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Privacy Policy

Fleet Operations Limited takes your privacy very seriously. Please read this Privacy Policy carefully as it contains important information on who we are, sets out the basis on which any personal information we collect from you, or that you provide to us will be processed, stored and shared by us in respect of your relationship with us as a customer/potential customer, an employee of our customer and our suppliers. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain personal information about you. When we do so we are subject to the Data Protection Act 2018 and we are responsible as ‘controller’ of that personal information for the purposes of those laws.

This privacy policy only applies to personal information we hold about individuals where we act as the Data Controller. It does not apply to information we hold about companies and other organisations or personal information we hold as a Data Processor.

We act as a data processor for our customers while executing the services we are contracted for.

We act as a data controller in maintaining business relationships with our customers, and sometimes while executing the services we are contracted for.

The information we collect may be collected via telephone; email; online live chat; our social media channels; in person from you; via our website or indirectly such as your browsing activity whilst on our website (see ‘Cookies’ below).

By giving your personal information to us, we will transfer, store or process it as set out below. We will take all reasonably necessary steps to ensure that your personal information is treated securely and in accordance with this Privacy Policy.

Key Terms

It would be helpful to start by explaining some key terms used in this policy:

We, us, our Fleet Operations Limited (Also trading as Traxall UK)
Our Data Protection Team The data protection team at Fleet Operations Limited that support the business with data protection matters
Personal information Any information relating to an identified or identifiable individual
Special category personal information Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership

Genetic and biometric data

Data concerning health, sex life or sexual orientation

What types of personal information do we collect about you:

We may collect and use the following personal information about you:

  • if you use our services, name and title, address, e-mail address, employment status, driving licence information, telephone number and date of birth.
  • if you are disabled, information about how your disability may impact your mobility requirements.
  • demographic information such as postcode, preferences and interests.
  • your billing information, transaction and payment card information.
  • information to enable us to undertake credit or other financial checks on you.
  • if you make a credit application we may store your banking and financial information (including income, expenditure and previous credit history).
  • if you make a credit application we may store information about your lifestyle and home ownership.
  • if you contact us online, we may keep a record of your email correspondence.
  • if you use our telematics services, location data, historic trip data (for trips you specify), safety events, trip categories, frequent trip rules.
  • details of any feedback you give us by phone, email, post or via social media.
  • if you contact us by telephone, we may record and/or monitor telephone conversations for training and customer services reasons.
  • if you enter a competition or complete a survey we will collect your name and relevant contact information.
  • if you report a problem with our services we will collect your name and relevant contact information.
  • if you make a complaint in connection with our services we will collect your name and relevant contact information.

Personal information we collect and/or observe about you on our website

Based on how you have used our services in the past and your activity on our website and by telephone, we collect the following personal information from you:

  • details of the services we have provided to you in the past.
  • details of your visits to our website, and of the resources that you access. We may use visitor information to measure the entry and exit points of visitors to the website and respective numbers of visitors to various pages and sections of the website and details of searches performed. We may also use this information in the future to measure the usage of advertising banners, and other “click throughs” to and from the website.
  • details of the website(s) you visited before you use a link to our website, pages visited in our website, and time spent on each. Information about your computer, or mobile device. This is statistical data about our users’ browsing actions.

Personal information we collect and use for legal, compliance, regulatory and crime detection and prevention purposes

We process your personal information so that we can meet our legal, compliance and regulatory obligations, for legal purposes, such as to respond to a valid legal claim, summons or regulatory order.

We also process your personal information for crime prevention and detection purposes.

How your personal information is collected

We collect most of this personal information directly from you —in person, by telephone, or email and/or via our website(s). However, we may also collect information:

  • from another person acting on your behalf, such as your employer
  • from our promotion partners
  • from social media
  • directly from a third party, e.g.:
    • credit reference agencies;
    • customer due diligence providers.
  • from a third party with your consent, e.g. the DVLA, your bank or building society
  • from cookies on our website—for more information on our use of cookies, please see our cookies policy below
  • from our web portal or mobile applications
  • via our IT systems, e.g.
    • automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email systems
    • systems relating to physical access, such as reception logs, door entry systems etc.

