We have put in place a number of measures to ensure that any personal data we obtain from you is processed and maintained in accordance with legal requirements and the accepted principles of good information handling in accordance with the Data Protection Act 1998 (the “DPA”) and the General Data Protection Regulations (“GDPR”).
The Data Controller is Lifestyle Rental Limited. We determine the purposes for which and the manner in which your personal data will be processed.
This Policy applies to customers who seek to obtain goods and products from us on rental contracts. It will cover how we process data in connection with the initial application and then our ongoing management and servicing of the rental contract account.
3.What is personal data?
This is any information that either alone, or in combination with other information, would identify a person as a living individual, for example your name and date of birth.
Personal information does not include “Aggregated Usage Data” which is anonymized and aggregated information on how people interact without website and Service. Aggregated Usage Data helps us understand how users interact with the service, so we can provide better features and customer service. In addition to collecting and using Aggregated Usage Data ourselves, we may share Aggregated Usage Data with third parties, including our customers, partners and service providers, for various purposes, including to help us better understand our customers’ needs and improve the Service as well as for advertising and marketing purposes. We do not share Aggregated Usage Data with third parties in a way that would enable them to identify you personally.
4.How we collect your personal information
We may as a result of your interaction with our website and when you apply to rent goods or products, process and store your information on our computer systems and also on third party servers. We will also collect and store personal and financial information about you when you provide us with information over the telephone, by web chat or by e mail, when sends us documents (which may be in paper form or electronic) and when we access information held by credit reference agencies about you. We also collect personal information when we communicate with you during our servicing of your agreement with us.
We will collect the data shown below, whether or not you become a customer in connection with your application. If you become a customer we will use it to manage and service your account.
5.The types of data we collect and use
The type of data we collect and the reasons why include the following:
- Credit Assessment. We collect personal and financial information from you and from credit reference agencies (CRAs) to help us carry out identify checks and to assess your ability to meet your financial commitments and to check that you are creditworthy.
Such information includes your current and recent addresses, whether you are on the electoral role, your age, e-mail address and telephone number, about your employment and income, whether you are a home owner or tenant, personal data about bank accounts, credit cards, mortgages and other agreements that involve a credit arrangement like utilities and communications contracts (including mobile and internet) and how you are meeting your payments obligations to these organisations and whether you have any court judgments. We will also collect information about your UK residency status.
- Prevent and detect crime: We collect personal and financial information from you and from CRAs and public or government bodies to help us to detect and prevent crime and fraud and to verify your identity under our anti-money laundering obligations.
- Servicing of your contract: The information we collect will enable us to communicate with you about your rental contract, to service your account and any matters relation to the products and goods supplied (for example, to deal with the return of the goods or if repairs are needed).
It will also enable us to set up a personalised customer log in account for you to view a summary of your account details, your contact information and products obtained.
The information we collect will also enable us to communicate with you via your television with personalized alerts and you can also access relevant information this way using the remote control including accessing your payment history and basic account details and you can interact with us to make a payment, make a payment arrangement, make support requests and arrange a call back
Your data will also be used to us to issue statements, to process your payments onto our systems, to contact you about any missing payments and to trace you. We will make a record of our communications with you and your account activity to help us to monitor and manage your account, check that we are providing an adequate service and to help us to deal with any complaints. We will collect information about your bank account or payment card to enable us to process your rental repayments.
- Improve our services and products: We will use your information, for research, assessment and analysis (including market and product analysis) and to develop and improve our services to you and other customers.
6.The legal basis for processing your personal data
The UK’s data protection law allows us to process your personal data where we have a proper reason for doing so. Such reasons include to fulfil a contract we have with you, where it is in our legitimate interest, where we have a legal duty and when you consent to it.
- We rely on the legitimate reason basis in respect of our credit assessment activities described above. We will also share your data with credit reference agencies. A legitimate interest is when we have a business or commercial reason to use your information and this is not unfairly against your interests.
- We rely on the contract performance basis in order to take steps to enter into the rental contract with you and supply the goods and products, to service the contract and to enforce our rights and remedies under the contract.
- We rely on the legal duty for processing by collecting information in order to prevent and detect crime and by sharing such data with credit reference and government agencies and authorities. We will also collect information necessary for us to maintain records as required by government and regulatory bodies.
- We will rely on your consent where
- you request that we disclose your information to others,
- in the event that we process any special categories of personal data at your request (for example data concerning your health), We will only record them with your explicit consent if they are relevant to the management of your account (for example if you have a medical condition which requires a bespoke approach to our dealings with you), and
- To send you marketing communications (see below).
We may wish to make you aware, from time to time of products or services which are similar to the ones you have recently taken out with us. We will only do this is we consider this to be a legitimate business interest of ours or with your consent. This could include offering you an upgrade to your existing product at the end of the rental term. If we do this you may notify us to cease sending these messages at any time.
