Wagonex Privacy Policy
Thank you for taking the time to read our Privacy Policy.
Wagonex Limited, whose registered office is at Wagonex Limited, Tramshed Tech, Pendyris Street, Cardiff, CF11 6BH and company number 10312289 (“Wagonex”, “we”, “us”, “our”) respects the privacy of visitors to our website and is committed to the protection of their personal information.
The purpose of this Privacy Statement is to tell you about the kinds of data we obtain about you, how we use it, and why. The sections of this Privacy Statement below explain more about how your personal data will be gathered, protected, shared and for what purposes we will use that personal data.
Introduction
This policy works in conjunction with our Terms of Website Use and Cookies Policy. Should you visit our website, become a customer, or apply to be a customer, this policy will apply to you.
Wagonex is the data controller and data processor, within these roles we are responsible for collecting and safely storing your personal data. If you have any concerns regarding your data or our use of it, you can contact us:
Phone: 020 3002 0976
Email: help@wagonex.com
Post: Wagonex Limited, Tramshed Tech, Pendyris Street, Cardiff, CF11 6BH
The Information Commissioner’s Office (ICO) is the UK regulator for Data Protection Concerns, you can contact them anytime via their website (www.ico.org.uk). We would, however, prefer the opportunity to address your concerns before involving the ICO.
Where you request a vehicle subscription, your data will be shared with our vehicle suppliers in order to fulfil your request. In the event data is shared with these third-party companies, they will also become the data controller and processor. We would also recommend reading their privacy notices. Wagonex cannot take any responsibility for what is included in their notices.
Binding nature
By accessing and using the Site and our services, you agree and consent to the collection, transfer, processing, use and disclosure of your personal data as outlined in this Privacy Statement.
Collection of Information
Some of our services require registration. Registration is optional but if you choose to withhold any personal data requested by us when registering, please note that it may not be possible for you to gain access to certain parts of the Site or for us to provide information or services that you have requested. This Site is not intended or designed to attract anyone under the age of 18.
Data integrity
Wagonex limits the collection and processing of personal data to what is necessary to fulfil the intended purpose of requesting such data. We shall take reasonable steps to ensure that any personal data collected is accurate, complete, and current.
Consent
We hereby notify you that we propose to collect and use your personal data in accordance with this Privacy Statement when you seek to register for a Wagonex service. You may request to delete your Wagonex account, or request your data be erased should you no longer wish for Wagonex to hold your personal data. Please note that if you have requested or taken out a vehicle subscription or lease, some data may need to be retained by Wagonex to comply with certain legal or regulatory requirements.
If you sign up to the Site you will be offered the opportunity to receive direct marketing communication, such as news, events or offers (also known as opting in). Where you have chosen not to opt in you will not receive any of these types of communications. If you decide to opt in but later change your mind, you will be able to opt out or unsubscribe from these communications at any time.
Anonymous Data we Collect
When you visit the Site, we do not collect any personal data about you without your permission, however we do collect anonymous information as detailed below. This information will only be collected where your computer or browser settings allows. This type of information allows us to monitor traffic on the Site, evaluate customer interest and perform other market research activities, such as surveying browsing habits on our site. This may include, but is not limited to, the following anonymous information:
IP addresses
Browser cookies
Geographic location
Demographic information
Device used
Browser used
Number of clicks
Number of site visits
We may also receive anonymous data from third party sites where you visit Wagonex via a link on another website.
This data is completely anonymised and cannot be tracked to any individual.
Use of IP address
Wagonex, or third party companies acting on behalf of Wagonex, may collect IP addresses for the purposes of systems administration and analyse the use of the Site.
We also may use IP addresses to identify users of the Site when we feel it is necessary to enforce compliance with the Site’s terms of use, or to protect our services, the Site or other users.
Use of Cookies
Wagonex uses cookies on this site to allow us to analyse its use and improve the experience for visitors to the Site. We also use marketing cookies to help us measure the success of our campaigns, find more relevant audiences and create better performing advertisements and promotions. Cookies are tiny files, composed of a string of letters and numbers, placed on your computer by web page servers. More information can be in our Cookie Policy.
Personal Data we Collect
We collect the following types of personal information about you so we can complete the activities explained in the "How and why we use your information" section below.
Information we collect:
Personal data collected and stored before sign up:
Email Address and Telephone number (if you contact us)
Communications between yourself and Wagonex (if you contact us)
Additional Personal data collected and stored at sign up:
Full Name
Email address
Telephone Number
Additional personal data collected and stored upon vehicle request:
Title
Date of Birth
Address (plus 3 years of address history)
Driving Licence
Identity documents (e.g. passport or address verification)
Photograph
Employment Details (such as employer and income)
Credit Score
insolvency/Bankruptcy Records
Company Director Records
County Court Judgement (CCJ) history
Sanctions database results
Politically Exposed Person (PEP) database results
Additional data collected and stored where insurance is requested:
Gender
DVLA records
Driving convictions history
Claims history
Family, lifestyle and social circumstances, such as marital status, homeowner status and dependants
Details of any Named Drivers (By providing us with personal information about others, you certify that you have permission to provide that information to Wagonex and our insurance provider for the purpose of providing insurance)
It is important to note that the above list may not be exhaustive, for example if additional information is requested on an adhoc basis to assist us in providing our services to you.
