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 * A BUSINESS LEASE VEHICLE
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Home > data protection notice


DATA PROTECTION NOTICE


THIS NOTICE WAS REVIEWED AND UPDATED  JUNE  8TH  2023


 

Preliminary section: Main amendments

As a trusted companion, the protection of your personal data is important to the
BNP Paribas Group.
We have enhanced our Privacy Notice by being more transparent on the following
information on:

 * Collection of connected vehicle data.


INTRODUCTION


We take the protection of your personal data very seriously; accordingly, the
BNP Paribas Group has adopted strong principles in its Personal Data Protection
Charter available at BNP Paribas - Personal Data Privacy Charter .
Arval ("We"), as a controller, is responsible for collecting and processing your
personal data in relation to its activities.
Our business is to provide an extensive offer of vehicles leasing and mobility
solutions to our customers (individuals, entrepreneurs, small and medium-sized
enterprises and large companies).
As a member of an integrated banking-insurance Group in collaboration with the
various entities of the BNP Paribas Group, we provide our customers with a
complete range of banking, insurance and leasing products and services.
The purpose of this Privacy Notice is to explain how we process your personal
data and how you can control and manage them.


1. ARE YOU SUBJECT TO THIS NOTICE?


This Privacy Notice applies to you if you are ("You"):

 * one of our customers or in a contractual relationship with us;
 * a member of our customer family. Indeed, our customers may occasionally share
   with us information about their family when it is necessary to provide them
   with a product or service or to get to know them better;
 * a person interested in our products or services when you provide us with your
   personal data (in an agency, on our websites and applications, during events
   or sponsorship operations) so that we can contact you.
 * an employee of our corporate customers.

When you provide us with personal data related to other people, please make sure
that you inform them about the disclosure of their personal data and invite them
to read this Privacy Notice. We will ensure that we will do the same whenever
possible (e.g., when we have the person's contact details).


2. HOW CAN YOU CONTROL THE PROCESSING ACTIVITIES WE DO ON YOUR PERSONAL DATA?


You have rights which allow you to exercise real control over your personal data
and how we process them.

If you wish to exercise the rights listed below, please submit a request by
mailing a letter to the following address Arval UK Data Protection Correspondent
at Arval UK Limited, Whitehill House, Windmill Hill Business Park, Swindon, SN5
6PE or on our websites with a scan/copy of your identity card where required.

If you have any questions relating to our use of your personal data under this
Privacy Notice, please contact our Data Protection Correspondent at the
following address Arval UK Limited, Whitehill House, Windmill Hill Business
Park, Swindon, SN5 6PE, e-mail dataprotection@arval.co.uk.


2.1 YOU CAN REQUEST ACCESS TO YOUR PERSONAL DATA


If you wish to have access to your personal data, we will provide you with a
copy of the personal data you requested as well as information relating to their
processing.

Your right of access may be limited in the cases foreseen by laws and
regulations. This is the case with the regulation relating to anti-money
laundering and countering the financing of terrorism, which prohibits us from
giving you direct access to your personal data processed for this purpose. In
this case, you must exercise your right of access with Information
Commissioner's Office which will request the data from us.


2.2 YOU CAN ASK FOR THE CORRECTION OF YOUR PERSONAL DATA


Where you consider that your personal data are inaccurate or incomplete, you can
request that such personal data be modified or completed accordingly. In some
cases, supporting documentation may be required.


2.3 YOU CAN REQUEST THE DELETION OF YOUR PERSONAL DATA


If you wish, you may request the deletion of your personal data, to the extent
permitted by law.


2.4 YOU CAN OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA BASED ON LEGITIMATE
INTERESTS


If you do not agree with a processing activity based on a legitimate interest,
you can object to it, on grounds relating to your particular situation, by
informing us precisely of the processing activity involved and the reasons for
the objection. We will cease processing your personal data unless there are
compelling legitimate grounds for doing so or it is necessary for the
establishment, exercise or defence of legal claims.


2.5 YOU CAN OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA FOR COMMERCIAL
PROSPECTING PURPOSES


You have the right to object at any time to the processing of your personal data
for commercial prospecting purposes, including profiling, insofar as it is
linked to such prospecting.


2.6 YOU CAN SUSPEND THE USE OF YOUR PERSONAL DATA


If you question the accuracy of the personal data we use or object to the
processing of your personal data, we will verify or review your request. You may
request that we suspend the use of your personal data while we review your
request.


2.7 YOU HAVE RIGHTS AGAINST AN AUTOMATED DECISION


As a matter of principle, you have the right not to be subject to a decision
based solely on automated processing based on profiling or otherwise that has a
legal effect or significantly affects you. However, we may automate such a
decision if it is necessary for the entering into or performance of a contract
with us, authorised by regulation or if you have given your consent.

In any event, you have the right to challenge the decision, express your views
and request the intervention of a competent person to review the decision.


