4.1 DATA PERTAINING TO WEBSITE VISITORS

4.1.1 WEBSITES **4.1.1.a To communicate with you** *What does this purpose entail?* We collect your information when you contact us via one of our online contact forms, for example, when you send us questions, suggestions, compliments or complaints, or when you request a quote for our Services. This processing is done for the performance of an agreement that you have with us, to be able to respond to a request or with your consent. *Which personal information do we process for this purpose?* For this purpose, we collect your full name, gender, title, (business) contact details (including your email address, telephone number, name of your company) vehicle registration or registration number and any other information that you provide to us in the open field entry of the contact form, where you can, for example, pose your question, describe your suggestion, make a compliment or share a complaint. *With whom do we share your personal information?* See section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’.  **4.1.1.b For surveys or other (marketing) communication.** *What does this purpose entail?* We process your personal information when we request that you complete a survey on our website for feedback on our websites and/or Services, with your consent or for which we have a legitimate interest to process these data. With your consent or where we have a legitimate interest, we may send you marketing communication, to keep you updated on events, special offers, possibilities and current and future products and services of LeasePlan. When we contact you in regard of surveys or marketing communication, we will do so either by email, phone, or by postal mailings (newsletters /brochures/ magazines). If you would no longer like to receive surveys or marketing communication from us, please use the opt out options in the communication or contact your local LeasePlan entity via their webform for individuals’ rights on their local website or see the general contact details below. Based on your visit to a website of LeasePlan, we can show you personalized advertisements outside the LeasePlan website. To understand what is relevant to you, we can use manual and automatic tools to analyse your personal information. *Which personal information do we process for this purpose?* For this purpose, we process your name, your address, your email address and topics you may be interested in (as may be indicated by you on our website).  *With whom do we share your personal information?* See section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’. 4.1.2 SOCIAL MEDIA **4.1.2.a To facilitate social sharing functionality** *What does this purpose entail?* Our websites may contain various social media sharing functionalities, such as Facebook, Twitter or LinkedIn buttons, which, with your consent, you may use to share information provided on our websites with the social media of your choosing. Our websites may also contain links to our own social media pages, such as our LeasePlan Facebook or LinkedIn pages or our Twitter feed, which you may choose to use to post feedback. Likewise, various social media websites, such as Snapchat, Facebook, Twitter or LinkedIn, may contain LeasePlan advertisements containing links to our websites. These social media websites may, with your consent, share information provided by you with us when you choose to follow a link to one of our websites. Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, Apple, Twitter, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including any personal information you disclose to other organizations through or in connection with our social media functionalities and/or advertisements. Processing of personal information is subject to privacy policies and practices of these other organizations. *Which personal information do we process for this purpose?* For this purpose, we process your name, email address, IP-address, photo, list of social media contacts and any other information that may be accessible by us when using social media functionalities. *With whom do we share your personal information?* See section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’. 4.1.3 COOKIES AND SIMILAR TECHNOLOGIES Any processing of your personal information via cookies and/or similar technologies will take place in accordance with our Cookie Statement. 4.1.4 LEASEPLAN BUSINESS PURPOSES **4.1.4.a Management reporting** *What does this purpose entail?* We process your personal information for various business purposes, for which we have a legitimate interest to process these data, such as data analysis, audits, developing new products, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities. To facilitate your use of our online services or applications, we may analyse data that we collect when using our digital media and combine it with information collected via cookies. For example, to better understand which digital channel (Google search, e-mail, social media) or device (desktop, tablet or mobile) you prefer, we can optimize or limit our communication and marketing activities by channel and by device. *Which personal information do we process for this purpose?* For this purpose, we may process your name, your email address, your IP address, gender, date of birth, place of residence, digits of your post code and any other information mentioned in this Privacy Statement or otherwise provided to us by you, if such is required for one of the purposes mentioned in the previous paragraph.  *With whom do we share your personal information?* See section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’. **4.1.4.b Compliance with laws and legal obligations and protection of LeasePlan assets and interests** *What does this purpose entail?* To comply with a legal obligation or where we have a legitimate interest, we process your personal information as appropriate or necessary:  (a) under applicable law, including laws outside your country of residence and including sectorial recommendations (e.g. counterparty due diligence, money laundering, financing of terrorism and other crimes); (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions and other applicable policies; (e) to protect our operations; (f) to protect our rights, privacy, safety or property, and/or that of yours or others; and  (g) to allow us to pursue available remedies or limit the damages that we may sustain. *Which personal information do we process for this purpose?* For this purpose, we process your name, your contact information, your correspondence with LeasePlan, your use of any of our Services and any other information mentioned in this Privacy Statement or otherwise provided to us by you, if such is required for one of the purposes mentioned in the previous paragraph. *With whom do we share your personal information?* Only if we are required to do so by law or sectorial recommendation to which LeasePlan is subject, your personal information will be provided to supervisory agencies, fiscal authorities and investigative agencies. See also section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’.

