Privacy policy

Privacy policy

Website Privacy notice
We are Kapitalleasing Ltd. We’re a company registered in England and Wales with company
number 14262740, whose registered address is at 86-90 Paul Street, London, England EC2A
4NE. In this privacy notice we will refer to ourselves as ‘we’, ‘us’ or ‘our’.
You can get hold of us in any of the following ways:
(a) by phoning us at 0161 242 1215; or
(b) by e-mailing us at kapitalleasing@outlook.com; or
(c) by writing to us at 3 Piccadilly, Manchester, M1 3BN.
We take the privacy, including the security, of personal information we hold about you
seriously. This privacy notice is designed to inform you about how we collect personal
information about you and how we use that personal information. You should read this
privacy notice carefully so that you know and can understand why and how we use the
personal information we collect and hold about you.
We do not have a Data Protection Officer, but if you have any questions about this privacy
notice or issues arising from it then you should contact Stephen Leader, who is responsible
for matters relating to data protection at our organisation, including any matters in this
privacy notice. You can contact them using the details set out above.
We may update this privacy notice from time to time. This version was last updated on the
24th of April 2023.

1. Key Definitions
   The key terms that we use throughout this privacy notice are defined below, for ease:
   Data Controller: under UK data protection law, this is the organisation or person responsible
   for deciding how personal information is collected and stored and how it is used.
   Data Processor: a Data Controller may appoint another organisation or person to carry out
   certain tasks in relation to the personal information on behalf of, and on the written
   instructions of, the Data Controller. (This might be the hosting of a site containing personal
   data, for example, or providing an email marketing service that facilitates mass distribution of
   marketing material to a Data Controller’s customer-base.)
   Personal Information: in this privacy notice we refer to your personal data as ‘personal
   information’. ‘Personal information’ means any information from which a living individual can
   be identified. It does not apply to information which has been anonymised.
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   Special Information – certain very sensitive personal information requires extra protection
   under data protection law. Sensitive data includes information relating to health, racial and
   ethnic origin, political opinions, religious and similar beliefs, trade union membership, sex life
   and sexual orientation and also includes genetic information and biometric information.
2. Details of personal information which we collect and hold about you
   2.1 Set out below are the general categories and in each case the types of personal
   information which we collect, use and hold about you:
   General Category Types of Personal Data in that category
   Identity Information This is information relating to your identity such as your name
   (including any previous names and any titles which you use),
   gender, marital status and date of birth
   Contact Information This is information relating to your contact details such as e-mail
   address, addresses, telephone numbers
   Marketing Information This is information relating to your marketing and communications
   preferences.
   Website, Device and
   Technical Information
   This is information about your use of our website and technical
   data which we collect (including your IP address, the type of
   browser you are using and the version, the operating system you
   are using, details about the time zone and location settings on the
   device and other information we receive about your device)
3. Details of special information which we collect and hold about you
   3.1 Special information is explained in section 1 above. We do not collect or hold any
   special information about you.
   3.2 We do not collect information from you relating to criminal convictions or offences.
4. Details of how and why we use personal information
   4.1 We are only able to use your personal information for certain legal reasons set out in
   data protection law. There are legal reasons under data protection law other than
   those listed below, but in most cases, we will use your personal information for the
   following legal reasons:
   (a) Contract Reason: this is in order to perform our obligations to you under a
   contract we have entered into with you;
   (b) Legitimate Interests Reason: this is where the use of your personal
   information is necessary for our (or a third party’s) legitimate interests, so
   long as that legitimate interest does not override your fundamental rights,
   freedoms or interests.
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   (c) Legal Obligation Reason: this is where we have to use your personal
   information in order to perform a legal obligation by which we are bound;
   and
   (d) Consent Reason: this is where you have given us your consent to use your
   personal information for a specific reason or specific reasons.
   4.2 As explained in section 3 above, there are more sensitive types of personal data which
   require higher levels of protection. Where we process such sensitive types of personal
   data we will usually do this in the following circumstances:
   (a) We have your explicit consent;
   (b) Where it is necessary in relation to legal claims;
   (c) Where you have made the personal data public.
   4.3 So that we are able to provide you with services, we will need your personal
   information. If you do not provide us with the required personal information, we may
   be prevented from supplying the services to you.