2.8 YOU CAN WITHDRAW YOUR CONSENT


If you have given your consent to the processing of your personal data, you can
withdraw this consent at any time.


2.9 YOU CAN REQUEST THE PORTABILITY OF PART OF YOUR PERSONAL DATA


You may request a copy of the personal data that you have provided to us in a
structured, commonly used and machine-readable format. Where technically
feasible, you may request that we transmit this copy to a third party.


2.10 HOW TO FILE A COMPLAINT WITH INFORMATION COMMISSIONER'S OFFICE


In addition to the rights mentioned above, you may lodge a complaint with the
competent supervisory authority, which is usually the one in your place of
residence, e.g., the ICO (Information Commissioner's Office) in UK.


3. WHY AND ON WHICH LEGAL BASIS DO WE USE YOUR PERSONAL DATA?


In this section we explain why we process your personal data and the legal basis
for doing so.


3.1 YOUR PERSONAL DATA ARE PROCESSED TO COMPLY WITH OUR VARIOUS REGULATORY
OBLIGATIONS


Your personal data are processed where necessary to enable us to comply with the
regulations to which we are subject, including banking and financial
regulations.

3.1.1 WE USE YOUR PERSONAL DATA TO:


 * manage and report risks (financial, credit, legal, compliance or reputational
   risks etc.) that the BNP Paribas Group could incur in the context of its
   activities;
 * assist the fight against tax fraud and fulfil tax control and notification
   obligations;
 * record transactions for accounting purposes;
 * prevent, detect and report risks related to Corporate Social Responsibility
   and sustainable development;
 * detect and prevent bribery;
 * comply with the provisions applicable to trust service providers issuing
   electronic signature certificates;
 * exchange and report different operations, transactions or orders or reply to
   an official request from a duly authorized local or foreign financial, tax,
   administrative, criminal or judicial authorities, arbitrators or mediators,
   law enforcement, state agencies or public bodies.

3.1.2 WE ALSO PROCESS YOUR PERSONAL DATA FOR ANTI-MONEY LAUNDERING AND
COUNTERING OF THE FINANCING OF TERRORISM PURPOSES


As part of a banking Group, we must have a robust system of anti-money
laundering and countering of terrorism financing (AML/TF) in each of our
entities managed centrally, as well as a system for applying local, European and
international sanctions.

In this context, we are joint controllers with BNP Paribas SA, the parent
company of the BNP Paribas Group (the term "We" in this section also includes
BNP Paribas SA).

The processing activities performed to meet these legal obligations are detailed
in Appendix 1.


3.2 YOUR PERSONAL DATA ARE PROCESSED TO PERFORM A CONTRACT TO WHICH YOU ARE A
PARTY OR PRE-CONTRACTUAL MEASURES TAKEN AT YOUR REQUEST


Your personal data are processed when it is necessary to enter into or perform a
contract to:

 * define your credit risk score and your reimbursement capacity;
 * evaluate (e.g., on the basis of your credit risk score) if we can offer you a
   product or service and under which conditions (e.g., price);
 * provide you with the products and services subscribed to under the applicable
   contract;
 * provide you with products, services, specific installation (such EV charging
   station) or mobility solutions;
 * enter into a contract with you. We may process personal data in order to
   register you as a new client, enter into a contract and perform it with you;
 * handle billing, invoicing and recovery;
 * provide you with services related to the preparation, delivery or use and the
   management of Vehicles:
 * configure and quote your Vehicle;
 * deliver your Vehicle at the place of your choice, possibly with equipment
   related to electric Vehicle charging devices in partnership with selected
   providers;
 * for insurance purposes;
 * in the context of OEMs recall campaigns in case of defect;
 * provide reporting;
 * manage road tax;
 * provide consulting services;
 * manage maintenance, breakdown, vehicle inspection, claim repair request with
   respect to the Vehicles;
 * provide roadside assistance;
 * provide a relief vehicle when needed:
 * provide you with fuel card (to pay your fuel), mobility cards (to recharge
   your electric Vehicle);
 * provide you with other mobility solutions subscribed to under the applicable
   contract;
 * raise your awareness of the impact of your driving on the environment or if
   you want to improve your safety on the road;
 * manage traffic and parking fines and offences related to the use of the
   Vehicle as part of the "Fines Management" service to the extent legally
   authorised;
 * provide you with an access to our digital platforms. We may process personal
   data when you use our digital platforms for several purposes (to manage your
   personal information or data related to Vehicles or to get an access to
   travel information for example);
 * provide access to the Arval premises and assets. We may process personal data
   when you visit us in our premises in order to maintain appropriate access and
   security control;
 * communicate with you. We may process personal data when you want to contact
   us, when you request us some information about our company or our services or
   when the contract needs to be updated;
 * manage existing debts (identification of customers with unpaid debts);
 * respond to your requests and assist you;
 * manage the end of the contract.