4.2 DATA PERTAINING TO CLIENTS AND PROSPECTIVE CLIENTS

4.2.1 CLIENT ACCOUNT MANAGEMENT **4.2.1.a To provide, manage and administer the Client account** *What does this purpose entail?* We collect your personal information to handle day-to-day management and administration of the Client accounts, such as maintaining contracts and keep you informed of all important developments concerning the Services and other information which is relevant for the Client contract and account. This processing is based on the performance of the lease agreement that we have with you or based on a legal obligation. *Which personal information do we process for this purpose?* For this purpose, we may process business contact details and log-in details to our Client online accounts. *With whom do we share your personal information?* See section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’. **4.2.1.b To communicate with you** *What does this purpose entail?* You can contact us by various means (such as email or telephone, or via our website). In this case we will use your personal information to answer your question/request. We can also contact you, for example, regarding day-to-day management and administration of your Client account. This processing is based on our legitimate business interest and relates *Which personal information do we process for this purpose?* For this purpose, we may process your name, your business contact details, your correspondence with LeasePlan pertaining to your question/request and all other personal information you provide to us and/or which is necessary to appropriately respond to you.   *With whom do we share your personal information?* See section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’. **4.2.1.c For surveys or other (marketing) communication** *What does this purpose entail?* We process your personal information to send you surveys, for which we have a legitimate interest to process these data. With your consent or where we have a legitimate interest, we may send you marketing communication, for example, to keep you updated on events, special offers, possibilities and current and future products and services of LeasePlan. We will send you such surveys in the form of either a periodic email or an email to request your feedback on our Services and other services performed on the vehicle. We may also send you postal mailings (newsletters/brochures/magazines). To understand what is relevant to you, we can use manual and automatic tools to analyse your personal information. If you would no longer like to receive surveys or marketing communication from us, please opt out or contact us via the local LeasePlan entity [webform](targetBlank:https://privacyportal-eu.onetrust.com/webform/396c853c-7bbe-43bb-9c80-0001fd327955/a92e1963-3828-444d-be01-0f0e551a86da) for individuals’ rights or via the contact details set out below. To facilitate your use of our online Services or applications, we may analyse data that we collect when using our digital media and combine it with information collected via cookies. For example, to better understand which digital channel (Google search, e-mail, social media) or device (desktop, tablet or mobile) you prefer, we can optimize or limit our communication and marketing activities by channel and by device. *Which personal information do we process for this purpose?* For this purpose, we may process your name and your business contact details. *With whom do we share your personal information?* See section [‘Sharing data with third parties’.](targetSelf:#Paragraph14) 4.2.2 LEASEPLAN PREMISES **4.2.2.a Access to and security control of LeasePlan premises** *What does this purpose entail?* We may process your personal information when you visit us on our premises for the purpose of ensuring appropriate access controls and security, for which we have a legitimate interest (safety and security of our assets). *Which personal information do we process for this purpose?* For this purpose, we may process your name, your contact information and the person you are visiting. We may also process video and/or audio information about you through video/audio recording equipment, such as for instance CCTV. *With whom do we share your personal information?* See section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’.   4.2.3 CLIENT REPORTING **4.2.3.a MyFleet** *What does this purpose entail?* We provide the online reporting tool ‘MyFleet’. Clients’ contact persons can log onto these tools to review the status of their fleet, damage reporting, contract management and to use other fleet reporting functionalities, such as dashboard reporting, trend analysis reporting, vehicle mileage and end of lease term. This processing is done based on our legitimate interest and relates to the performance of the lease agreement that we have with our Client. *Which personal information do we process for this purpose?* For this purpose, we collect contact details and job function (e.g.,(International) Fleet Manager) of Client's contact person, and login details (e.g., username and password). *With whom do we share your personal information?* See section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’. 4.2.4 LEASEPLAN BUSINESS PURPOSES **4.2.4.a Management reporting** *What does this purpose entail?* We process your personal information for various business purposes, for which we have a legitimate interest to process these data, such as data analysis, audits, developing new products, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities. To facilitate your use of our online services or applications, we may analyse data that we collect when using our digital media and combine it with information collected via cookies. For example, to better understand which digital channel (Google search, e-mail, social media) or device (desktop, tablet or mobile) you prefer, we can optimize or limit our communication and marketing activities by channel and by device. *Which personal information do we process for this purpose?