How we collect personal information
Most personal data collected will be requested from you when you sign up to use our services, and apply for a vehicle.
We may also collect personal information from various sources including from publicly available sources. We also collect information from other persons or organisations, for example:
Credit reference and/or fraud prevention agencies
Law enforcement agencies
Insurance industry registers and databases used to detect and prevent insurance fraud
We may also use legal public sources such as the electoral roll and other third-party sources such as credit reference agencies to obtain information about you, for example to verify your identity or check your credit history.
How long will we keep your information
We will only hold your information for as long as is necessary to administer your vehicle subscription or lease, any insurance policy you purchase, manage our business or in order to comply with legal or regulatory requirements.
Use of Your Personal Data
Providing our Service
We will use your personal data to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and services that you request from us. To provide our services your personal data may be used for the following:
To determine your suitability for a vehicle, and insurance if selected
To keep in touch, keep you up to date and provide information on a service you have requested from us or expressed an interest in -this may include sending you messages, contacting you by telephone, providing updates, security alerts, and account notifications
To establish and maintain your contract with the vehicle provider
To establish and maintain your contract with the insurance provider where insurance is purchased with your vehicle
To establish and facilitate automated payments and refunds where appropriate for your vehicle and any relevant insurance policy
To verify your identity
To run third party background checks preventing financial crime to meet our legal obligations
To run credit score and credit history checks
To track sales and receive remuneration from our partners and suppliers
As the vehicles are provided by third party suppliers, when a vehicle package is selected, your details will be passed to that vehicle supplier to allow them to carry out their obligations and provide you that service. Where insurance is selected with your vehicle, your details will also be passed to our insurance provider. Further details on this is given under the Sharing Your Information with Third Parties section further down.
Marketing Use
We may use data collected for research analytics purposes to help develop and improve our products and services and to provide customer service training. This data may also be used to personalise and customise your experience based on your interactions with the website.
To help improve and promote our services, and the services of our partners, we may use your data:
To analyse characteristics and preferences to show you promotional messages, marketing, advertising, and other information that we think might be of interest to you show, personalise, measure, and improve our advertising on advertising platforms
To carry out analysis and market research
To tailor advertising messages to you, on this and other websites, based on data we have collected or created
To help us understand if and how our marketing works
Where you have provided consent (also known as opting in), we may also use your personal data to provide you with information about other services we offer that are similar to those that you have already purchased or enquired about; and to provide you, or permit selected third parties to provide you, with information about services we feel may interest you.
Where you have opted in to receive marketing communications your data may be used to:
Send you direct promotional and marketing messages or information you may find interesting
To let you know about our services and promotions by email, social media (e.g., Facebook), SMS and using push notifications (where you agree).
Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Wagonex or its third-party partners
Invite you to events and relevant opportunities
Sharing Your Information with Third Parties
When you provide personal data to Wagonex, it will be accessible to some of Wagonex’s business partners, such as companies we retain to fulfil requests for information or provide assistance on specific services. Wagonex requires third parties to whom it discloses personal data to protect personal data using substantially similar standards to those required by Wagonex. We also require that these third parties not use your personal data for any use that is not specifically authorised by Wagonex.
There may also be instances in which Wagonex is required to share your information with third parties who have not been retained by us (directly or indirectly), such as if we are required to do so because of an applicable law, court order or governmental regulation, or if such disclosure is otherwise necessary in support of a criminal or other legal investigation or proceeding.
Furthermore, in the event that Wagonex sells or buys any business assets or if Wagonex or substantially all of its assets are acquired by a third party, we may disclose your personal data to the prospective seller or purchaser. Entities receiving personal data under these conditions typically have privacy requirements that apply to their handling of your information. Personal data collected from you may also be transferred to a third party in the event that the business of the Site and the customer data connected with it is sold, assigned or transferred. In the event that such sale, assignment or transfer should occur, Wagonex would require the buyer, assignee or transferee to treat your information in accordance with this.
Sharing your Information with our Vehicle Suppliers
Wagonex acts as a credit broker, not a lender. The vehicles available on our website are provided by third party vehicle suppliers.
When you request a vehicle your data will be shared with that vehicle's supplier in order to review your suitability against their criteria, and fulfil your vehicle request.
When you take out a subscription or lease vehicle via Wagonex.com you are bound by the vehicle suppliers Terms and Conditions, as set out in their contract. You should read and review the vehicle supplier’s privacy notice as it outlines how they will process your personal data. Their privacy notice will be provided to you with your contract documentation. If you have any questions about their processing, you should contact the vehicle supplier directly. Wagonex cannot take any responsibility for what is included in their notices.
Sharing your Information with our Insurers
Where insurance is selected with your vehicle subscription, or if an insurance quote is requested, your data will be shared with our insurance provider in order to fulfil your request.
When you take our insurance with your vehicle, you are bound by the insurers Terms and Conditions. These can be viewed alongside our Insurance Terms of Business here. We would also recommend reading the insurers’ privacy notices. Wagonex cannot take any responsibility for what is included in their notices.