3.3 YOUR PERSONAL DATA ARE PROCESSED TO FULFIL OUR LEGITIMATE INTEREST OR THAT
OF A THIRD PARTY


Where we base a processing activity on legitimate interest, we balance that
interest against your interests or fundamental rights and freedoms to ensure
that there is a fair balance between them. If you would like more information
about the legitimate interest pursued by a processing activity, please contact
us using the contact details provided in section 9 "HOW TO CONTACT US?" above.

3.3.1 IN THE COURSE OF OUR BUSINESS AS A PROVIDER OF MOBILITY SERVICES, WE USE
YOUR PERSONAL DATA TO:


3.3.1.1 IF YOU ARE A PRIVATE LEASE CUSTOMER OR PROSPECT:


 * manage the risks to which we are exposed:
   * we keep proof of operations or transactions, including in electronic
     evidence;
   * we monitor your transactions to manage, prevent and detect fraud;
   * we carry out the collection of debts;
   * we handle legal claims and defences in the event of litigation;
   * we develop individual statistical models in order to help define your
     creditworthiness;

 * carry out financial operations such as debt portfolio sales, securitizations,
   financing or refinancing of the BNP Paribas Group.

3.3.1.2 FOR ALL CATEGORIES OF DATA SUBJECTS:


 * enhance cyber security, manage our platforms and websites, and ensure
   business continuity;
 * implement information technology solutions;
 * maintain information systems in operational conditions;
 * use video surveillance to prevent personal injury and damage to people and
   property;
 * enhance the automation and efficiency of our operational processes and
   customer services (e.g., automatic filling of complaints, tracking of your
   requests and improvement of your satisfaction based on personal data
   collected during our interactions with you such as phone recordings, e-mails
   or chats);
 * sell used vehicles;
 * conduct statistical studies and develop predictive and descriptive models
   for:
   * commercial purpose: to identify the products and services that could best
     meet your needs, to create new offers or identify new trends among our
     customers, to develop our commercial policy taking into account our
     customers' preferences
   * safety purpose: to prevent potential incidents and enhance safety
     management;
   * compliance purpose (e.g., anti-money laundering and countering the
     financing of terrorism) and risk management;
   * anti-fraud purposes; You can find further information about how your
     personal data is used for this purpose here
     https://www.arval.co.uk/sites/uk/files/media/documents/legal/cifas-information-notice-arval.pdf
   * organize contests, lotteries, promotional operations, conduct opinion and
     customer satisfaction surveys.

3.3.1.3 IF YOU ARE AN EMPLOYEE OF OUR CORPORATE CUSTOMER:


 * provide you with services related to the preparation, delivery or use and the
   management of Vehicles including:
   * to configure and quote your Vehicle;
   * to deliver your Vehicle at the place of your choice, possibly with
     equipment related to electric Vehicle charging devices in partnership with
     selected providers;
   * to assist OEMs recall campaigns in case of defect;
   * to ensure Vehicle repair, maintenance and replacement of tyres;
   * for accident management and insurance purposes;
   * for roadside assistance;
 * provide you with a fuel card (to pay your fuel), mobility cards (to provide
   you with multi mobility solutions);
 * raise your awareness of the impact of your driving on the environment or if
   you want to improve your safety on the road;
 * manage traffic and parking fines and offences related to the use of the
   Vehicle as part of the "Fines Management" service to the extent legally
   authorised;
 * manage our customers' accounts, manage the contractual relationship with our
   customers of whom you are an employee or to keep you informed about the
   development of our services;
 * provide fleet management services to our customers in relation with the
   Vehicles' habits (kilometres travelled, fuel or alternative energy
   consumption, etc.);
 * provide you with an access to our digital platforms. We may process personal
   data when you use our digital platforms for several purposes (to manage your
   personal information or data related to Vehicles or to get an access to
   travel information for example);
 * manage resolution of disputes and assist you and answer your requests and
   complaints;
 * provide access to the Arval premises and assets. We may process personal data
   when you visit us in our premises in order to maintain appropriate access and
   security control;
 * communicate with you. We may process personal data when you want to contact
   us, when you request us some information about our company or our services or
   when the contract needs to be updated;
 * provide reporting to our customers;
 * manage road tax;
 * provide consulting services to our customers;
 * handle billing and invoicing;
 * manage the end of the contract.

3.3.2 WE USE YOUR PERSONAL DATA TO SEND YOU COMMERCIAL OFFERS BY ELECTRONIC
MEANS, POST AND PHONE (TO THE EXTENT THAT WE ARE PERMITTED TO)


As part of the BNP Paribas Group, we want to be able to offer you access to the
full range of products and services that best meet your needs.

Once you are a customer and unless you object, we may send you these offers
electronically for our products and services and those of the Group if they are
similar to those you have already subscribed to.

