, license plate number, vehicle make and model, servicing history and operational contacts. Furthermore, LeasePlan may collect any vehicle data entered by you in LeasePlan’s portal or communicated during telephone conversations with LeasePlan. *Disclosure of collected data to third parties*LeasePlan shares data related to vehicle management with its Clients (employers). See also section ‘[Sharing data with third parties’](targetSelf:#Paragraph14). **4.3.2. b Repair, maintenance and tires** *Description* LeasePlan processes your data in connection with the provision of (scheduled) repair and maintenance Services or tire Services on your vehicle and to actively analyse, predict and manage maintenance work and repairs on the basis of LeasePlan’s legitimate interest and of the provision of the Services governed by the rental agreement between LeasePlan and your employer. *Personal data processed for these purposes* For this purpose, LeasePlan collects your name, address, (company) email address, license plate number, vehicle make and model, servicing history and operational contacts. Furthermore, LeasePlan may collect any data entered in LeasePlan’s portal (for example, the telephone number given by you to arrange for maintenance work) or data communicated during telephone conversations with LeasePlan. *Disclosure of data to third parties L*easePlan shares data with its Clients (your employers) and with third parties in charge of carrying out maintenance work / repairs or replacement of vehicle tires, such as dealerships / distributors, body repair shops or garages. See also section ‘[Sharing data with third parties’](targetSelf:#Paragraph14). **4.3.2.c Claims Management** *Description* LeasePlan processes your personal data by recording and managing claims involving you or your vehicle in order to restore mobility and handle any damage. LeasePlan carries out such activities: (i) allowing you to report claims immediately through Client Service; (ii) providing roadside services and/or replacement vehicles, where applicable; (iii) planning repairs and any other necessary work. This processing is carried out on the basis of LeasePlan’s legitimate interest and of the provision of the Services under the lease agreement between LeasePlan and your employer. The information collected may also be used for damage assessment purposes as part of the company’s damage management and risk retention policies, in regard of which LeasePlan has a legitimate interest in processing such data. *Personal data processed for these purposes* For this purpose, LeasePlan processes the following personal data: − Data originating from LeasePlan: license plate number, vehicle make and model, history of services provided and operational contacts. − Data originating from you: your name, contact details, description of the vehicle, description of the accident, description of any damage, photographs relating to the accident, date of birth, number of vehicle passengers, information on witnesses of the accident (where applicable) and any other information provided by you in relation to the claim (including information on any personal injuries). − Data originating from third parties, such as parties involved in the accident or insurance companies: information relating to third parties involved in the accident / event (such as the identity of the passengers in your vehicle, driver and passengers in third-party vehicles), information relating to other third parties (such as witnesses, intervening police officers, etc.) insurance information, information on the event and on claims of third parties. − Data originating from authorities (such as the police): your name, address, license plate number, information on the accident, police reports and witness statements. *Disclosure of data to third parties*LeasePlan shares these data with its Clients (your employers) via MyFleet. LeasePlan may also share certain data with dealerships / distributors, body repair shops, garages, insurance companies (whether affiliated or independent) and qualified professionals (such as lawyers, doctors, investigators, etc.) appointed by LeasePlan or third parties for the purpose of resolving the dispute and settling any damages. See also section ‘[Sharing data with third parties’](targetSelf:#Paragraph14). **4.3.2.d Management of Fines** *Description*The following information may vary depending on the country in which Drivers commit traffic or parking violations. As the owner of the vehicles, LeasePlan may receive reports issued by the authorities (e.g. State Police or Municipal Police) relating to infringements committed by vehicle drivers. In these cases, LeasePlan processes your personal data in order to manage the payment of the fine and, where applicable, to obtain reimbursement from the Client (your employer) on the basis of LeasePlan’s legitimate interest. *Personal data processed for these purposes* LeasePlan processes data received from the competent authorities (such as State Police and Municipal Police), namely: your name, address and license plate number, the nature, place and date of the violation / infringement committed and the fine imposed. *Disclosure of data to third parties*In certain situations, LeasePlan may have to share these data with its Clients (your employers), for example if the vehicles are used by several employees and LeasePlan is unaware of the vehicle driver’s identity.*See also section Errore. L'origine riferimento non è stata trovata.* See also section ‘[Sharing data with third parties’](targetSelf:#Paragraph14). **4.3.2.e Fuel Card, Electric Vehicle Charging** *Description*Our Services includes a fuel management programme that allows you, for example, to pay for fuel at petrol stations by using a payment system issued or operated by LeasePlan. If you have an electric vehicle, at the request of your employer or at your request, you may use an energy key, referred to as Keyfob, which enables electric charging at public charging stations. Such processing is carried out on the basis of LeasePlan’s legitimate interest and of the provision of the Services that LeasePlan has in place with your employer.*Personal data processed for these purposes For this purpose, LeasePlan collects the following data: name, contact details, email address, fuel card or Keyfob number, charging station number and address, vehicle license plate number, fuel information, mileage and related costs. In the event of a refund, we may also need to acquire bank account information. Disclosure of data to third parties*LeasePlan needs to share information with companies that provide fuel cards / Keyfobs and payment tools. Clients (your employers) may also have access to some personal data forwarded to them by LeasePlan through the online portal, the e-Mobility portal or the “MyFleet” reporting tool. By accessing the tool, Clients may check the status of their fleet (e.g. mileage) or use the MyFleet features (e.g. to obtain information on fuel consumption or trend analysis reports). See also section ‘[Sharing data with third parties’](targetSelf:#Paragraph14). 4.3.3 MOBILITY SERVICES **4.3.3.a Rental** *Description* LeasePlan collects your personal data for the provision of car rental services in order to allow you, for example, to reach the nearest LeasePlan specialists through Customer Service, collect your vehicle from the most convenient agency or receive the vehicle at your domicile in the located specified by you. Such processing is carried out on the basis of LeasePlan’s legitimate interest and of the provision of the Services under the lease agreement that LeasePlan has in place with your employer or, if applicable, on the basis of the agreement you have in place with us. *Personal data processed for these purposes* For this purpose, LeasePlan ill collects the following data: name, email, mobile phone number, vehicle license plate number, related costs, place of delivery, rental time and company contact. *Disclosure of data to third parties*LeasePlan shares your data with (independent) specialists affiliated with LeasePlan. See also section ‘[Sharing data with third parties’](targetSelf:#Paragraph14). **4.3.3.b Roadside Assistance ** *Description* In the event of a vehicle breakdown, for example in the event of a tire puncture or mechanical issues during the journey, LeasePlan provides roadside assistance in collaboration with third-party suppliers. This processing is carried out on the basis of LeasePlan’s legitimate interest and of the provision of the Services under the rental agreement that LeasePlan has in place with your employer. *Personal data processed for these purposes* For this purpose, LeasePlan collects the following data: name, email address, mobile phone number, vehicle license plate number and place where the breakdown and subsequent roadside assistance occurred. *Disclosure of data to third parties*LeasePlan shares your data with third parties who provide vehicle repair, towing or car replacement services. See also section ‘[Sharing data with third parties’](targetSelf:#Paragraph14). 