8.Disclosure of your personal information
We may give information about you and how you manage your account to the following organisations and where we do so shall take reasonable steps to ensure that your rights are protected and that they will keep the information confidential:
- People who provide a service to us or are acting as our agents. This includes any organisation where we have decided to outsource all or part of the administration or servicing of your agreement including in respect of
- delivery fulfilment of the goods,
- a third party that holds customer data on its servers for us, including back up data for our use.,
- debt collection and goods recovery,
- a third party intermediary to manage credit card processing (although they are not permitted to store, retain or use your billing information for any other purpose), and
- third parties we use to carry out repairs or servicing to the goods and products supplied.
- Our insurers, auditors and accountants, solicitors, consultants and other professional advisers;
- Anyone to whom we transfer or may transfer our rights and duties under your finance agreement (for example if we were to sell your agreement to another funder company);
- Any funders or investors (or prospective funders or investors) of our business;
- Credit reference agencies and fraud prevention agencies (see below);
- We may also give out personal information about you if we have a duty to do so in order to comply with any legal obligation (including with any Government agencies or regulators).
We do not currently send customer data outside of the UK. However in the event that we were to send data to an organisation located outside of the European Economic Area we will make sure that they agree to apply the same levels of protection as we are required to apply to information held in the UK and to use your information only for the purpose of providing the service to us.
9.Credit Reference Agencies
In order to assess a finance application, we will perform credit and identity checks on you with one or more CRAs. When CRAs receive a search from us they will place a search footprint on your credit file that may be seen by other finance companies. They supply to us both public (including the electoral register) and shared credit and fraud prevention information.
We and other organisations may also access and use CRA information to:
- assess your credit worthiness and whether you can afford the rental or credit repayments ;
- verify the accuracy of the data provided to us;
- prevent criminal activity, fraud and money laundering;
- manage the accounts; and
- trace and recover debts
If you tell us that you have a spouse or financial associate, we will link your records together so you must be sure that you have their agreement to disclose information about them. CRAs also link your records together and these links will remain on your and their files until such time as you or your partner successfully files for a disassociation with the CRAs to break that link.
Information relating to your application will be shared by us and sent to CRAs and will be recorded by them. We will give details of your account and how you manage it to them. We will continue to exchange information about you with CRAs while you have a relationship with us. If you do not repay in full and on time, CRAs will record the outstanding debt and that you have defaulted. This information may be supplied to other organisations by CRAs to perform similar checks Records remain on file for six years after they are closed, whether settled by you or defaulted. We will also notify the CRAs when you settle your account.
Further information about the CRAs, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRAs are explained in more detail at:
10.Retention of your personal information
The length of time we retain your information will depend on the purpose for which the information was provided. In general, however:
- We will keep the information that is necessary to enable us to manage your account and provide you with a service that you have requested for as long as it takes us to provide that service.
- We will keep your contact details for as long as we have your consent to send you marketing information.
- We will keep records of your account history for a period that will not usually exceed six years after the end of the rental agreement. This is to allow us to respond to any complaints or disputes that may arise during that period.
- We will keep other information about you if it is necessary for us to do so to comply with the law or regulatory requirements.
11.Access to your information and your other rights
You have the right to request a copy of the information that we hold about you (sometimes called a “subject access request”). If you would like a copy of some or all of your personal information, please email or write to us at our address below. This is free of charge although we can charge a reasonable fee if your request is excessive or repetitive.
You also have the following rights. In most cases we generally must respond within a month.
- You may ask us to rectify information you think is inaccurate.
- You are entitled to request that the personal data we hold about you be erased if you can show that the data (or some of it) is no longer necessary in relation to the purpose for which it was originally collected or processed by us. This is because it has been obtained in order to provide a rental product to you and to service and maintain your account and therefore we would usually have a legitimate interest in retaining it. There may also be legal or regulatory reasons why we need to continue to retain it.
- In certain circumstances you have the right to restrict and/or object to certain processing if it meets legal requirements.
- Where we rely on your consent to process your personal data, you may withdraw your consent at any time. However we may continue to process your personal data if we have other legitimate or lawful reasons to do so. If you withdraw your consent, we may not be able to provide our products and services to you. If this is the case, we will tell you.
- You have the right to ask us not to use your information for marketing purposes and to stop sending marketing communications.
You have a right to complain to us if you are dissatisfied in the way that we have handled your personal data. You may contact us for details of our complaints policy. If you are an individual, you also have a right to complain to the Information Commissioner’s Office if you are unhappy with the way we handle your data. Their details are Customer Contact, Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF, telephone 0303 123 1113 or email firstname.lastname@example.org. You can also download and complete a complaint form by following the link at https://ico.org.uk/concerns/
- Margaret Powell House,
423 Midsummer Blvd
- 0333 987 4475 (local rate)