Lifecycle Management Group Limited 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, leaseguardonline.com, leaseguardgroup.co.uk, mspaymentterms.co.uk, optimisecontract.co.uk, theleasingframework.co.uk and NHSLeasing.co.uk 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 the law.
Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
Means a user account required to access and/or use certain areas and features of our site;
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 site. Details of the Cookies used by our site are set out in section 13, below;
Means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
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 site. This definition shall, where applicable, incorporate the definitions provided in the Data Protection Act 1998 or EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
Means Lifecycle Management Group Limited, a limited company registered in England under company number 06390313 whose registered address is Unipart House, Garsington Rd, Oxford, OX4 2PG.
Information About Us
- Our website is owned and operated by Lifecycle, a limited company registered in England under company number 06390313, whose registered address is Unipart House, Garsington Rd, Oxford, OX4 2PG
- Our VAT number is 831424945.
- 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?
As a data subject, you have the following rights under the GDPR, which this Policy and our use of personal data have been designed to uphold:
- The right to be informed about our collection and use of personal data;
- The right of access to the personal data we hold about you (see section 12);
- The right to rectification if any personal data we hold about you is inaccurate or incomplete (please contact us using the details in section 14);
- 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 6 but if you would like us to delete it sooner, please contact us using the details in section 14);
- The right to restrict (i.e. prevent) the processing of your personal data;
- The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
- The right to object to us using your personal data for particular purposes; and
- Rights with respect to automated decision making and profiling.
- If you have any cause for complaint about our use of your personal data, please contact us using the details provided in section 14 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.
- For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
What Data Do We Collect?
- Business/company name;
- Job title;
- Contact information such as email addresses and telephone numbers;
- Demographic information such as post code, preferences and interests;
- IP address;
- Web browser type and version;
- Operating system;
- A list of URLs starting with a referring site, your activity on our site, and the site you exit to;
How Do We Use Your 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 1998 or GDPR at all times. For more details on security see section 7, below.
Our use of your personal data will always have a lawful basis, either because it is necessary for our performance of a contract with you, because you have consented to our use of your personal data (e.g. by subscribing to emails), or because it is in our legitimate interests. Specifically, we may use your data for the following purposes:
- Providing and managing your Account;
- Providing and managing your access to our site;
- Personalising and tailoring your experience on our site;
- Supplying our products and/or services to you (please note that we require your personal data in order to enter into a contract with you);
- Personalising and tailoring our products and/or services for you;
- Replying to emails from you;
- Supplying you with emails that you have opted into, you may unsubscribe or opt-out at any time by using the Unsubscribe option in all marketing emails.
- Market research;
- Analysing your use of our site and gathering feedback to enable us to continually improve our site and your user experience;
- With your permission and/or where permitted by law, we may also use your 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 1998 or GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
- You have the right to withdraw your consent to us using your personal data at any time, and to request that We delete it.
We do not keep your personal data for any longer than is necessary considering the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
- Contractual information – Stored for 10 years after the contracting authority has ceased to be a customer.
- System information – Stored in the browser and cleared by the user as required.
How and Where Do We Store Your Data?
- We only keep your personal data for as long as we need to in order to use it as described above in section 6, and/or for as long as we have your permission to keep it.
- Your data will only be stored in the UK.
- Data security is very important to us, and to protect your data we have taken suitable measures to safeguard and secure data collected through our site.
Lifecycle Management Group Limited takes the security of the information we hold very seriously.
Our Information security policy ensures that:
- The data we hold will be protected against any unauthorized access;
- Confidentiality of the data we hold will be assured;
- Integrity of the data we hold will be maintained;
- Availability of the 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 with Rackspace who are compliant with several security frameworks (ISO27001/2, SSAE 16, ISAE 3402, and Safe Harbour).
Do We Share Your Data?
- Subject to section 8.2 and 8.3, we will not share any of your data with any third parties for any purposes.
- 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.
- 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 data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your 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 may compile statistics about the use of our site 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?
How Can You Control Your Data?
In addition to your rights under the GDPR, set out in section 4, when or you submit personal data via our site, you may be given options to restrict our use of your data. In particular, we aim to give you strong controls on our use of your 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
- You may access certain areas of our site without providing any data at all. However, to use all features and functions available on our site you may be required to submit or allow for the collection of certain data.
How Can You Access Your Data?
- Data subjects may make subject access requests (“SARs”) at any time to find out more about the personal data which the Company holds about them, what it is doing with that personal data, and why.
- All SAR requests should be emailed to DataProtection@Lifecycle.co.uk
- 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, the data subject shall be informed.
- The Company does not charge a fee for the handling of normal SARs. The Company reserves the right to charge reasonable fees for additional copies of information that has already been supplied to a data subject, and for requests that are manifestly unfounded or excessive, particularly where such requests are repetitive.