Background

Lifecycle Management Group Ltd understands that your privacy is important and that you care about how your personal data is used and shared. We respect and value the privacy of everyone who visits Lifecycle.co.uk, MyOptimise.co.uk, Optimise.eu.com, OptimiseContract.co.uk, theleasingframework.co.uk, replacementplanning.co.uk and NHSLeasing.co.uk (our “Sites”) and will only collect and use personal data in ways that are described here, and in a manner, that is consistent with our obligations and your rights under data protection law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of our Sites and/or You will be required to read and accept this Privacy Policy when signing up for an Account. If you do not accept and agree with this Privacy Policy, you must stop using our Sites immediately.

Definitions and Interpretation
In this Policy the following terms shall have the following meanings:

"Account"

Means a user account required to access and/or use certain areas and features of Our Sites, namely our OPTIMiSe portal.

"Cookie"

Means a small text file placed on your computer or device by our site when you visit certain parts of our site and/or when you use certain features of Our Sites. Details of the Cookies used by Our Sites are set out in section 14, below.

"Personal Data"

Means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Sites. This definition shall, where applicable, incorporate the definitions provided in the Data Protection Act 2018 or EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”).

"We/Us/Our"

Means Lifecycle Management Group Ltd, a limited company registered in England under company number 06390313 whose registered address is Unipart House, Garsington Rd, Oxford, OX4 2PG.
Information About Us
1. Our Sites are owned and operated by Lifecycle Management Ltd, a limited company registered in England under company number 06390313, whose registered address is Unipart House, Garsington Rd, Oxford, OX4 2PG.
2. Our VAT number is 831424945.
3. Our Data Protection is managed by the IT Department, who can be contacted by email at DataProtection@Lifecycle.co.uk
What Does This Policy Cover?
This Privacy Policy applies only to your use of Our Sites. It is important that you read this Privacy Policy together with any other fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your personal data. Our Sites may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
Your Rights
1. Under certain circumstances, you have rights under data protection laws in relation to your personal data. This Policy and Our use of personal data have been designed to uphold:
  1. The right to be informed about Our collection and use of personal data;
  2. The right of access to the personal data We hold about you (see section 13);
  3. The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact us using the details in section 15);
  4. The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 7 but if you would like Us to delete it sooner, please contact Us using the details in section 15). Note, however, that We may not always be able to comply with your request to be forgotten for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  5. The right to restrict (i.e. prevent) the processing of your personal data in certain scenarios;
  6. The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation). Note that this right only applies to automated information which you initially provided consent for Us to use or where We used the information to perform a contract with you;
  7. The right to object to Us using your personal data for particular purposes. In some cases, We may demonstrate that We have compelling legitimate grounds to process your information which override your rights and freedoms; and
  8. The right to withdraw consent at any time where We are relying on consent to process your personal data. If you withdraw your consent, We may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
2. If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 15 and we will do our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
3. For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
What Personal Data Do We Collect?
Depending upon your use of Our Sites, We may collect some or all of the following personal data which we have grouped together as follows (please also see section 14 on Our use of Cookies and similar technologies or click here for Our Cookie Policy):
1. Identity Data: includes full name, username and job title;
2. Contact Data: includes email addresses and telephone numbers;
3. Transaction Data: includes details about payments to and from you and other details of services you have purchased from Us;
4. Profile Data: includes your username and password and your account preferences;
5. Technical Data: includes IP address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access Our Sites;
6. Usage Data: includes information about how you use Our Sites, products and services;
7. Marketing and communications Data:includes your preferences in receiving marketing from Us and your communication preferences
How do we collect your Personal Data?
We use different methods to collect data from and about you including through:
1. Direct interactions - You may give us your Identity and Contact Data by filling in forms or by corresponding with Us via Our Sites, by phone, email or otherwise. This includes personal data you provide when you:
  
  • apply for Our products or services;
  
  • create an Account;
  
  • request marketing to be sent to you; or
  
  • give Us feedback or contact us.
2. From key account holders within your organisation – we may colleague Identity and Contact Data from your colleagues relating to you when we require this information to set up an account for you or to provide our services to you.
3. Automated technologies or interactions - As you interact with Our Sites, We will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see clause 14 for further details.
4. Third parties or publicly available sources – We may receive Technical Data from analytics providers such as Google and CANDDI, and search information providers.

How Do We Use Your Personal Data?

All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the Data Protection Act 2018 or GDPR at all times. For more details on security see section 8, below.
Our use of your personal data will always have a lawful basis. Most commonly, We will use your personal data either because it is necessary for Our performance of a contract with you, because it is in Our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests, or because We need to comply with a legal obligation. Generally, We do not rely on consent as a legal basis for processing your personal data although We will get your consent before sending direct marketing communications to you. You have the right to withdraw consent to marketing at any time by contacting Us.
We have set out below, a description of all the ways We plan to use your personal data, and which of the legal bases We rely on to do so. We have also identified what Our legitimate interests are where appropriate.