   4.4 It is important that you keep your personal information up to date. If any of your
   personal information changes, please contact us as soon as possible to let us know. If
   you do not do this then we may be prevented from supplying the services to you (for
   example, if you change your contact information and do not tell us, then we will be
   unable to serve you).
   4.5 Where we rely on consent for a specific purpose as the legal reason for processing
   your personal information, you have the right under data protection law to withdraw
   your consent at any time. If you do wish to withdraw your consent, please contact us
   using the details set out at the beginning of this notice. If we receive a request from
   you withdrawing your consent to a specific purpose, we will stop processing your
   personal information for that purpose, unless we have another legal reason for
   processing your personal information, in which case, we will confirm that reason to
   you.
   4.6 We have explained below the different purposes for which we use your personal
   information and, in each case, the legal reason(s) allowing us to use your personal
   information. Please also note the following:
   (a) if we use the Legitimate Interests Reason as the legal reason for which we can
   use your personal information, we have also explained what that legitimate
   interest is; and
   (b) for some of the purposes we may have listed more than one legal reason on
   which we can use your personal information, because the legal reason may be
   different in different circumstances. If you need confirmation of the specific legal
   reason that we are relying on to use your personal data for that purpose, please
   contact us using the contact details set out at the start of this privacy notice.
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   Purpose Legal Reason(s) for using the personal
   information
   To enrol you as a customer Contract Reason
   To manage our contract with you and to
   notify you of any changes
   Contract Reason
   Legal Obligation Reason
   To comply with audit and accounting matters Legal Obligation Reason
   To ensure the smooth running and correct
   operation of our website
   Legitimate Interests Reason (to ensure our
   website runs correctly)
   To understand how customers and visitors to
   our website use the website and interact with
   it via data analysis
   Legitimate Interests Reason (to improve and grow
   our business, including our website, and to
   understand our customer’s needs, desires and
   requirements)
   4.7 Sometimes we may anonymise personal information so that you can no longer be
   identified from it and use this for our own purposes. In addition, sometimes we may
   use some of your personal information together with other people’s personal
   information to give us statistical information for our own purposes. Because this is
   grouped together wither other personal information and you are not identifiable from
   that combined data we are able to use this.
   4.8 Under data protection laws we can only use your personal information for the
   purposes we have told you about, unless we consider that the new purpose is
   compatible with the purpose(s) which we told you about. If we want to use your
   personal information for a different purpose which we do not think is compatible with
   the purpose(s) which we told you about then we will contact you to explain this and
   what legal reason is in place to allow us to do this.
5. Details of how we collect personal information and special information
   5.1 We usually collect identity information and contact information directly from you
   when you fill out a form or contact us by e-mail, telephone, in writing or otherwise.
   5.2 We may receive some of your personal information from third parties or publicly
   available sources. This includes:
   (a) Identity information and contact information from publicly available sources
   such as Companies House;
   (b) Website, Device and Technical Information from third parties such as
   analytics providers (like Google);
   5.3 We may also receive Website, Device and Technical Information automatically from
   technologies such as cookies which are installed on our website.
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6. Details about who personal Information may be shared with
   6.1 We may need to share your personal information with other organisations or people.
   These organisations include:
   (a) Third parties who are not part of our group. These may include:
   (i) Suppliers: such as IT support services, payment providers,
   administration providers, marketing agencies who are based in the
   UK;
   (ii) Government bodies and regulatory bodies: such as HMRC, fraud
   prevention agencies who are based in the UK;
   (iii) Our advisors: such as lawyers, accountants, auditors, insurance
   companies who are based in the UK;
   (iv) Our bankers who are based in the UK;
   (v) Credit Reference Agencies who are based in the UK;
   (b) any organisations which propose to purchase our business and assets in
   which case we may disclose your personal information to the potential
   purchaser.
   6.2 Depending on the circumstances, the organisations or people who we share your
   personal information with will be acting as either Data Processors or Data Controllers.
   Where we share your personal information with a Data Processor we will ensure that
   we have in place contracts, which set out the responsibilities and obligations of us and
   them, including in respect of security of personal information.
   6.3 We do not sell or trade any of the personal information which you have provided to
   us.
7. Details about transfers to countries outside of the EEA
   7.1 We do not transfer your personal information outside of the EEA.
8. Details about how long we will hold your personal information
   8.1 We will only hold your personal data for as long as is necessary. How long is necessary
   will depend upon the purposes for which we collected the personal information (see
   section 4 above) and whether we are under any legal obligation to keep the personal
   information (such as in relation to accounting or auditing records or for tax reasons).