* For this purpose, we may process various information that we collect in the context of providing our Services (such as your name, contact details, fleet details etc.), as needed for one of the purposes set out above. *With whom do we share your personal information?* See section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’. **4.2.4.b Compliance with laws and legal obligations and protection of LeasePlan assets and interests** *What does this purpose entail?* To comply with a legal obligation or where we have a legitimate interest, we process your personal information as appropriate or necessary: (a) under applicable law, including laws outside your country of residence and including sectorial recommendations (e.g. counterparty due diligence, money laundering, financing of terrorism and other crimes); (b) credit checks (c) to comply with legal process; (d) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (e) to enforce our terms and conditions and other applicable policies; (f) to protect our operations; (g) to protect our rights, privacy, safety or property, and/or that of yours or others; and (h) to allow us to pursue available remedies or limit the damages that we may sustain. *Which personal information do we process for this purpose?* For this purpose, we process the name, contact information, the date, place and country of birth of the ultimate beneficial owner of the counterparty that LeasePlan want to do business with; we may also process the name, address and the date, place and country of birth of the person(s) who represent the company towards LeasePlan; your correspondence with LeasePlan, your use of Services and any other information mentioned in this Privacy Statement, if such is required for one of the purposes mentioned in the previous paragraph. *How We Make Decisions About You* We may use automated systems to help us make some of our decisions, for example, when you apply for products and services, to make credit decisions and to carry out fraud and money laundering checks, as described elsewhere in this statement. Using automated decisions helps us to make sure they are quick, fair, efficient and correct, based on what we know. This processing is necessary for our own legitimate interests of protecting our business from risk and ensuring compliance with regulatory requirements. You may have a right to certain information about how we make these decisions and to ask for an automated decision to be reviewed or made by a person. See Section 9 [‘Your Rights and Contacting Us’](targetSelf:#Paragraph18) for more information. *With whom do we share your personal information?* Only if we are required to do so by law or sectorial recommendation to which LeasePlan is subject, your personal information will be provided to supervisory agencies, fiscal authorities and investigate agencies. See section [‘Sharing data with third parties’.](targetSelf:#Paragraph14) 

4.3 DATA PERTAINING TO DRIVERS (EMPLOYEES OF OUR CLIENTS)

4.3.1 DRIVER CONTACT **4.3.1.a To communicate with you** *What does this purpose entail?* You can contact us by various means (such as email or telephone, or via our website). In this case we will use your personal information to answer your question/request. We can also contact you in relation to your vehicle or other relevant driver-related issues. In relation to you this processing is based on our legitimate interest and is part of delivering the Services to you and your employer under the lease agreement that we have with your employer) or with your consent where this is required. *Which personal information do we process for this purpose?* For this purpose, we process your name, your contact information, your correspondence with LeasePlan pertaining to your question/request and all other personal information you provide to us and/or which is necessary to appropriately respond to you, including your vehicle registration number. For quality and training purposes we may also record your telephone calls with customer services departments for which we have a legitimate business interest. *With whom do we share your personal information?* We share your information with a third party with whom we have an agreement for making online payments, such as the deposit payment and the monthly payments of the lease amount. We only share information that is necessary for the execution of the payments. See section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’. **4.3.1.b For surveys or other (marketing) communication** *What does this purpose entail?* We process your personal information when we send you periodic surveys to request your feedback on our Services and other services performed on the vehicle, for which we have a legitimate interest to process these data. With your consent (where this is required) or where we have a legitimate interest, we may send you marketing communication, to keep you updated on events, special offers, possibilities and current and future products and services of LeasePlan. When we contact you in regard of surveys or marketing communication, we will do so either by email or by postal mailings (newsletters/brochures/magazines). To understand what is relevant to you, we can use manual and automatic tools to analyse your personal information. If you would no longer like to r marketing communication from us, please use the opt out options in the communication or contact your local LeasePlan entity via their [webform](targetSelf:https://privacyportal-eu.onetrust.com/webform/396c853c-7bbe-43bb-9c80-0001fd327955/a92e1963-3828-444d-be01-0f0e551a86da) for individuals’ rights on their local website or see the general contact details below. *Which personal information do we process for this purpose?* For this purpose, we process your name, your address, your email address, your vehicle registration number and your interests (as indicated by you). *With whom do we share your personal information?* See section [‘Sharing data with third parties’.](targetSelf:#Paragraph14)   4.3.2 VEHICLE SERVICES **4.3.2.a Management of the vehicle** *What does this purpose entail?