4.3.4 DRIVER SAFETY PROGRAMMES **4.3.4. a Preparing, Managing and Providing Training** *Description* LeasePlan provides various driver safety and risk management training programmes in order to analyse and improve Client driving behaviour, promote the Clients’ proactive commitment to safety and good corporate citizenship, reduce the number of claims, confirm the overall effectiveness of your companies’ safety initiatives and identify communication and training opportunities. LeasePlan entrusts the management and performance of the above safety training programmes to third parties, who contact you to initiate a safety assessment and provide you with (both online and classroom) training sessions. Any personal data collected by third parties in relation to such activities are subject to the privacy policies of said third parties. LeasePlan receives your “driver risk index” (information about potential risks identified through questionnaires) from third-party suppliers, any recommended courses that you have signed up for and completed. Such processing is carried out on the basis of LeasePlan’s legitimate interest and of the provision of the Services under the lease agreement that LeasePlan has in place with your employer or on your consent. *Personal data processed for these purposes* For this purpose, LeasePlan collects and process the following personal information: − Directly from Clients (your employers): your name, company email address and license plate number. − From third parties commissioned by LeasePlan: driver risk index, recommended courses, courses you have signed up for and courses you have completed. *Disclosure of data to third parties*LeasePlan shares your data with parties we have entrusted with the management and performance of driver safety programmes and with our clients (your employers). See also section ‘[Sharing data with third parties’](targetSelf:#Paragraph14). 4.3.5 ONLINE PORTALS AND APPS **4.3.5.a Online Portals and Apps for Users** *Description* Depending on your country, LeasePlan provides you with online portals and apps with different features. For example, through our portals and apps you may find useful information on rental vehicles, change your username, contact details and other personal data, report any vehicle damage, book appointments for repairs, maintenance work or tire changes, contact our Driver Contact Centre, view and pay any fines, claim fuel expenses and, in case you have an electric vehicle, manage the charging thereof. LeasePlan can also provide you with an overview of your use of the vehicle (such as your average fuel consumption, damage etc.). Such data processing is carried out on the basis of LeasePlan’s legitimate interest and of the provision of the Services under the rental agreement between LeasePlan and your employer or with your consent. *Personal data processed for these purposes* For this purpose, LeasePlan receives your name and email address from your employer (our Client) to send you the login credentials (username and temporary password) for accessing the online portals and the app. *Disclosure of data to third parties* See section ‘[Sharing data with third parties’](targetSelf:#Paragraph14). Please also read our APP Privacy Statement to learn about how we collect and use your personal data in this regard. **4.3.5.b MyFleet** *Description* MyFleet is an application that allows our Clients (your employers) to view national and international reports. Among other features, MyFleet allows Clients to obtain information on mileage and rental time of (single) vehicles. LeasePlan also uses the data contained in the MyFleet tool to provide its Clients (your employers) with an (aggregated) overview of the main fleet management aspects (for example, in terms of costs and risks) with the aim of adopting a balanced approach to (costs, environment and safety) management, manage the launch of and compliance with fleet policies, having the possibility to state commitments for the reduction of polluting emissions as part of the Client’s social responsibility commitments, evaluating the effectiveness of policy changes and actively communicating developments involving the fleet. Such data processing is carried out on the basis of LeasePlan’s legitimate interest and of the provision of the Services under the rental agreement between LeasePlan and your employer. *Personal data processed for these purposes* For this purpose, LeasePlan may process the following personal data: − Data originating from our Client (your employer): Driver’s name, Driver’s identification number generated by the Client, number and use of the fuel card (optional). − Data originating from LeasePlan: vehicle details (e.g. make, model, registration number, license plate number), residual contract term, vehicle damage, fuel type, fuel card number and type, fuel consumption and insurance data. − Data originating from the Driver: mileage and description of any damage to the vehicle involved in a road accident. − Data originating from third parties (such as the State Police, Municipal Police or garages): mileage and information on vehicle maintenance work and repairs. *Disclosure of data to third parties*LeasePlan shares these data with the Client’s authorized (International) Fleet Managers. See also section ‘[Sharing data with third parties’](targetSelf:#Paragraph14). 4.3.6 LEASEPLAN BUSINESS **4.3.6.a Management reporting** *Description* LeasePlan processes any personal data acquired in the pursuit of various internal business purposes, in regard of which LeasePlan has a legitimate interest in the processing of such data, such as data analysis, accounting, development of new products, enhancement, improvement or modification of the Services, identification of usage trends, assessment of the effectiveness of promotional campaigns, as well as the development and expansion of its business operations. To facilitate your use of our online services or applications, LeasePlan may analyse the data it collects when you use digital pages and associate them with information collected via cookies. For example, to better understand which digital channel (Google search engine, email, social media) or IT tool you prefer (desktop, tablet or mobile phone), we may optimize or limit our communication or marketing activities by channel or IT tool. *Personal data processed for these purposes* For this purpose, LeasePlan may process data of various kinds, collected during the course of the Services (such as your name, your contact details, vehicle details, etc.), depending on the needs concerning the above purposes.*Disclosure of data to third parties* See section ‘[Sharing data with third parties’](targetSelf:#Paragraph14). **4.3.6.b Compliance with Legal Provisions and Obligations and Protection of LeasePlan’s Assets and Rights ***Description* To comply with legal provisions or when we have a legitimate interest, LeasePlan processes personal data as appropriate or necessary, as follows: (a) pursuant to applicable legislation, including enforcement laws of countries other than your country of residence and recommended industry practices (e.g. counterparty due diligence, anti-money laundering and anti-terrorist financing and other offences); (b) in order to perform creditworthiness checks; (c) in compliance with legal procedures; (d) in order to meet the demands of public and state authorities, including those of countries other than your country of residence; (e) in order to apply LeasePlan’s applicable conditions and policies; (f) in order to protect LeasePlan’s transactions; (g) in order to protect your rights, privacy, security or property, those of LeasePlan or of any third parties; (h) in order to allow LeasePlan to use any available remedies or contain any damage suffered. If you and your employer have given your consent, LeasePlan may also analyse information regarding the vehicle(s) if you have already rented a car from LeasePlan, for example to calculate the cost of your new rental vehicle. *Personal data processed for these purposes* For this purpose, LeasePlan processes data relating to your name, contact details, correspondence with the company, Services used or any other information specified in this Privacy Statement for one of the purposes stated in the preceding paragraph. *Disclosure of data to third parties*Where required by law or industry best practices to which LeasePlan is subject, personal data may be disclosed to regulatory institutions, tax authorities and judicial bodies. See also section ‘[Sharing data with third parties’](targetSelf:#Paragraph14).

