Privacy Policy

We are Genus VS Limited t/as Genus Leasing, company number 5247254  
Our registered office isThe Old Post Cottage Top Green, Denston, Newmarket, Suffolk, CB8 8PW (‘we’, ‘us’ or ‘our’).  
We take the privacy of our customers very seriously. We ask that you read this Privacy Policy (‘the Policy’) carefully as it contains important information about how we will use your personal data. 
 
For the purposes of the Data Protection Act (‘DPA’), we are the ‘Data Controller’ (i.e. the company who is responsible for, and controls the processing of, your personal data). 
 
This Policy was last updated in May 2018 in line with the General Data Protection Regulation (GDPR) reform that took effect from 25th May 2018. The reform sets out more rights for individuals and greater transparency in how personal data is processed by Data Controllers, such as consent, distribution, marketing and deletion. As we are a credit intermediary, we undertake several financial tasks that relate to consumer credit. Our firm’s lawful basis for processing your personal data is done so under a Legitimate Interest - Article 6(1)(f) – “the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.” 

Personal Data We may Collect 
We will obtain personal data about you (including your name, address, date of birth, contact information, interests, payment details, financial information and opinions) and those whose personal data you have with express authority disclosed to us (‘others’) whenever you complete an online form or make a telephone enquiry with us to receive our services. If you submit an online enquiry you will be required to agree to the terms of this Policy which include permitting us to contact you for the purposes of the finance related enquiry via the contact means of which you provide us with the details of. i.e. email address, telephone number, etc. 
 
For example, we will obtain personal data when you (e.g. contact us for any reason, or purchase services). In certain circumstances, we may hold sensitive personal data if you provide us with such information if you feel that it is relevant for the purpose of your enquiry, but we will not ask for such information. Any sensitive personal data obtained and recorded will only be done so with your explicit consent. 

How and why we use personal data 
We will use the personal data you disclose to us for the purposes described in Our Terms. 
These purposes include: 
to assist us in processing your enquiries and obtaining the services which you require; 
to help us identify you and any accounts that you hold with us; 
undertaking credit checks; 
administration; 
research, statistical analysis and behavioural analysis; 
customer profiling and analysing your preferences; 
marketing (providing you have opted-in) [for further information see ‘Marketing and opting-in’ below]; 
fraud prevention and detection; 
billing and order fulfilment; 
customising our website and its content to your particular preferences; 
to notify you of any changes to our website or to our services which may affect you; 
security vetting; and 
improving our services. 

Marketing and opting-in 
We may share your personal data with organisations as set out in the ‘Disclosure of personal data’ section below. If you have opted-in to receive our marketing material, we will ensure that it is to your requirements and granular. We or they may contact you or others (unless you have asked us or them not to do so) by mail, telephone, text message, email, (each contact method requires its own consent via an opt-in selection) The nature of these marketing communications relate to information on products, services, promotions and special offers which we believe may be of interest to you or others. If you or others would prefer not to receive any further direct marketing communications from us or our business partners, it is possible to opt out at any time. See further ‘Your rights’ below. 

Disclosure of personal data 
We may disclose personal data which You provide to Us to:  
- Our agents and service providers (e.g. providers of web hosting, maintenance services or potential funders); 
- Law enforcement agencies in connection with any investigation to help prevent unlawful activity; 
- Our business partners in accordance with the ‘Marketing and opting out’ section above, specifically being:  
    - finance companies with whom we deal for the purposes of providing our services to you; 
    - and other third parties with whom we deal in the course of providing our services to you;  
Any regulators within whose jurisdiction We operate from time to time. 
 
Please be aware that we will not sell or otherwise disclose any personal data provided to us to any other party without your express permission. 

Keeping data secure 
We currently safeguard personal data by storing it on a CRM protected by password and shall ensure that from time to time we use no lesser technical and organisational measures to safeguard personal data which is disclosed to us. Whilst we will use all reasonable efforts to safeguard such personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data which are transferred from you or to you via the internet. 

Monitoring 
We may monitor and record communications with you (such as telephone conversations and emails) for the purpose of quality assurance, training, fraud prevention or compliance purposes. 