Sharing your Information for Marketing Purposes
Advertising partners:
We may share some of your data to our partners who use it to help us target our advertising to you and others. This means we try to show you adverts that we think are relevant to you, try to stop showing you adverts that are not or try to find audiences that are similar to you.
Analytics suppliers:
We may share data about your visit with analytics suppliers who help us improve our services for you and our business. This data is shared in a way that does not directly identify you.
Sharing your Information for Administrative Purposes
Wagonex may share your data to third party service providers to help with the administration and fulfilment of any vehicle requests. For example:
Payment Providers - to facilitate payments for the vehicle and insurance
Platform and Technical Development Resource - To from time to time assist in the building, improving and maintaining our platform/website
Credit Check Providers - To run a credit check to determine your suitability for a vehicle
Identity Check Providers - To help us verify your identity
Fraud Prevention Agencies - Such as sanctions databases or insurance industry registers and databases used to detect and prevent financial crime and/or insurance fraud
Monitoring of communications
We may keep a record of any communication (email, phone calls, online chat etc.) between you and Wagonex. We do this for regulatory compliance, self-regulatory practices, training of staff and crime prevention.
Transfer of personal data outside the UK
The personal data that you provide to Wagonex may be shared with other companies within Wagonex’s partners described above. This may mean that your personal data may be transferred to Wagonex affiliates at, and stored at, a destination outside the European Economic Area.
By submitting your personal data, you agree to this transfer, storing or processing. Other Wagonex affiliates that may receive your personal data will abide by substantially similar privacy requirements relating to your personal data. Other Wagonex affiliates to whom we provide your personal data may use your personal data in the same way as we may. We strive to protect personal data entrusted to us no matter what country the information is stored in or transferred to, and have appropriate procedures in place to help ensure the security of your personal data.
Security of Your Information.
We use appropriate technical, administrative and physical safeguards to protect data that you provide to us from loss, misuse or alteration. Despite these safeguards, it is not possible to guarantee the absolute security of personal data. Internet transmissions, particularly email transmissions, are never 100% secure or error-free. We also caution you to guard your own computer and password against unauthorised access or use by others.
Links to Other Sites.
This Privacy Statement applies only to the Site and not to third party websites. The Site may contain links or references to other web sites maintained by third parties over which Wagonex has no control. Similarly, the Site may be accessed via third party links or websites over which Wagonex has no control. While we aim to ensure that such websites are of a high standard, we cannot guarantee the privacy standards of web sites to which we link. This Privacy Statement is not intended to be applicable to any linked, non-Wagonex owned or operated site. Please ensure that you check the legal and privacy statement posted on each website you link to before entering any personal data.
Your data protection rights
You have certain legal rights under UK data protection law and regulations, summarised as follows:
The right to be informed about our data processing activities, including through Privacy Notices such as this.
The right of access to the personal information we hold about you. To request a copy of this information you must make a data subject access request in writing to us.
The right of rectification. You may ask us to correct any inaccurate or incomplete data, which must be actioned by us without undue delay.
The right to erasure and to restrict processing. You have the right to have your personal data erased and to prevent processing except where we have a legal or regulatory obligation to process your personal information. You should bear in mind that by exercising this right you may hinder or prevent our ability to provide products and services.
The right to data portability. On your request, we will provide you with your personal data in a structured format.
The right to object. You have particular rights in relation to automated decision making and profiling to reduce the risk that a potentially damaging decision is taken without human intervention. You can object to your personal data being used for profiling, direct marketing or research purposes.
You can exercise these rights at any time by contacting us at help@wagonex.com.
Withdrawal of Consent
Where you have provided your specific consent to the certain use of personal data, most notably in the form of opting into marketing communications, you may withdraw that consent by contacting us at help@wagonex.com.
Updates to Wagonex Privacy Statement.
Wagonex may update this Privacy Statement from time to time. If the changes are material, we may post a notice on the Site but we may not always update you. We encourage you to review our Privacy Statement periodically so that you are aware of any changes. Your continued use of the Site constitutes your agreement to the Privacy Statement and any updates.
How to make a complaint
We hope you will be satisfied with the way we handle your information, however If you wish to make a complaint about how we hold or use your data, please contact us at help@wagonex.com.
If you are dissatisfied with how we deal with your complaint you have the right to complain to the Financial Ombudsman Service (FOS). The usual time limit for referrals to the FOS is six months from the date we issue our final response.
The Financial Ombudsman may be contacted by:
Telephone: 0300 123 9 123 or 0800 023 4567
Email: complaint.info@financial-ombudsman.org.uk
Post: Harbour Exchange Square, London E14 9SR
Further information is available regarding the FOS at Web: https://www.financial-ombudsman.org.uk/default.htm
Where your complaint is regarding an issue concerning your personal data, you may also refer the matter to the Information Commissioner. For more information please visit www.ico.org.uk.
How to Contact Us.
If you have any queries about how we use your information, want to access the personal data we hold on you (subject access request) or request the erasure of your data (right to be forgotten) please contact us at help@wagonex.com or calling us on 02030 020 976.