4.4 DATA PERTAINING TO PRIVATE LEASE CLIENTS

4.4.1 REGISTRATION **4.4.1.a Becoming a LeasePlan Client** *Description* LeasePlan collects information when you register (through our website) as a client. Such processing is required for the conclusion and performance of the lease agreement, including the evaluation, identification and approval of the client and any creditworthiness checks on the part of LeasePlan. *Personal data processed for these purposes* For this purpose, LeasePlan collects your name, gender, job title, address, contact details (including your email address, telephone number, drivers’ license, vehicle delivery or collection address, transaction data, such as order, amounts to be paid, payment details), bank account number and the authorization given to LeasePlan. *Disclosure of data to third parties*LeasePlan forwards your data to third parties with whom we have a contract in place to provide online payment services, such as payment of the security deposit and payment of the monthly rental fee. LeasePlan only shares information if it is necessary for making the payment. See also section ‘[Sharing data with third parties’](targetSelf:#Paragraph14). **4.4.1. b Portals and apps** *Description* LeasePlan makes online portals and apps available to you. By using the portals and apps you may find useful information on lease vehicles, your contact details and other personal data, report any changes, report any vehicle damage, book appointments for repairs, maintenance work or tire changes, contact our client service, or view and pay fines. Such data are processed because this is necessary for the performance of the lease agreement or with your consent. *Personal data processed for these purposes* For this purpose, LeasePlan processes your name, email address to send you a temporary password for the use of the web platform and app. *Disclosure of data to third parties* See section ‘[Sharing data with third parties’](targetSelf:#Paragraph14). 4.4.2 CONTACT **4.4.2.a Notifications** *Description* You may contact LeasePlan by various means (for example, by email, telephone or through the website). In such circumstances, LeasePlan uses your personal data to answer your questions / requests. LeasePlan may also contact you in relation to rental agreements with individuals. Such data are processed because this is necessary for the performance of the rental agreement or with your consent. *Personal data processed for these purposes* For this purpose, LeasePlan processes your name, contact details, correspondence with LeasePlan regarding your questions / requests, as well as any other personal data you provide, including the license plate number, or needed to provide an adequate reply to your inquiries, the conditions negotiated in the lease agreement and your financial obligations towards LeasePlan. *Disclosure of collected data to third parties* See section ‘[Sharing data with third parties’](targetSelf:#Paragraph14). **4.4.2.b Surveys or other marketing communications** *Description* LeasePlan processes your personal data when you complete periodic satisfaction surveys relating to the Services or other services provided on the vehicle, in relation to which we process your data on the basis of a legitimate interest. With your express consent or on the basis of LeasePlan’s legitimate interest, you may receive commercial communications, updates on LeasePlan’s present and future events, special offers, happenings, products and services. For surveys or commercial communications, LeasePlan contacts you by email or by sending newsletters / brochures / magazines (by postal service). To understand what you are interested in, LeasePlan may use manual or automated tools to analyse your personal data. If you no longer wish to receive surveys or commercial communications, you may contact LeasePlan using this [form](targetSelf:https://app-eu.onetrust.com/app/#/webform/204d5d03-adf8-4c9d-a105-0ad329845acf). *Personal data processed for these purposes* For this purpose, LeasePlan collects your name, your address, email address, your license plate number, and the topics of your interest (as possibly specified by you on LeasePlan’s website). *Disclosure of collected data to third parties* See section ‘[Sharing data with third parties’](targetSelf:#Paragraph14). 4.4.3 VEHICLE SERVICES **4.4.3.a Vehicle Management** *Description* LeasePlan processes your data during the ordinary use of the vehicle. Such processing is necessary for the performance of the rental agreement. *Personal data processed for these purposes* For this purpose, LeasePlan processes your name, address, (company) email address, rental category, license plate number, vehicle make and model, servicing history and operational contacts. Furthermore, LeasePlan may collect any vehicle data entered by you in LeasePlan’s portal or communicated during telephone conversations with LeasePlan. *Disclosure of collected data to third parties* See section ‘[Sharing data with third parties’](targetSelf:#Paragraph14). **4.4.3.b Repair, maintenance and tires** *Description* LeasePlan processes your data in connection with the provision of (scheduled) repair and maintenance Services or tire Services on your vehicle and to actively analyse, predict and manage maintenance work and repairs. This processing is based on LeasePlan’s legitimate interest and is necessary for the performance of the lease agreement. *Personal data processed for these purposes* For this purpose, LeasePlan collects your name, address, (company) email address, license plate number, vehicle make and model, servicing history and operational contacts. Furthermore, LeasePlan may collect any data entered in LeasePlan’s portal (for example, the telephone number given by you to arrange for maintenance work) or data communicated during telephone conversations with LeasePlan. *Disclosure of data to third parties*LeasePlan shares data with third parties in charge of carrying out vehicle maintenance work / repairs or tire replacement, such as dealerships / distributors, body repair shops or garages. See also section ‘[Sharing data with third parties’](targetSelf:#Paragraph14). **4.4.3.c Claims Management** *Description* LeasePlan processes your personal data by recording and managing claims involving you or your vehicle in order to restore mobility and handle any damage. LeasePlan carries out such activities: (i) allowing you to report claims immediately through Customer Service; (ii) providing roadside services and/or replacement vehicles, where applicable; (iii) planning repairs and any other necessary work. Such processing is necessary for the performance of the rental agreement. The information collected may also be used for damage assessment purposes as part of the company’s damage management and risk retention policies, in regard of which LeasePlan has a legitimate interest in processing such data. *Personal data processed for these purposes* For this purpose, LeasePlan processes the following personal data: − Data originating from LeasePlan: license plate number, vehicle make and model, servicing history and operational contacts. − Data originating from you: your name, contact details, description of the vehicle, description of the accident, description of any damage, photographs relating