* We process your information in relation to administering your use of the vehicle and to handle the day-to-day management of the vehicle, for which we have a legitimate interest, and this is also related to delivering the Services to you and your employer under the lease agreement that we have with your employer. *Which personal information do we process for this purpose?* For this purpose, we process your name, address, (company) email address, lease category, vehicle registration number, make and model, service history and operational contact with you. In addition, you may provide certain information pertaining to vehicle management to us through the LeasePlan portal, or when you call LeasePlan or to one of our suppliers. *With whom do we share your personal information?* We share information pertaining to management of the vehicle with our Clients (your employer). See section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’.    **4.3.2.b Repair, maintenance and tyres** *What does this purpose entail?* We process your information in relation to providing (scheduled) repair and maintenance Services and tyres Services and to analyse, predict and pro-actively steer on maintenance and repairs. for your vehicle, for which we have a legitimate interest, and this is also related to delivering the Services to you and your employer under the performance of the lease agreement that we have with your employer. *Which personal information do we process for this purpose?* For this purpose, we collect your name, address, (company) email address, vehicle registration number, make and model, service history and operational contact with you. In addition, you may provide certain information to us through the LeasePlan portal (e.g., your phone number to make an appointment for maintenance of the car), or when you call LeasePlan.   *With whom do we share your personal information?* We share information with our Clients (your employer) and with third parties performing maintenance/repair on the vehicle or changing or replacing tyres, such as dealers/garages, body repair shops or car fitters. See also section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’. **4.3.2.c Accident management** *What does this purpose entail?* We process your information by recording and administering accidents that you and/or your vehicle may have been involved in, to restore mobility and handle damage. We will do so by (i) giving you an opportunity to report accidents as they happen at our Customer Call Center, (ii) providing, where applicable, roadside assistance and/or a replacement vehicle and (iii) arranging repair and other necessary follow-up. This processing is based on our legitimate interest and this this is also related to delivering the Service to you and your employer under the performance of the lease agreement that we have with your employer. We may also use this information for assessing damage repairs under our damage handling and risk retention policies, for which we have a legitimate interest to process these data. We may also be required to process special category data. These may include (i) data relating to traffic or driving offences and our lawful reason for processing these would be that it is in the substantial public interest and that it is necessary for establishing or defence to legal claims if necessary or (ii) medical reports or similar health related information and if we do process these we will obtain your specific consent to do so and to share these with any necessary third parties. *Which personal information do we process for this purpose?* For this purpose, we collect the following personal information: - Ourselves: vehicle registration number, make and model, service history and operational contact with you. - From you: your name, contact details, vehicle details, accident details, damage details, photos of the incident, date of birth, number of passengers in the vehicle, information of witnesses to the accident (if applicable) and any other information you choose to provide to us in the context of the accident (including any information pertaining to possible injuries). - From third parties, such as individuals involved in the accident or insurance companies: information of third parties involved in the accident/incident (such as the identity of your passengers, driver and passengers of third-party vehicles, and other third parties involved), information of other third parties (such as witnesses, investigating police officers and others) insurance information, information about the incident and third- party claims. - From authorities (such as police): your name, address, vehicle registration number, information regarding the accident, police reports and witness statements. *With whom do we share your personal information?* We share this information with our Client (your employer) through our tool MyFleet. We may also share certain information with dealers/garages, body repair shops, car fitters, car insurance companies(which may be both affiliated and third-party car insurance companies) and professional experts employed on our behalf or on behalf of third parties (such as lawyers, medical experts, investigators, etc.) for the purpose of damage or claim resolution. See also section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’. **4.3.2.d Traffic and parking fines management** *What does this purpose entail?* The following may depend on the country where Drivers may have committed traffic and/or parking violations: As the registered owner of the vehicles, traffic and/or parking fines incurred by Drivers of the vehicles may be addressed to LeasePlan by the authority that issued a specific traffic or parking fine (such as police or local municipality). We process your personal information for the purpose of processing and managing the payment of the fine and, if applicable, obtaining reimbursement from our Client (your employer), for which we have a legitimate interest to process these data. We may also be required to process special category data. These may include data relating to traffic or driving offences and our lawful reason for processing these would be that it is in the substantial public interest and that it is necessary for establishing or defence to legal claims if necessary. *Which personal information do we process for this purpose?