Information about other individuals 
If you give us information about others, you confirm that the other third-party person has appointed you to act on his/her behalf. This is also relevant where others are concerned if you indeed ask another person to act on your behalf as a third party. Under the third party authorisation, the other person can: 
Give consent on his/her behalf to the processing of his or her personal data for the purposes and reasons set out in this Policy; and 
Receive on his/her behalf any data protection notices. 
Such authorisation will remain in place until this has been revoked, either by verbal or written communication. 

Use of Google Analytics Advertising 
We use Google Analytics Advertising Features (‘GAAF’) through Our website, which means that certain information about the traffic on Our website is collected. In light of using GAAF, we will not facilitate the merging of personally-identifiable information with non-personally identifiable information collected through GAAF unless We receive Your express consent to that merger.  
Furthermore, We are hereby notifying You that the specific GAAF feature(s) which We have implemented are: 
Remarketing with Google Analytics 
Google Display Network Impression Reporting 
Google Analytics Demographics and Interest Reporting 
- We use first-party cookies (such as GAAF cookies) or other first-party identifiers, and third-party cookies (such as advertising cookies) or other third-party identifiers together; and 
- You can op-out of the GAAF You use, including through Ads Settings, Ad Settings for mobile apps, or any other available means such as the Google Analytics currently available opt-outs accessible via https://tools.google.com/dlpage/gaoptout/ 

Your Rights 
As a customer of Genus Leasing you have the following rights related to your data and how it’s processed:  
The right to be informed – this means we must provide, at the point of collecting your data, a privacy or verbal notice informing you of how your personal information will be used. 
The right to access your personal information – this means that you have the right to know what information we hold on you, and to request a copy of it. This information is provided free of charge. 
The right to get inaccurately recorded information corrected. 
The right to erasure – this means that you can request that your personal data is deleted from our records, also referred to as ‘the right to be forgotten’. 
The right to restrict how your personal information is used – this means that you have the right to object to how we use your personal information, including for direct marketing purposes. 
The right to receive your personal information in a legible and transferable format. 
The right to object to the use of your personal information 
Rights related to automated decision-making including profiling – this means you have the right to refuse to your personal information being used to make a decision based on an automatic process without human intervention 

For further information on how to action any of these rights please contact the data protection officer at the address on this statement.  

If you are dissatisfied with our use of your information or our response to any exercise of these rights you have the right to complain to the Information Commissioner's Office which regulates the processing of personal data in the UK (click here for more information). 

Data Retention 
We will only process your personal data providing you have given your consent for us to do so. Under the provisions of the DPA, our firm’s lawful basis for processing personal data is based on a Legitimate Interest. 
 
The legitimate interest relates to a legal requirement for the firm to hold your personal data and financial information on record for up to a total of six years. This six-year period satisfies the requirement of our regulator, The Financial Conduct Authority and is also in line with other financial industry retention periods. 

International Transfers 
In the normal course of business there may be a need for Genus VS Ltd or any other firm associated to the business, usually when processing an application for credit, personal data would have to be transferred outside of the European Economic Area (EEA) where those countries do not typically have the same protections and safeguards in place for the protection of personal data to those countries within the EEA. 
Genus Leasing deal with a number of large, international corporations where data is likely to be transferred in this way. Assurances and processes will always be put in place and considered before any international transfer to a non-EEA country is undertaken to ensure the protection and security of the personal data. 

Our Contact Details 
We welcome your feedback and questions. Please send communication to Alan Beckett 
Email: info@genusleasing.com  
Post: Unit A1 Risby Business Park, Newmarket Road, Risby, Bury St Edmunds, Suffolk, IP28 6RD  
Phone:  01284 810467.  
We may change this Policy from time to time. You should check this policy occasionally to ensure You are aware of the most recent version which will apply each time You deal with Us. 

Should you wish to contact the ICO about your dealing with Genus Leasing their contact details are: 

Email: Dpo@ico.org.co.uk   
Online: https://ico.org.uk/make-a-complaint/ 
Phone0303 123 1113 

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