to the accident, date of birth, number of vehicle passengers, information on witnesses of the accident (where applicable) and any other information provided by you in relation to the claim (including information on any personal injuries). − Data originating from third parties, such as parties involved in the accident or insurance companies: information relating to third parties involved in the accident / event (such as the identity of the passengers in your vehicle, driver and passengers in third-party vehicles), information relating to other third parties (such as witnesses, intervening police officers, etc.) insurance information, information on the event and on claims of third parties. − Data originating from authorities (such as the police): your name, address, license plate number, information on the accident, police reports and witness statements. *Disclosure of data to third parties*LeasePlan shares these data with dealerships / distributors, body repair shops, garages, insurance companies (whether affiliated or independent) and qualified professionals (such as lawyers, doctors, investigators, etc.) appointed by LeasePlan or third parties for the purpose of resolving a dispute and settling damages. See also section ‘[Sharing data with third parties’](targetSelf:#Paragraph14). **4.4.3.d Energy Key.** *Description* In the event that you have an electric vehicle, at the request of your employer you may use an energy key, referred to as Keyfob, which enables the electric recharging at public charging stations. Such processing is necessary for the performance of the lease agreement. Furthermore, LeasePlan may provide services in relation to the placement of charging points. *Personal data processed for these purposes* For this purpose, LeasePlan collects the following information: your name, email address, Keyfob number, license plate number, mileage and related costs. In the event of a reimbursement, LeasePlan may also need to receive your bank account details. *Disclosure of data to third parties*LeasePlan needs to share these data with electric recharge payment service and system providers. See also section ‘[Sharing data with third parties’](targetSelf:#Paragraph14). **4.4.3.e Management of Fines** *Description* The following information may vary depending on the country in which you have committed traffic or parking violations. As the owner of the vehicles, LeasePlan may receive reports issued by authorities (for example State Police or Municipal Police) relating to traffic offenses or offenses relating to illegal parking and layby. In these cases, LeasePlan processes your personal data in order to manage the payment of the fine. Such processing is necessary for the performance of the lease agreement. *Personal data processed for these purposes* LeasePlan processes data received from the competent authorities (such as State Police and Municipal Police), namely: your name, address and license plate number, the nature, place and date of the violation / infringement committed and the fine imposed. *Disclosure of data to third parties* See section ‘[Sharing data with third parties’](targetSelf:#Paragraph14). 4.4.4 MOBILITY SERVICES **4.4.4.a Roadside assistance** *Description* In the event of a vehicle malfunction, for example in the event of a tire puncture or mechanical failure while driving, LeasePlan provides you with a roadside assistance service offered in collaboration with third party suppliers. Such processing is necessary for the performance of the rental agreement. *Personal data processed for these purposes* For this purpose, LeasePlan collects the following data: name, email, mobile phone number, vehicle license plate number and place where the breakdown and subsequent roadside assistance occurred.*Disclosure of data to third parties*LeasePlan shares your data with third parties who provide vehicle repair, towing or car replacement services. See also section ‘[Sharing data with third parties’](targetSelf:#Paragraph14).4.4.5 LEASEPLAN BUSINESS PURPOSES **4.4.5.a Management reporting** *Description* LeasePlan processes any personal data acquired for various internal business purposes, on the basis of LeasePlan’s legitimate interest in the processing of such data, such as data analysis, checks, development of new products, enhancement, improvement or modification of websites and services, for the purpose of identifying usage trends, assessing the effectiveness of promotional campaigns, as well as carrying out and expanding business operations. To facilitate your use of our online services or your requests, LeasePlan may analyse the data it collects when you use digital pages and associate them with information collected via cookies. For example, to better understand which digital channel (Google search engine, email, social media) or IT tool you prefer (desktop, tablet or mobile phone), we may optimize or limit our communication or marketing activities by channel or IT tool. *Personal data processed for these purposes* For this purpose, LeasePlan may process your name, email address, IP address, gender, date of birth, place of residence, postcode and any other information described in this Privacy Statement or otherwise provided by you, where required, for one of the purposes stated in the preceding paragraph. *Disclosure of collected data to third parties* See section ‘[Sharing data with third parties’](targetSelf:#Paragraph14). **4.4.5.b Compliance with Legal Provisions and Obligations and Protection of LeasePlan’s Assets and Rights ** *Description* To comply with legal provisions or when we have a legitimate interest, LeasePlan processes your personal data as appropriate or necessary, as follows: (a) pursuant to applicable legislation, including enforcement laws of countries other than your country of residence and recommended industry practices (e.g. counterparty due diligence, anti-money laundering and anti-terrorist financing and other offences); (b) in compliance with legal procedures; (c) in order to meet the demands of public and state authorities, including those of countries other than your country of residence; (d) in order to apply LeasePlan’s applicable conditions and policies; (e) in order to protect LeasePlan’s transactions; (f) in order to protect your rights, privacy, security or property, those of LeasePlan or of any third parties; (g) in order to allow LeasePlan to use any available remedies or contain any damage suffered. *Personal data processed for these purposes* For this purpose, LeasePlan processes data relating to the name, contact details, date, place and country of birth, of the beneficiary / beneficial owner of the company; LeasePlan may also process the name, address, date, place and country of birth of the person(s) representing the company before LeasePlan; your correspondence with LeasePlan, your use of the Services and any other information specified in this Privacy Statement, where required, for one of the purposes stated in the preceding paragraph.*Disclosure of data to third parties*Where required by law or industry best practices to which LeasePlan is subject, personal data may be disclosed to regulatory institutions, tax authorities and judicial bodies*.* See also section ‘[Sharing data with third parties’](targetSelf:#Paragraph14).