Note that We may process your personal data for more than one lawful ground depending on the specific purpose for which We are using your data. Please contact Us if you need details about the specific legal ground We are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To provide and manage your Account	(a) Identity (b) Contact (c) Profile	Performance of a contract with you
To process and supply Our products and/services to you including: (a) Access to Our Sites (b) Manage payments, fees and charges (c) Collect and recover money owed to Us	(a) Identity (b) Contact (c) Transaction (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for Our legitimate interests (to recover debts due to Us)
To manage Our relationship with you which will include: (a) Notifying you about changes to Our terms or privacy policy (b) responding to questions and queries from you (c) asking you to provide feedback	(a) Identity (b) Contact (c) Profile (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for Our legitimate interests (to keep Our records updated and to study how customers use Our products/services)
To administer and protect Our business and Our Sites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical (d) Usage	(a) Necessary for Our legitimate interests (for running Our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant and personalised products and/services to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for Our legitimate interests (to study how customers use our products/services, to develop them, to grow Our business and to inform Our marketing strategy)
To improve Our Sites, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for Our products and services, to keep Our Sites updated and relevant, to develop Our business and to inform Our marketing strategy)
To make suggestions and recommendations to you about products or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	(a) Necessary for Our legitimate interests (to develop Our products/services and grow Our business) (b) Consent

With your permission and/or where permitted by law, We may also use your personal data for marketing purposes which may include contacting you by email and/or telephone and/or post with information, news and offers on Our products and/or services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the Data Protection Act 2018 or GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to Us as a result of a product/service purchase or other transactions.
We do not keep your personal data for any longer than is necessary considering the reason(s) for which it was first collected, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if We reasonably believe there is a prospect of litigation in respect to Our relationship with you. 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, regulatory, tax, accounting or other requirements. Personal data will therefore be retained for the following periods (or its retention will be determined on the following bases):
1. Contractual information – Stored for 10 years after your organisation has ceased to be Our customer. This applies to personal data relating to Our contract with your organisation and the contracts that have been set up by Us on behalf of your organisation.
2. System information – Stored in the browser and cleared by the user as required.

How and Where Do We Store Your Data?
1. We only keep your personal data for as long as We need to in order to use it as described above in section 7, and/or for as long as We have your permission to keep it.
2. Your personal data will only be stored in the UK.
3. Data security is very important to Us, and to protect your personal data We have taken suitable measures to safeguard and secure personal data collected through Our Sites.
4. Lifecycle Management Group Ltd takes the security of the information We hold very seriously. Our Information security policy ensures that:
  
  • The personal data We hold will be protected against any unauthorized access;
  
  • Confidentiality of the personal data We hold will be assured;
  
  • Integrity of the personal data We hold will be maintained;
  
  • Availability of the personal data We hold for business processes will be maintained;
  
  • Legislative and regulatory requirements will be met;
  
  • We have business continuity plans and they are maintained and tested;
  
  • Information security training has been given to all employees;
  
  • All actual or suspected information security breaches will be reported to the IT Department and will be thoroughly investigated.
  
  Our office network and data centre servers are protected by high-end firewalls and are constantly monitored against external threats.
  Both sites have physical security guards and restricted access 24-7-365.
  Our online applications are hosted on Microsoft Azure who are compliant with several security frameworks (ISO/IEC 27001:2013 and NIST SP 800-53).
Do We Share Your Data?
1. Subject to section 9.2 and 9.3, We will not share any of your personal data with any third parties for any purposes.
2. In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where we are involved in legal proceedings, where we are complying with legal obligations, a court order, or a governmental authority.
3. We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your personal data. Where any of your personal data is required for such a purpose, We will take all reasonable steps to ensure that your personal data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law. We do not allow Our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with Our instructions.
4. We may compile statistics about the use of Our Sites including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
What Happens If Our Business Changes Hands?
We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that personal data only for the same purposes for which it was originally collected by Us.
How Can You Control Your Data?
In addition to your rights under the GDPR, set out in section 4, when you submit personal data via Our Sites, you may be given options to restrict Our use of your personal data. In particular, We aim to give you strong controls on Our use of your personal data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details and by managing your Account).
Your Right to Withhold Information
1. You may access certain areas of Our Sites without providing any personal data at all. However, to use all features and functions available on Our Sites you may be required to submit or allow for the collection of certain personal data.
2. You may restrict Our use of Cookies that are not strictly necessary. For more information, see section 14 and or click here for our Cookie Policy.
How Can You Access Your Data?
1. You may make a subject access request (“SAR”) at any time to find out more about the personal data which We hold about you, how We process that personal data, and why.
2. All SAR requests should be emailed to DataProtection@Lifecycle.co.uk
3. We may need to request specific information from you to help Us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up Our response.
4. Responses to SARs shall normally be made within one month of receipt, however this may be extended by up to two months if the SAR is complex and/or numerous requests are made. If such additional time is required We will notify you.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, We may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
Our Use of Cookies
Our Sites may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Sites and to provide and improve Our products and/or services. In addition, our Sites use analytics services provided by Google and Candi, which also use Cookies. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Sites. For more details, please click here for our Cookie Policy
Contacting Us
If you have any questions about Our Sites or this Privacy Policy, please contact Us by email at DataProtection@Lifecycle.co.uk. Please ensure that your query is clear, particularly if it is a request for information about the personal data We hold about you (as under section 13, above).
Changes to Our Privacy Policy
We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Sites and you will be notified when you next visit Our Sites or log-in to your Account.