We will ensure that these commercial offers relate to products or services that
are relevant to your needs and complementary to those you already have to ensure
that our respective interests are balanced.

We may also send you, by phone and post, unless you object, offers concerning
our products and services as well as those of the Group and our trusted
partners.

3.3.3 WE ANALYSE YOUR PERSONAL DATA TO PERFORM STANDARD PROFILING TO PERSONALIZE
OUR PRODUCTS AND OFFERS (TO THE EXTENT THAT WE ARE PERMITTED TO)


To enhance your experience and satisfaction, we need to determine to which
customer group you belong. For this purpose, we build a standard profile from
relevant data that we select from the following information:

- what you have directly communicated to us during our interactions with you or
when you subscribe to a product or service;

- resulting from your use of our products or services;

- from your use of our various channels: websites and applications (e.g., if you
are digitally savvy, if you prefer a customer journey to subscribe to a product,
or service with more autonomy (selfcare));

Unless you object, we will perform this customization based on standard
profiling. We may go further to better meet your needs, if you consent, by
performing a tailor-made customization as described below.


3.4 YOUR PERSONAL DATA ARE PROCESSED IF YOU HAVE GIVEN YOUR CONSENT


For some processing of personal data, we will give you specific information and
ask for your consent. Of course, you can withdraw your consent at any time.

In particular, we ask for your consent for:

 * tailor-made customization of our offers and products or services based on
   more sophisticated profiling to anticipate your needs and behaviours;
 * any electronic offer for products and services not similar to those you have
   subscribed to or for products and services from our trusted partners;
 * use of your navigation data (cookies) for commercial purposes or to enhance
   the knowledge of your profile.

You may be asked for further consent to process your personal data where
necessary.


4. WHAT TYPES OF PERSONAL DATA DO WE COLLECT?


We collect and use your personal data, meaning any information that identifies
or allows one to identify you.

Depending among others on the types of product or service we provide to you and
the interactions we have with you, we collect various types of personal data
about you:

If you are a private lease customer or prospect, we collect:

 * Identification information: e.g., full name, gender, place and date of birth,
   nationality, identity card number, passport number, driving licence number,
   vehicle registration number, photograph, signature);
 * Contact information: (private or professional) postal address, e-mail
   address, phone number;
 * Information relating to your financial and family situation: e.g., marital
   status, matrimonial regime, number of children and age, study or employment
   of children, composition of the household, property you own: apartment or
   house;
 * Lifestyle: hobbies and interests, travel, your environment (nomadic,
   sedentary);
 * Economic, financial and tax information: e.g., tax ID, tax status, country of
   residence, salary and other income, value of your assets;
 * Education and employment information: e.g., level of education, employment,
   employer's name and remuneration;
 * Banking and financial information related to the products and services you
   hold: e.g., bank account details, products and services owned and used
   (credit, insurance, savings and investments, leasing, home protection),
   credit card number, money transfers, assets, profile of declared investor,
   credit history, payment incidents;
 * Transaction data: transactions including beneficiary's data such as full
   names, addresses and contact details as well as details of bank transactions,
   amount, date, time and type of transaction (credit card, transfer, cheque,
   direct debit);
 * Data relating to your habits and preferences in relation to the use of our
   products and services;
 * Data collected from our interactions with you: e.g., your comments,
   suggestions, needs collected during our exchanges with you in person in our
   Agencies (reports) and online during phone communications (conversation),
   discussion by e-mail, chat, chatbot, exchanges on our social media pages and
   your latest complaints. Your connection and tracking data such as cookies and
   tracers for non-advertising or analytical purposes on our websites, online
   services, applications, social media pages;
 * Data collected from the video protection system (including CCTV) and
   geolocation: e.g., showing locations of withdrawals or payments for security
   reasons, or to identify the location of the nearest branch or service
   suppliers for you;
 * Data about your devices (mobile phone, computer, tablet, etc.): IP address,
   technical specifications and uniquely identifying data;
 * Personalized login credentials or security features used to connect you to
   the Arval website and apps.

If you are an employee of our corporate customer/prospect, we collect:

 * Identification information: e.g., full name, gender, place and date of birth,
   nationality, identity card number, passport number, driving licence number,
   vehicle registration number, photograph, signature);
 * Contact information: (private or professional) postal address, e-mail
   address, phone number;
 * Lifestyle: hobbies and interests, travel, your environment (nomadic,
   sedentary);
 * Data relating to your habits and preferences in relation to the use of our
   products and services;
 * Data collected from our interactions with you: e.g., your comments,
   suggestions, needs collected during our exchanges with you in person in our
   Agencies (reports) and online during phone communications (conversation),
   discussion by e-mail, chat, chatbot, exchanges on our social media pages and
   your latest complaints. Your connection and tracking data such as cookies and
   tracers for non-advertising or analytical purposes on our websites, online
   services, applications, social media pages;
 * Data collected from the video protection system (including CCTV) and
   geolocation: e.g., showing locations of withdrawals or payments for security
   reasons, or to identify the location of the nearest branch or service
   suppliers for you;
 * Data about your devices (mobile phone, computer, tablet, etc.): IP address,
   technical specifications and uniquely identifying data;
 * Personalized login credentials or security features used to connect you to
   the Arval website and apps.