4.5 DATA PERTAINING TO PRIVATE BUYERS OF USED VEHICLES

4.5.1 PURCHASE **4.5.1.a Purchase of a LeasePlan Used Vehicle ** *Description* LeasePlan processes your data in connection with your (possible) purchase of a LeasePlan used vehicle, trade-in of your vehicle, if applicable, and associated Services. This activity involves the conclusion of a purchase contract, the performance of Services and a financial transaction. This processing is necessary for the conclusion and performance of the contract, including LeasePlan’s creditworthiness assessment, acceptance and preliminary checks. *Personal data processed for these purposes* For this purpose, LeasePlan processes data relating to your name, gender, job title, contact details (including your email address, telephone number, company name), information relating to the vehicle trade-in and any details necessary to complete the transaction, including current account details. *Disclosure of data to third parties*LeasePlan may share this information with parties involved in the trade-in or with financial service providers. See also section ‘[Sharing data with third parties’](targetSelf:#Paragraph14).4.5.2 CONTACT DETAILS OF THE BUYER **4.5.2.a Notifications.** *Description* LeasePlan collects your data when you contact us via one of our online contact forms (or when you provide information in one of our stores), for example when you send us questions, suggestions, ratings or complaints or when you request a quote for our services. We may contact you in connection with the possible purchase of a vehicle. This processing is carried out because it is necessary for the performance of the contract you have entered into with LeasePlan or on the basis of your consent. *Personal data processed for these purposes* For these purposes we collect your name, gender, job title and (business) contacts, including your email address, telephone number, company name and any other information you may have provided to us in the open-question fields of the contact form where, for example, you may ask us questions, make suggestions, ratings or complaints. *Disclosure of data to third parties* See section ‘[Sharing data with third parties’](targetSelf:#Paragraph14). **4.5.2.b Surveys or Other Marketing Communications** *Description* LeasePlan processes your personal data when you complete the satisfaction surveys relating to the Services, in relation to which we process your data on the basis of a legitimate interest. With your consent or on the basis of LeasePlan’s legitimate interest, you may receive commercial communications, updates on LeasePlan’s present and future events, special offers, happenings, products and services. For surveys or commercial communications, LeasePlan contacts you by email or by sending newsletters / brochures / magazines (by postal service). To understand what you are interested in, LeasePlan may use manual or automated tools to analyse your personal data. If you no longer wish to receive surveys or commercial communications, you may contact LeasePlan using this [form](targetSelf:https://app-eu.onetrust.com/app/#/webform/204d5d03-adf8-4c9d-a105-0ad329845acf). *Personal data processed for these purposes* For this purpose, LeasePlan collects your name, address, email address and topics of interest to you (as stated by you). *Disclosure of data to third parties* See section ‘[Sharing data with third parties’](targetSelf:#Paragraph14). 4.5.3 LEASEPLAN BUSINESS PURPOSES **4.5.3.a Management reporting** *Description* LeasePlan processes any personal data acquired for various internal business purposes, on the basis of LeasePlan’s legitimate interest in the processing of such data, such as data analysis, checks, development of new products, enhancement, improvement or modification of websites and services, for the purpose of identifying usage trends, assessing the effectiveness of promotional campaigns, as well as carrying out and expanding business operations. To facilitate your use of our online services or your requests, LeasePlan may analyse the data it collects when you use digital pages and associate them with information collected via cookies. For example, to better understand which digital channel (Google search engine, email, social media) or IT tool you prefer (desktop, tablet or mobile phone), we may optimize or limit our communication or marketing activities by channel or IT tool. *Personal data processed for these purposes* For this purpose, LeasePlan may process your name, email address, IP address, gender, date of birth, place of residence, postcode and any other information described in this Privacy Statement or otherwise provided by you, where required, for one of the purposes stated in the preceding paragraph. *Disclosure of collected data to third parties* See section ‘[Sharing data with third parties’](targetSelf:#Paragraph14). **4.5.3.b Compliance with Legislation and Statutory Obligations and Protection of LeasePlan’s Assets and Rights ** *Description* To comply with legal provisions or when we have a legitimate interest, your personal data may be processed by LeasePlan, as follows: (a) pursuant to applicable legislation, including enforcement laws of countries other than your country of residence and recommended industry practices (e.g. counterparty due diligence, anti-money laundering and anti-terrorist financing and other offences); (b) in compliance with legal procedures; (c) in order to meet the demands of public and state authorities, including those of countries other than your country of residence; (d) in order to apply LeasePlan’s applicable conditions and policies; (e) in order to protect LeasePlan’s transactions; (f) in order to protect your rights, privacy, security or property, those of LeasePlan or of any third parties; (g) in order to allow LeasePlan to use any available remedies or contain any damage suffered. *Personal data processed for these purposes* For this purpose, LeasePlan processes data relating to the name, contact details, date, place and country of birth, of the beneficiary / beneficial owner of the company; LeasePlan may also process the name, address, date, place and country of birth of the person(s) representing the company before LeasePlan; your correspondence with LeasePlan, your use of the Services and any other information specified in this Privacy Statement, where required, for one of the purposes stated in the preceding paragraph.*Disclosure of data to third parties*If required by law or industry best practices to which LeasePlan is subject, your personal data may be disclosed to regulatory institutions, tax authorities and judicial bodies. See also section ‘[Sharing data with third parties’](targetSelf:#Paragraph14).