How and why we use your personal information

Under data protection law, we can only use your personal information if we have a proper reason for doing so, for example:

  • to comply with our legal and regulatory obligations;
  • for the performance of our contract with you or to take steps at your request before entering into a contract;
  • for our legitimate interests or those of a third party; or
  • where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for Our reasons
To provide services to you For the performance of our contract with you or to take steps at your request before entering into a contract. For example, vehicle management, accident management, fleet administration, roadside assistance, maintenance management, risk management and vehicle procurement.
To prevent and detect fraud against you For our legitimate interests or those of a third party, i.e. to minimise fraud that could be damaging for us and for you
Conducting checks to identify our customers, customer’s employees and suppliers and verify their identity. Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, eg under health and safety regulation or rules issued by our professional regulator To comply with our legal and regulatory obligations
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies To comply with our legal and regulatory obligations
Recording calls made to our offices so we can review how we handle calls and make any necessary improvements For our legitimate interests
Provide you with special assistance in relation to special categories of personal information For the performance of our contract with you or to take steps at your request before entering into a contract; to comply with our legal and regulatory obligations; with your consent
Improve our products and services For our legitimate interests
Ensuring business policies are adhered to, for example: policies covering security and internet use For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so that we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable informationTo comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Operational reasons, such as improving efficiency, training and quality control For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorised access and modifications to systems For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for youTo comply with our legal and regulatory obligations
Updating customer records For the performance of our contract with you or to take steps at your request before entering into a contractTo comply with our legal and regulatory obligations

For our legitimate interests or those of a third party, for example: making sure that we can keep in touch with our customers about existing orders and new products
Statutory returns To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments To comply with our legal and regulatory obligationsFor our legitimate interests or those of a third party, for example: to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Marketing our services [and those of selected third parties] to:

  • existing and former customers;
  • third parties who have previously expressed an interest in our services;
  • third parties with whom we have had no previous dealings.
 For our legitimate interests or those of a third party; with your consent, i.e. to promote our business to existing and former customers
For debt collection and credit vetting to project our business against financial loss For our legitimate interests or those of a third party, i.e. to ensure our customers are likely to be able to pay for our products and services
To seek to protect and promote your health and safety and that of our other customers, staff and third parties To comply with our legal and regulatory obligationsFor our legitimate interests or those of a third party
To seek to detect, investigate, prevent and report crime and anti-social behaviour For our legitimate interests or those of a third party, i.e. to detect and prevent crime and anti-social behaviour
For resolving complaints dealing with disputes and legal proceedings To comply with our legal and regulatory obligations

Promotional communications

If you have made an enquiry on our website or by telephone, your personal information may be used by us in the ways the law allows, to contact you by post or electronic means (email or text message) about our services, including exclusive offers, promotions or new services. We will only do this if you did not opt out of such marketing at the point where we collect your contact details.

If you have not made an enquiry or purchase, we will only send you information and offers by email or text message if you sign up (opt in) to receive such marketing.

We will always treat your personal information with the utmost respect and never sell or share it with other organisations for marketing purposes.

What you need to do if you don’t want to receive our promotional communications

You have the right to opt out of receiving promotional communications at any time by:

  • contacting us via email at data.protection@fleetoperations.co.uk or writing to us at Fleet Operations Limited, Fleet House, Maries Way, Silverdale Business Park, Newcastle Under Lyme, Staffordshire, ST5 6PA.
  • using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts where the option is provided.

We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

Who we share your personal information with

We routinely share personal information with:

  • our customers (who are typically your employer or contracting agent) to help us to deliver our services;
  • our suppliers, sub-contractors and business partners who help us to provide our services to you, for example to process accident management claims or for vehicle delivery/collection;
  • third parties we use to help deliver our services to you, e.g. payment service providers.
  • other third parties we use to help us run our business, e.g. marketing agencies or website hosts;
  • The courts and other dispute resolution arbitrators and mediators and other parties to legal proceedings
  • third parties approved by you, e.g. social media sites you choose to link your account to or third-party payment providers;
  • credit reference agencies;
  • our insurers and brokers;
  • our bank(s);
  • our card payment facilitators, that help us process customer payments and assist us in detecting and preventing fraudulent payments or bookings;

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We may also share personal information with external auditors, e.g. in relation to the audit of our accounts.

We may disclose and exchange information with law enforcement agencies, regulatory bodies and external law firms (acting on your instructions) to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

We will not share your personal information with any other third party.

Where your personal information is held

Information may be held at our offices, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).