   We may also need to keep personal information in case of any legal claims.
   8.2 You can contact us (using the details at the beginning of this notice) to request a copy
   of our retention policy which sets out how long different types of personal data will
   be kept for.
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9. Automated decision making
   9.1 ‘Automated decision making’ is where a decision is automatically made without any
   human involvement. Under data protection laws, this includes profiling. ‘Profiling’ is
   the automated processing of personal data to evaluate or analyse certain personal
   aspects of a person (such as their behaviour, characteristics, interests and
   preferences).
   9.2 Data protection laws place restrictions upon us if we carry out automated decision
   making (including profiling) which produces a legal effect or similarly significant effect
   on you.
   9.3 We do not carry out automated decision making (including profiling) which produces
   a legal effect or similarly significant effect on you. If we decide to do this then we will
   notify you and we will inform you of the legal reason we are able to do this.
10. YOUR RIGHTS UNDER DATA PROTECTION LAW
    10.1 Under data protection laws you have certain rights in relation to your personal
    information, as follows:
    (a) Right to request access: (this is often called ‘subject access’). This is the right
    to obtain from us a copy of the personal information which we hold about
    you. We must also provide you with certain other information in response
    to these requests to help you understand how your personal information is
    being used.
    (b) Right to correction: this is the right to request that any incorrect personal
    data is corrected and that any incomplete personal data is completed.
    (c) Right to erasure: (this is often called the “right to be forgotten”). This right
    only applies in certain circumstances. Where it does apply, you have the
    right to request us to erase all of your personal information.
    (d) Right to restrict processing: this right only applies in certain circumstances.
    Where it does apply, you have the right to request us to restrict the
    processing of your personal information.
    (e) Right to data portability: this right allows you to request us to transfer your
    personal information to someone else.
    (f) Right to object: you have the right to object to us processing your personal
    information for direct marketing purposes. You also have the right to object
    to us processing personal information where our legal reason for doing so is
    the Legitimate Interests Reason (see section 4 above) and there is something
    about your particular situation which means that you want to object to us
    processing your personal information. In certain circumstances you have
    the right to object to processing where such processing consists of profiling
    (including profiling for direct marketing).
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    10.2 In addition to the rights set out in section 10.1, where we rely on consent as the legal
    reason for using your personal information, you have the right to withdraw your
    consent. Further details about this are set out in section 4.5.
    10.3 If you want to exercise any of the above rights in relation to your personal
    information, please contact us using the details set out at the beginning of this notice.
    If you do make a request then please note:
    (a) we may need certain information from you so that we can verify your
    identity;
    (b) we do not charge a fee for exercising your rights unless your request is
    unfounded or excessive; and
    (c) if your request is unfounded or excessive then we may refuse to deal with
    your request.
11. Marketing
    11.1 You may receive marketing from us about similar goods and services, where either
    you have consented to this, or we have another legal reason by which we can contact
    you for marketing purposes.
    11.2 However, we will give you the opportunity to manage how or if we market to you. In
    any e-mail which we send to you, we provide a link to either unsubscribe or opt-out,
    or to change your marketing preferences. To change your marketing preferences,
    and/or to request that we stop processing your personal information for marketing
    purposes , you can always contact us on the details set out at the beginning of this
    notice.
    11.3 If you do request that we stop marketing to you, this will not prevent us from sending
    communications to you which are not to do with marketing (for example in relation
    to services which you have purchased from us).
    11.4 We do not pass your personal information on to any third parties for marketing
    purposes.
12. Complaints
    If you are unhappy about the way that we have handled or used your personal
    information, you have the right to complain to the UK supervisory authority for data
    protection, which is the Information Commissioner’s Office (ICO). Please do contact
    us in the first instance if you wish to raise any queries or make a complaint in respect
    of our handling or use of your personal information, so that we have the opportunity
    to discuss this with you and to take steps to resolve the position. You can contact us
    using the details set out at the beginning of this privacy notice.
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13. Third Party Websites
    Our website may contain links to third party websites. If you click and follow those
    links then these will take you to the third party website. Those third party websites
    may collect personal information from you and you will need to check their privacy
    notices to understand how your personal information is collected and used by them.