Whether you are a private lease customer or an employee of our corporate
customer, we may collect sensitive data such as health data, biometric data, or
data relating to criminal offences, subject to compliance with the strict
conditions set out in data protection regulations.


5. WHO DO WE COLLECT PERSONAL DATA FROM?


We collect personal data directly from you; however, we may also collect
personal data from other sources.

We sometimes collect data from public sources:

 * publications/databases made available by official authorities or third
   parties (e.g., the Official Journal of the French Republic, the Trade and
   Companies Register, databases managed by the supervisory authorities of the
   financial sector);
 * websites/social media pages of legal entities or business clients containing
   information that you have disclosed (e.g. your own website or social media
   page);
 * public information such as that published in the press.

We also collect personal data from third parties:

 * from other BNP Paribas Group entities;
 * from our customers (companies or individuals);
 * from our business partners (including car manufacturers, car dealers, OEMs);
 * from service providers of payment initiation and account aggregators (service
   providers of account information);
 * from third parties such as credit reference agencies and fraud prevention
   agencies;
 * from data brokers who are responsible for ensuring that they collect relevant
   information in a lawful manner.


6. WHO DO WE SHARE YOUR PERSONAL DATA WITH AND WHY?


 1. With BNP Paribas Group's entities

As a member of the BNP Paribas Group, we work closely with the Group's other
companies worldwide.

Your personal data may therefore be shared between BNP Paribas Group entities,
where necessary, to:

 * comply with our various legal and regulatory obligations described above;
 * fulfil our legitimate interests which are:

 * to manage, prevent, detect fraud;
   * conduct statistical studies and develop predictive and descriptive models
     for business, security, compliance, risk management and anti-fraud
     purposes;
   * enhance the reliability of certain data about you held by other Group
     entities
   * offer you access to all the Group's products and services that best meet
     your needs and wishes;
   * customize the content and prices of products and services;

Your personal data may also be shared between Arval Group companies to conduct
statistical studies and develop predictive and descriptive models for business,
security, compliance, risk management and anti-fraud purposes.

In this context, we and such other Arval Group companies may act as joint
controllers by using a joint tool, through which there is shared access to and
mutual use of the personal data of customers and drivers.

Requests from data subjects regarding data subject rights may be submitted to
either of the joint controllers. The joint controllers inform each other about
such requests and support each other in order to address them.

The processing is based on the joint controllers' legitimate interest of
improving their products and services by conducting such statistical studies.

 1. With recipients outside the BNP Paribas Group and processors

In order to fulfil some of the purposes described in this Privacy Notice, we
may, where necessary, share your personal data with:

 * processors which perform services on our behalf (e.g., IT services,
   logistics, printing services, telecommunication, debt collection, advisory
   and distribution and marketing).
 * banking and commercial partners, independent agents, intermediaries or
   brokers, financial institutions, counterparties, trade repositories with
   which we have a relationship if such transmission is required to allow us to
   provide you with the services and products or execute our contractual
   obligations or transaction (e.g., banks, correspondent banks, depositaries,
   custodians, issuers of securities, paying agents, exchange platforms,
   insurance companies, payment system operators, issuers or payment card
   intermediaries, mutual guarantee companies or financial guarantee
   institutions);
 * local or foreign financial, tax, administrative, criminal or judicial
   authorities, arbitrators or mediators, public authorities or institutions
   (e.g., the Bank of England, Financial Conduct Authority), to which we, or any
   member of the BNP Paribas Group, are required to disclose pursuant to:
   * their request;
   * our defence, action or proceeding;
   * complying with a regulation or a recommendation issued from a competent
     authority applying to us or any member of the BNP Paribas Group;
 * service providers of third-party payment (information on your bank accounts),
   for the purposes of providing a payment initiation or account information
   service if you have consented to the transfer of your personal data to that
   third party;
 * certain regulated professions such as lawyers, notaries, or auditors when
   needed under specific circumstances (litigation, audit, etc.) as well as to
   our insurers or to an actual or proposed purchaser of the companies or
   businesses of the BNP Paribas Group.


7. INTERNATIONAL TRANSFERS OF PERSONAL DATA


In case of international transfers originating from the United Kingdom to
European Economic Area (EEA) and to a non-EEA country, the transfer of your
personal data may take place. Where the UK has recognised a non-EEA country as
providing an adequate level of data protection, your personal data may be
transferred on this basis.