4.6 DATA PERTAINING TO PROFESSIONAL BUYERS OF USED VEHICLES (Traders)

4.6.1 REGISTRATION AND PURCHASE **4.6.1.a Registration as a professional trader** *Description* In order to purchase a LeasePlan used vehicle at an auction or via one of our vehicle resale websites, traders must be registered as professional dealerships. Such processing is carried out on the basis of LeasePlan’s legitimate interest (and on the provision of the Services regulated by the contract, including credit creditworthiness assessment, acceptance and verification), or on the basis of a legal obligation. *Personal data processed for these purposes* For this purpose, LeasePlan processes data relating to your name, contact details (including email address and telephone number), identity document and information relating to your company including Chamber of Commerce documents and V.A.T. certificate. *Disclosure of collected data to third parties* See section ‘[Sharing data with third parties’](targetSelf:#Paragraph14). **4.6.1.b Purchase of a LeasePlan Used Car.** *Description* LeasePlan ill processes your information in relation to your possible purchase of used cars from LeasePlan (referred to as LeasePlan Occasion) and other related Services through a purchase auction or through the vehicle resale website. This includes the conclusion of the purchase contract, delivery and settlement of the payment transaction. This processing is carried out on the basis of a legitimate interest (and on the provision of the Services governed by the purchase contract). *Personal data processed for these purposes* For this purpose, LeasePlan processes data relating to your name, contact details (including email address and telephone number), identity document and information relating to your company including Chamber of Commerce documents and V.A.T. certificate, which are necessary information to complete the purchase, including bank account details. *Disclosure of collected data to third parties* See section ‘[Sharing data with third parties’](targetSelf:#Paragraph14). 4.6.2 CONTACT DETAILS OF TRADERS **4.6.2.a Notifications** *Description* LeasePlan collects your data when you contact us via one of our online contact forms (or provide us with information in one of our stores), for example when you send us questions, suggestions, ratings or complaints or when you request a quote for our Services. We may contact you in connection with the possible purchase of a vehicle. Such processing is carried out on the basis of LeasePlan’s legitimate interest (and on the provision of the Services governed by the contract with the Dealer) or on the basis of your consent. *Personal data processed for these purposes* For these purposes, we collect your name, (business) contacts, your correspondence with LeasePlan relating to your questions / requests and any other personal information you provide to us and/or information that needs to be adequately addressed. *Disclosure of data to third parties* See section ‘[Sharing data with third parties’](targetSelf:#Paragraph14). **4.6.2.b Surveys or other marketing communications** *Description* LeasePlan processes your personal data when you complete the satisfaction survey relating to the Services, in regard of which we process your data on the basis of a legitimate interest. With your consent or on the basis of LeasePlan’s legitimate interest, you may receive commercial communications, updates on LeasePlan’s present and future events, special offers, happenings, products and services. For surveys or commercial communications, LeasePlan contacts you by email or by sending newsletters / brochures / magazines (by postal service). If you no longer wish to receive surveys or commercial communications, you may contact LeasePlan using this [form](targetSelf:https://app-eu.onetrust.com/app/#/webform/204d5d03-adf8-4c9d-a105-0ad329845acf). *Personal data processed for these purposes* For this purpose, LeasePlan collects your name, address, email address and topics of interest to you (as stated by you).*Disclosure of data to third parties* See section ‘[Sharing data with third parties’](targetSelf:#Paragraph14). 4.6.3 LEASEPLAN BUSINESS PURPOSES **4.6.3.a Management reporting** *Description* LeasePlan processes any personal data acquired for various internal business purposes, on the basis of LeasePlan’s legitimate interest in the processing of such data, such as data analysis, checks, development of new products, enhancement, improvement or modification of the website and Services, for the purpose of identifying usage trends, assessing the effectiveness of promotional campaigns, as well as carrying out and expanding business operations. To facilitate your use of our online services or applications, LeasePlan may analyse the data it collects when you use digital pages and associate them with information collected via cookies. For example, to better understand which digital channel (Google search engine, email, social media) or the IT tool you prefer (desktop, tablet or mobile phone), we may optimize or limit our communication or marketing activities by channel or IT tool. *Personal data processed for these purposes* For this purpose, LeasePlan may process your name, IP address, gender, date of birth, place of residence, postcode, and other information specified in this Privacy Statement or provided by you, as necessary for the purposes described above.*Disclosure of collected data to third parties* See section ‘[Sharing data with third parties’](targetSelf:#Paragraph14). **4.6.3.b Compliance with Legal Provisions and Obligations and Protection of LeasePlan’s Assets and Rights. ** *Description* To comply with legal provisions or when we have a legitimate interest, your personal data may be processed by LeasePlan, as follows: (a) pursuant to applicable legislation, including enforcement laws of countries other than your country of residence and recommended industry practices (e.g. counterparty due diligence, anti-money laundering and anti-terrorist financing and other offences); (b) in compliance with legal procedures; (c) in order to meet the demands of public and state authorities, including those of countries other than your country of residence; (d) in order to apply LeasePlan’s applicable conditions and policies; (e) in order to protect LeasePlan’s transactions; (f) in order to protect your rights, privacy, security or property, those of LeasePlan or of any third parties; (g) in order to allow LeasePlan to use any available remedies or contain any damage suffered. *Personal data processed for these purposes* For this purpose, LeasePlan processes data relating to the name, contact details, date, place and country of birth, of the beneficiary / beneficial owner of the company; LeasePlan may also process the name, address, date, place and country of birth of the person(s) representing the company before LeasePlan; your correspondence with LeasePlan, your use of the Services and any other information specified in this Privacy Statement, where required, for one of the purposes stated in the preceding paragraph. *Disclosure of data to third parties* If required by law or industry best practices to which LeasePlan is subject, your personal data may be disclosed to regulatory institutions, tax authorities and judicial bodies. See section ‘[Sharing data with third parties’](targetSelf:#Paragraph14).