Some of these third parties may be based outside of the UK and European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the UK and EEA’.

How long your personal information will be kept

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of your personal information are available in our retention policy which is available on request.

 

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

Transferring your personal information out of the UK and EEA

To deliver services to you, it is sometimes necessary for us to share your personal information outside the UK and European Economic Area (EEA), for example:

  • service providers located outside the UK or EEA; (e.g. US based software providers like Google)
  • if you are based outside the UK or EEA

These transfers are subject to special rules under European and UK data protection law.

These non-UK and non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the UK.

If you would like further information, please contact our data protection team (see ‘How to contact us’ below).

Your rights in relation to any personal information we hold about you

You have the following rights, which you can exercise free of charge:

 

Access The right to be provided with a copy of your personal information (the right of access).We may ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information. That may include information about your previous order(s) or other interactions. If someone is acting on your behalf, they will need to provide written and signed confirmation from you that you have given your authority to that person/company for them to make the request. We may not provide you with a copy of your personal information if it includes the personal information of other individuals or we have another lawful reason to withhold that information.
Rectification The right to require us to correct any mistakes in your personal information.
Withdrawing your consent Where we rely on your consent as the legal basis for processing your personal information, as set out in section above titled ‘How and why we use your personal information’, you may withdraw your consent at any time.If you would like to withdraw your consent to receiving any direct marketing to which you previously opted-in, please see the section titled “What you need to do if you don’t want to receive our promotional communications’ for further details. If you would like to withdraw your consent to us processing any special categories of personal information, please contact our data privacy manager. Please note if you ask us to stop processing this information, it may mean we won’t be able to provide all or parts of the services you have requested. The withdrawal of consent may also affect an individual’s ability to fulfil their contractual or non-contractual obligation to the third party (e.g. their employer), and so we would recommend that the individual consult with the third party in the first instance.

If we have to cancel an order or other purchase as a result, you may incur a cancellation charge.

If you withdraw your consent, our use of your personal information before you withdraw is still lawful.
To be forgotten The right to require us to delete your personal information.In certain situations, you may ask for your personal information to be removed from our systems by e-mailing or writing to us at the address at the end of this Privacy Policy. Provided we do not have any continuing lawful reason to continue processing or holding your personal information, we will make reasonable efforts to comply with your request.
Restriction of processing The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the personal information.We may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings.
Data portability Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with your contract, as set out in section titled ‘How and why we use your personal information’, you have the right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that personal information to a third party.
You can ask us to send your personal information directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if it contains the personal information of other individuals or we have another lawful reason to withhold that information.
To object
  • at any time to your personal information being processed for direct marketing (including profiling);
  • in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision-making The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the UK General Data Protection Regulation.

If you would like to exercise any of those rights, please:

  • email, call or write to our data protection team see below: ‘How to contact us’
  • let us have enough information to identify you (e.g. your full name and address)
  • let us have proof of your identity and address; and
  • let us know what right you want to exercise and the information to which your request relates.

Cookies and similar technologies

A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our website. We use cookies on our website. These help us recognise you and your device and store some information about your preferences or past actions.

You can set your browser not to accept cookies however some of our website features may not function as a result.

For further information on our use of cookies please see our Cookies Policy

For further information on cookies generally visit www.aboutcookies.org or www.allaboutcookies.org.

Keeping your personal information secure

We have appropriate security measures to prevent personal information from being accidentally lost or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Links to other websites

Our website may contain links to and from other websites. Unless we own such websites, we accept no responsibility for the way in which they process your personal data. You are recommended to check the privacy policy of each website before you submit any personal data to it.

How to complain

We hope that our Data Privacy Manager can resolve any query or concern you may raise about our use of your information.

The UK General Data Protection Regulation also gives you right to lodge a complaint with the Information Commissioner’s Office. The ICO may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.

Changes to this privacy policy

This privacy notice was published on 11th October 2018 and last updated on 17th June 2022.

We may change this privacy notice from time to time—when we do we will inform you via our website.

How to contact us

Please contact our data protection team by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.

Our contact details are shown below:

Data Protection Team
Fleet Operations Limited
Fleet House, Maries Way
Silverdale Business Park
Newcastle-under-Lyme
Staffordshire
ST5 6PA

Email: data.protection@fleetoperations.co.uk

Telephone: 0344 567 8000

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