For transfers to non-EEA countries where the level of protection has not been
recognized as adequate by the UK we will either rely on an exception applicable
to the specific situation (e.g. if the transfer is necessary to perform our
contract with you, such as when making an international payment) or implement
one of the following appropriate safeguards to ensure the protection of your
personal data:

 * Standard contractual clauses approved by the European Commission;
 * Contractual clauses authorised by the ICO;
 * Binding corporate rules;
 * An approved code of conduct;
 * Certification under an approved certification scheme.

To obtain a copy of these safeguards or details on where they are available, you
can send a written request as set out in Section 2 above.


8. HOW LONG DO WE KEEP YOUR PERSONAL DATA?


We will retain your personal data over the period required to comply with
applicable laws and regulations or another period with regard to our operational
requirements, such as proper account maintenance, facilitating customer
relationship management, and responding to legal claims or regulatory requests.

For instance:

 * Manage and report risk, monitor operations and transactions to identify
   deviation, prevent and detect fraud and fulfil tax control and notification
   obligations – 1 year after the end of the internal controls
 * KYC (Know Your Customer) - Perform a KYC analysis and check on clients (both
   companies and physical users) prior to signing a contract and classify them
   depending on the risk – 7 years after end of the contractual relationship
   with customer
 * Credit Risk Processing to build and monitor a credit risk file for each
   customer, manage credit risk analysis and decide what to do for credit
   collection – 7 years after end of the contractual relationship with customer
 * Invoice / Billing – Record transactions for accounting purposes and comply
   with legal obligations regarding financial security – 7years after the
   invoice date
 * Insurance claims - For vehicle accident management and insurance purposes – 7
   years after end of contractual relationship with the customer
 * Fines - Manage traffic and parking fines and offences related to the use of
   the Vehicle as part of the "Fines Management" service to the extent legally
   authorized – 1 year after event date
 * Improve the efficiency of our processes and services in case of complaint - 7
   years after the end of the contractual relationship with our customer
 * Collect all B2C/B2B2C leads and make an offer - 4 years after last contact
   date for B2B and 2 years for B2C
 * Provide customers with the products and services subscribed for services
   related to the preparation, delivery or use of vehicles - 7 years after the
   event date
 * Research & Development in order to conduct statistical studies and develop
   predictive models – Duration of the R&D project


9. HOW TO FOLLOW THE EVOLUTION OF THIS PRIVACY NOTICE


In a world where technologies are constantly evolving, we regularly review this
Privacy Notice and update it as required.

We invite you to review the latest version of this document online, and we will
inform you of any significant amendments through our website or through our
standard communication channels.


10. HOW IS MY PRIVACY PROTECTED WHEN I HAVE AN ARVAL CONNECTED MOTOR VEHICLE?


Data may be collected and used by Arval if your vehicle is equipped with a
telematics device, installed by the vehicle manufacturer and/or by Arval. 

If you would like to know if Data is collected from your vehicle by Arval (Arval
and/or manufacturer’s telematics device), please contact us at the following
address: dataprotection@arval.co.uk)
Arval may process such data to serve its legitimate interests as described in
the table below. The purposes of processing and the data retention time will not
exceed the indications provided below.

DATA

PURPOSES

RETENTION PERIOD

Mileage at the end of each day

Next maintenance dates (when applicable)

Vehicle dashboard alerts (when applicable)

DTC (Diagnostic Trouble Code) technical alerts (when applicable)

For Electric Vehicles: battery state of health

Pro-active proposal of adjustment of the individual lease contract (duration
and/or mileage)

Pro-active maintenance of the Motor Vehicle (alert about the next service and/or
maintenance of the Motor Vehicle)

Detection of alteration of odometer mileage display

Pro-active management of maintenance servicing. Preventive maintenance.
Pro-active management of contract (mileage/duration)

Pro-active management of maintenance servicing. Preventive maintenance.
Pro-active management of contract terms (mileage/duration)

Contract duration + 1 year

In case of a reported or suspected theft of the vehicle, theft protocols can be
initiated to give the geolocation of the vehicle, irrespective of whether the
telematics unit is in "Business" or "Private" mode

Geolocation positions collection when formal and official claim completed

In the event of bad debt or misappropriation: Geolocation positions collection
when formal and official claim completed

Optimize claims management

Increase the rate of stolen vehicle recovery

Increase the rate of vehicle recovery

Repair process improvement,

Facilitate and check the claims circumstances

Facilitate Claim Management

Decrease insurance fraud

Better identify Third Party Liability

Geolocation data once collected is stored until whichever is the later of 30
days after collection, or 30 days after the claim is closed

 

1 year

- Trip data: Start & stop Timestamps, mileage, driving time, type of road
(urban, road, motorway), fuel level and consumption, battery level for electric
vehicles, type of environment (day, night, twilight)

- Driving events per trip (harsh braking, cornering, brutal lane change, speed,
energy waste in braking, hard acceleration, idling) and related calculated
scores

These data are pseudonymised* within one to two months after collection and in
any case, prior to any use by Arval for the purposes listed in the next column.