4.7 DATA PERTAINING TO SUPPLIERS

4.7.1 SUPPLIER ACCOUNT MANAGEMENT **4.7.1.a Provision, Management and Administration of the Supplier Account** *Description* LeasePlan collects your personal information to carry out the ordinary management and administration of the Supplier’s accounts, such as contractual management and communications relating to the main news and information regarding the services rendered and other information necessary in relation to the Supplier’s contract and accounts. This processing is carried out on the basis of the contract LeasePlan has in place with you or on the basis of a legal obligation. *Personal data processed for these purposes* For this purpose, LeasePlan may process the Supplier’s company contact details and access data to its accounts. *Disclosure of collected data to third parties* See section ‘[Sharing data with third parties’](targetSelf:#Paragraph14). **4.7.1.b Notifications** *Description* You may contact LeasePlan by various means (for example, by email, telephone or through the website). In such circumstances, LeasePlan uses your personal data to answer your questions / requests. LeasePlan may contact you, for example, for communications relating to, among other things, the routine management and administration of your Supplier account. This processing is carried out on the basis of the contract that LeasePlan has in place with you or with your consent. *Personal data processed for these purposes* For this purpose, LeasePlan may process your name, your company contact details, correspondence with LeasePlan regarding questions / requests you submit, as well as any other personal data you provide or needed to adequately reply to your questions / requests.*Disclosure of collected data to third parties* See section ‘[Sharing data with third parties’](targetSelf:#Paragraph14). **4.7.1.c Surveys or other marketing communications** *Description* LeasePlan processes your personal data to send you satisfaction surveys in relation to which we process your data on the basis of a legitimate interest. With your express consent or on the basis of LeasePlan’s legitimate interest, you may receive commercial communications, updates on LeasePlan’s present and future events, special offers, happenings, products and services. LeasePlan sends you such surveys in regular emails or email messages to ask for your opinion on our communications and reports. LeasePlan may also send you newsletters / brochures / magazines (mailing). If you no longer wish to receive surveys or commercial communications, you may contact LeasePlan using this [form](targetSelf:https://privacyportal-eu-cdn.onetrust.com/dsarwebform/396c853c-7bbe-43bb-9c80-0001fd327955/204d5d03-adf8-4c9d-a105-0ad329845acf.html). *Personal data processed for these purposes* For this purpose, LeasePlan collects your name and your company details.*Disclosure of collected data to third parties* See section ‘[Sharing data with third parties’](targetSelf:#Paragraph14). 4.7.2 LEASEPLAN PREMISES **4.7.2.a Access to LeasePlan’s Premises and Security Checks** *Description* In order to ensure adequate access and security checks, LeasePlan may process your personal data when you visit our company premises, based on LeasePlan’s legitimate interest in processing such data (protection and security of our assets). *Personal data processed for these purposes* For this purpose, LeasePlan collects your name, your contact details and the name of the person you are meeting within the premises. *Disclosure of collected data to third parties* See section ‘[Sharing data with third parties’](targetSelf:#Paragraph14). 4.7.3 LEASEPLAN BUSINESS PURPOSES **4.7.3.a Management reporting** *Description* LeasePlan processes any personal data acquired for various internal corporate purposes, on the basis of LeasePlan’s legitimate interest in the processing of such data, such as data analysis, checks, development of new products, enhancement, improvement or modification of the website and Services, for the purpose of identifying usage trends, assessing the effectiveness of promotional campaigns, as well as carrying out and expanding business operations. To facilitate your use of our online services or your requests, LeasePlan may analyse the data it collects when you use digital pages and associate them with information collected via cookies. For example, to better understand which digital channel (Google search engine, email, social media) or IT tool you prefer (desktop, tablet or mobile phone), we may optimize or limit our communication or marketing activities by channel or IT tool. *Personal data processed for these purposes* For this purpose, LeasePlan may process your name, email address, IP address, gender, date of birth, place of residence, postcode, and other information specified in this Privacy Statement or provided by you, as necessary for the purposes described above. *Disclosure of collected data to third parties* See section ‘[Sharing data with third parties’](targetSelf:#Paragraph14). **4.7.3.b Compliance with Legal Provisions and Obligations and Protection of LeasePlan’s Assets and Rights ** *Description* To comply with legal provisions or when we have a legitimate interest, LeasePlan processes your personal data as appropriate or necessary, as follows: (a) pursuant to applicable legislation, including enforcement laws of countries other than your country of residence and recommended industry practices (e.g. counterparty due diligence, anti-money laundering and anti-terrorist financing and other offences); (b) in compliance with legal procedures; (c) in order to meet the demands of public and state authorities, including those of countries other than your country of residence; (d) in order to apply LeasePlan’s applicable conditions and policies; (e) in order to protect LeasePlan’s transactions; (f) in order to protect your rights, privacy, security or property, those of LeasePlan or of any third parties; and (g) in order to allow LeasePlan to use any available remedies or contain any damage suffered. *Personal data processed for these purposes* For this purpose, LeasePlan processes data relating to the name, contact details, date, place and country of birth, of the beneficiary / beneficial owner of the counterparty with whom LeasePlan entertains business relations. LeasePlan may also process the name, address, date, place and country of birth of the person(s) representing the company before LeasePlan; your correspondence with LeasePlan, the services you provide and any other information specified in this Privacy Statement, where required, for one of the purposes stated in the preceding paragraph.*Disclosure of data to third parties*Where required by law or industry best practices to which LeasePlan is subject, personal data may be disclosed to regulatory institutions, tax authorities and judicial bodies. See also section ‘[Sharing data with third parties’](targetSelf:#Paragraph14).

5. Disclosure of Personal Data to Third Parties

In addition to each of the above purposes, LeasePlan may also disclose data to third parties in the following cases:

Within the LeasePlan Group for the purposes described in this Privacy Statement.
− You may view the list and locations of the LeasePlan group companies at this link.
To third parties in charge of providing services on behalf of LeasePlan.
In order to provide you with our services, LeasePlan engages third-party service providers who support LeasePlan in providing rental services and other related services, such as dealerships, garages, body shops and suppliers of our driver safety training programmes. The third parties appointed by LeasePlan to provide such services are companies that also support LeasePlan in providing rental services, for example by supporting us in the management and maintenance of our IT infrastructures, security for access to our facilities. Dealerships or suppliers of (electric) vehicles may require the driver’s contact details to activate a personal account to be configured as a driver, otherwise the vehicle does not function.

LeasePlan also uses and disclose your personal information to third parties as necessary and appropriate when we have a legal obligation or legitimate interest to do so in the following cases:

To comply with applicable laws and regulations.

− This purpose may also concern laws applicable in countries other than your country of residence.

To cooperate with public government or regulatory authorities.
− To reply to inquiries or provide important information;
− These authorities may also be located in countries other than your country of residence.

To cooperate with law enforcement agencies.
− For example, when we reply to inquiries from law enforcement agencies or report information that we consider important.

On other legal grounds.
− To apply our general terms and conditions; and
− To protect our rights, privacy, security and the assets of LeasePlan, of its affiliates or yours.

For corporate affairs or commercial purposes.
− LeasePlan has a legitimate interest in disclosing or transferring your personal data to third parties in the event that there is a business reorganization, acquisition, sale, joint venture, assignment, transfer or other partial or total disposals of our contracts, assets or shares (including in relation to bankruptcies or similar proceedings). The third parties involved may, in such cases, be for example a purchasing party and its consultants.

6. International transfer of personal data

Due to the global dimension of LeasePlan and its Services, your personal information may be processed and stored in a country other than your country of residence. Some countries outside the European Union are recognized by the European Commission as countries that guarantee an adequate level of personal data protection according to EU standards (the complete list of these countries is available here.) For the transfer of data outside the European Union, to countries that the European Commission considers not to meet an adequate security level, LeasePlan applies suitable security measures through the adoption of its Binding Corporate Rules or under contractual arrangements put in place by LeasePlan. You may obtain a copy of the above rules by contacting us via the contact form.

7. Security Measures and Personal Data Retention Period

**Personal data security measures ** LeasePlan takes the necessary organizational, technical and administrative measures to protect your personal information within our organization.

Unfortunately, it is not possible to guarantee the absolute security of personal data disclosures and storage. If you find that your interaction with LeasePlan is not secure (for example, if you think the security of your LeasePlan accounts has been compromised), please report any problems immediately by contacting LeasePlan through this form.

**Personal data retention period ** LeasePlan retains your personal data for the period necessary to pursue the purposes specified in this Privacy Statement and compatibly with applicable legislation.

The criteria applied to establish the retention period include:

duration of your business relationship with LeasePlan (for example since the time you first rented a LeasePlan vehicle);
legal obligations to which LeasePlan is subject (for example certain laws require LeasePlan to retain your transaction data for a specified period of time before they can be deleted); or
if retention is advisable in light of our legal position (such as the statute of limitations, litigation or regulatory investigations).

8. Minors’ Privacy Protection

LeasePlan Services are not intended for individuals under the age of 18.

9. Your Rights and How to Contact LeasePlan

Your rights If you wish to modify, rectify, update or erase your personal data processed by LeasePlan, or if you wish to receive an electronic copy of your data in order to transfer them to third-party companies (for the purposes of your right to data portability based on applicable legislation), you may contact LeasePlan by filling out the following form. We reply in accordance with applicable legislation.

Your request must contain accurate information on the type of personal data under consideration. For security reasons, LeasePlan only accepts requests regarding data associated with the email address specified in the contact form, reserving the right to verify the applicant’s identity before accepting any requests. LeasePlan undertakes to accept your requests as soon as reasonably possible and, in any case, within the time limits established by law, if any.

Please note that LeasePlan may retain certain data for recordkeeping purposes and/or in order to complete any transactions that may have been initiated prior to your data rectification or erasure request. Furthermore, some data may remain within LeasePlan’s databases or records and not be erased.

Further information If you have any questions or complaints regarding this Privacy Statement, please contact LeasePlan by filling out the following form. Please do not include sensitive information in any email messages you send us, as email is not considered a secure communication tool.

Further EU information You may also:

Contact our privacy office by filling out the following form. Alternatively, you may contact our LeasePlan Corporation N.V. headquarters for the attention of the Data Protection Officer (DPO) at Gustav Mahlerlaan 360, 1082 ME Amsterdam, The Netherlands), or
File a complaint with your country’s privacy authority or that of the country in which a violation of the applicable privacy legislation has been alleged.

10. Changes to this Privacy Statement

LeasePlan reserves the right to change this Privacy Statement at any time. To find out the date of the latest changes made to this Privacy Statement, please check the caption “Latest update” at the top of this report. Any changes to this Privacy Statement take effect from the time of publication of the updated Privacy Statement on the Services.

Click here to view and download the Global Privacy Statement.