Improve vehicle Knowledge

- Better understand vehicle model performance and maintenance costs

- Better identify mobility products depending on usage patterns and activity

Research and Development in relation to:

- Consulting: Energy transition, benchmark, correlation between conditions of
Motor Vehicle usage and TCO components / fuel and other energy or consumption

- Insurance: usage understanding, segmented offering

- Maintenance: uptime management, operational processes enhancements,
preventive/pro-active maintenance, tyres cost reduction and usage optimization,
cost optimization (oil, brake pads, etc…), battery potential defects, while
evaluating End of Contract mileage, repairs etc…

- Marketing: usage understanding, segmented offering opportunities

Carrying out statistics of claim rates in order to

 * find correlation risk level (car accidents) and usage patterns (for insurance
   purposes)
 * to better identify mobility products based on usage patterns and activity

Carrying out fuel consumption statistics in order to

 * Improve quality of service provided to the lessee and
 * provide advices about vehicles choices (relevant vehicle for a given use
   according to vehicle activity, fuel consumption, driving context)

Up to 10 years

* ‘PSEUDONYMISATION’ MEANS THE PROCESSING OF PERSONAL DATA IN SUCH A MANNER THAT
THE PERSONAL DATA CAN NO LONGER BE ATTRIBUTED TO A SPECIFIC DATA SUBJECT WITHOUT
THE USE OF ADDITIONAL INFORMATION, PROVIDED THAT SUCH ADDITIONAL INFORMATION IS
KEPT SEPARATELY AND IS SUBJECT TO TECHNICAL AND ORGANISATIONAL MEASURES TO
ENSURE THAT THE PERSONAL DATA ARE NOT ATTRIBUTED TO AN IDENTIFIED OR
IDENTIFIABLE NATURAL PERSON.
IF YOUR EMPLOYER SUBSCRIBES TO ARVAL CONNECT, YOUR EMPLOYER, AS CONTROLLER, WILL
INFORM YOU ABOUT THE PROCESSING ACTIVITIES CARRIED OUT FOR ITS OWN PURPOSES.



APPENDIX 1



PROCESSING OF PERSONAL DATA TO COMBAT MONEY LAUNDERING AND THE FINANCING OF
TERRORISM


We are part of a banking Group that must adopt and maintain a robust anti-money
laundering and countering the financing of terrorism (AML/CFT) programme for all
its entities managed at central level, an anti-corruption program, as well as a
mechanism to ensure compliance with international Sanctions (i.e., any economic
or trade sanctions, including associated laws, regulations, restrictive
measures, embargoes, and asset freezing measures that are enacted, administered,
imposed, or enforced by the French Republic, the European Union, the U.S.
Department of the Treasury’s Office of Foreign Assets Control, and any competent
authority in territories where BNP Paribas Group is established).
In this context, we act as joint controllers together with BNP Paribas SA, the
parent company of the BNP Paribas Group (the term “we” used in this appendix
therefore also covers BNP Paribas SA). 
To comply with AML/CFT obligations and with international Sanctions, we carry
out the processing operations listed hereinafter to comply with our legal
obligations:
-    A Know Your Customer (KYC) program reasonably designed to identify, verify
and update the identity of our customers, including where applicable, their
respective beneficial owners and proxy holders;
-    Enhanced due diligence for high-risk clients, Politically Exposed Persons
or “PEPs” (PEPs are persons defined by the regulations who, due to their
function or position (political, jurisdictional or administrative), are more
exposed to these risks), and for situations of increased risk;
-    Written policies, procedures and controls reasonably designed to ensure
that the Bank does not establish or maintain relationships with shell banks;
-    A policy, based on the internal assessment of risks and of the economic
situation, to generally not process or otherwise engage, regardless of the
currency, in activity or business:
o    for, on behalf of, or for the benefit of any individual, entity or
organisation subject to Sanctions by the French Republic, the European Union,
the United States, the United Nations, or, in certain cases, other local
sanctions in territories where the Group operates; 
o    involving directly or indirectly sanctioned territories, including
Crimea/Sevastopol, Cuba, Iran, North Korea, or Syria;
o    involving financial institutions or territories which could be connected to
or controlled by terrorist organisations, recognised as such by the relevant
authorities in France, the European Union, the U.S. or the United Nations.
-    Customer database screening and transaction filtering reasonably designed
to ensure compliance with applicable laws;
-    Systems and processes designed to detect and report suspicious activity to
the relevant regulatory authorities;
-    A compliance program reasonably designed to prevent and detect bribery,
corruption and unlawful influence pursuant to the French “Sapin II” Law, the U.S
FCPA, and the UK Bribery Act.
In this context, we make use of: 
o    services provided by external providers that maintain updated lists of PEPs
such as Dow Jones Factiva (provided by Dow Jones & Company, Inc.) and the
World-Check service (provided by REFINITIV, REFINITIV US LLC and London Bank of
Exchanges);
o    public information available in the press on facts related to money
laundering, the financing of terrorism or corruption; 
o    knowledge of a risky behaviour or situation (existence of a suspicious
transaction report or equivalent) that can be identified at the BNP Paribas
Group level.
We carry out these checks when you enter into a relationship with us, but also
throughout the relationship we have with you, both on yourself and on the
transactions you carry out. At the end of the relationship and if you have been
the subject of an alert, this information will be stored in order to identify
you and to adapt our controls if you enter into a new relationship with a BNP
Paribas Group entity, or in the context of a transaction to which you are a
party.  
In order to comply with our legal obligations, we exchange information collected
for AML/CFT, anti-corruption or international Sanctions purposes between BNP
Paribas Group entities. When your data are exchanged with countries outside the
European Economic Area that do not provide an adequate level of protection, the
transfers are governed by the European Commission’s standard contractual
clauses. When additional data are collected and exchanged in order to comply
with the regulations of non-EU countries, this processing is necessary for our
legitimate interest, which is to enable the BNP Paribas Group and its entities
to comply with their legal obligations and to avoid local penalties.


APPENDIX 2



AUTOMATED DECISIONS INCLUDING PROFILING


 AUTOMATED DECISIONS
 


SOME OF OUR PERSONAL DATA PROCESSING IS FULLY AUTOMATED AND LEADS TO A DECISION
ABOUT YOU WITHOUT HUMAN INTERVENTION, FOR EXAMPLE AUTOMATIC DECISION TO GRANT
FINANCING PRODUCTS TO CUSTOMERS (INCLUDING INDIVIDUALS AND COMPANIES).
IN ORDER TO MAKE THIS DECISION IN AN AUTOMATED WAY, WE BASE OURSELVES: 
•    ON THE DATA ENTERED (I.E. THE PURPOSE OF THE PRODUCT/SERVICE,
IDENTIFICATION INFORMATION, ETC.);
•    ON THE DATA AVAILABLE TO US IN THE CONTEXT OF OUR EXISTING RELATIONSHIP;
•    ON PUBLICLY AVAILABLE INFORMATION AS WELL AS INFORMATION THAT OTHER
AGENCIES ARE REQUIRED TO CONSULT. 
WE MAKE SURE THAT THE DATA WE USE IS AS UP TO DATE AS POSSIBLE IN ORDER FOR OUR
DECISION MODELS TO BE AS UP TO DATE AS POSSIBLE AND WE ADAPT THE MODELS TO THE
CUSTOMER'S PROFILE AND REVIEW THEM REGULARLY. 


PROFILING


AS PART OF THE PROCESSING OF YOUR PERSONAL DATA, WE USE VARIOUS PROFILING
TECHNIQUES TO ASSIST US WITH RUNNING OUR BUSINESS. BY “PROFILING” WE MEAN THE
AUTOMATED ANALYSIS OF PERSONAL DATA ABOUT A CUSTOMER TO EVALUATE CERTAIN THINGS
ABOUT THEM – BASICALLY DRAWING CONCLUSIONS ABOUT THE CUSTOMER BASED ON A
STATISTICAL MODEL. WE MAY USE THESE TECHNIQUES IN THE COURSE OF EVALUATING
APPLICATIONS FOR CARDS AND/OR LOANS FOR AFFORDABILITY AND SUITABILITY,
UNDERTAKING CREDIT LIMIT INCREASE ELIGIBILITY CHECKS, TO MANAGE YOUR ACCOUNT,
AND FOR MARKETING AND TARGETED ADVERTISING PURPOSES. WE MAY ALSO AUTOMATICALLY
DECIDE THAT YOU POSE A FRAUD OR MONEY LAUNDERING RISK OR IF OUR PROCESSING
REVEALS YOUR BEHAVIOUR TO BE CONSISTENT WITH THAT OF KNOWN FRAUDSTERS OR MONEY
LAUNDERERS; OR IS INCONSISTENT WITH YOUR PREVIOUS SUBMISSIONS; OR YOU APPEAR TO
HAVE DELIBERATELY HIDDEN YOUR TRUE IDENTITY.
YOU HAVE THE RIGHT TO CHALLENGE THE DECISION/PROFILING, EXPRESS YOUR VIEWS
AND/OR REQUEST THE INTERVENTION OF A COMPETENT PERSON TO REVIEW THE
DECISION/PROFILING.


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Arval UK Limited (Whitehill House, Windmill Hill, Swindon, SN5 6PE. Registration
number 1073098. VAT Registration GB 202 1441 76) is authorised and regulated by
the Financial Conduct Authority, under registration number 312798

 

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