* We process information that we receive from the competent authorities (such as police or local municipalities): your name, address and vehicle registration number, the and time of the offense/incident committed by you and the imposed fines. *With whom do we share your personal information?* LeasePlan may need to share this information with our Client (your employer) in certain situations, for example, when leased vehicles are used in carpools and LeasePlan does not know who the actual driver of a specific vehicle is. See also section '[Sharing data with third parties](targetSelf:#Paragraph14)'. **4.3.2.e Fuel card, EV charging and tolls** *What does this purpose entail?* Our Services may include a fuel management program, which allows you to, for example, pay for your fuel at petrol stations using a LeasePlan issued or managed payment mechanism. In case you have an Electric Vehicle, you may be provided with an EV charging card for charging your vehicle at charge points. We may also arrange for the placement of an EV charge station. This processing is based on our legitimate interest and is also related to delivering the Service to you and your employer under the performance of the lease agreement that we have with your employer. We may further collect certain information to manage toll-related activities of a fleet. *Which personal information do we process for this purpose?* For this purpose, we collect the following information: your name, contact information, email address, fuel or EV charging card number, charging station number, address, phone number, vehicle registration number, fuel information, mileage and related costs. In case of re- imbursements, we may also need to collect bank account information. We may also collect toll-related information, such as information on location, time and costs. *With whom do we share personal information?* LeasePlan needs to share the information with the fuel card/ EV charging solution/ payment company. Also our Clients (your employer) may have access to certain personal information made available by us on our Internet or e-Mobility portal or online reporting tool ‘MyFleet’. Clients can log in and review the status of their fleet (e.g., mileage), and use other fleet reporting functionalities (e.g., dashboard reporting on fuel consumption and fuel price and trend analysis reporting). Via MyFleet Clients can also request fuel cards or EV charging cards. See also section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’. 4.3.3 MOBILITY SERVICES **4.3.3.a Renting** *What does this purpose entail?* We collect your personal information to provide our rental program services, so that you can, for example, reach LeasePlan’s rental specialists through our Customer Contact Center, rent a vehicle from the most appropriate rental location or have a rental vehicle delivered to you. This processing is based on our legitimate interest, and this is also related to delivering the Service to you and your employer under the performance of the lease agreement that we have with your employer) or if applicable the agreement that you have with us. *Which personal information do we process for this purpose?* For this purpose, we collect: your name, email, mobile phone number, car vehicle registration number, related costs, delivery location, rental time and company contact person. *With whom do we share your personal information?* We share your data with LeasePlan's (external) rental specialists. See also section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’. **4.3.3.b Roadside assistance** *What does this purpose entail?* When you experience a car malfunction, for example, a flat tyre or mechanical difficulties while on the road, LeasePlan is able to arrange roadside assistance, for which we work closely with contracted third parties. This processing is based on our legitimate interest and is also related to delivering the Service to you and your employer under the performance of the lease agreement that we have with your employer). *Which personal information do we process for this purpose?* For this purpose, we collect the following information: your name, email address, mobile phone number, vehicle registration number and location of where assistance was needed and provided.   *With whom do we share your personal information?* We share information with third parties providing on the road repair services, towing services or a replacement car. See also section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’.  4.3.4 DRIVER SAFETY PROGRAM **4.3.4.a To prepare, manage, and administer trainings** *What does this purpose entail?* We provide various driver safety and risk management training programs in order to analyse and improve driving behavior, promote Client’s proactive commitment to safety and good corporate citizenship, decrease accident rates, validate the effectiveness of Client’s overall safety initiatives and identify communication and training opportunities. We engage third parties for administering and executing such safety programs, who will contact you to initiate a safety assessment and provide the actual training courses (either online or in a classroom setting). Any personal data collected by the third party in relation to this is subject to the privacy practices of such third party. We receive back from these third parties your ‘driver risk index’ (information about potential risks identified through questionnaire processes), trainings that have been recommended, signed up for and completed. This processing is based on our legitimate interest and is also related to delivering the Service to you and your employer under the performance of the lease agreement that we have with your employer) or on your consent. *Which personal information do we process for this purpose?* For this purpose, we collect/process the following personal information: - Directly from Clients (your employer): your name, (company) email address and vehicle registration number. - From third parties engaged by us: driver risk index, trainings recommended, trainings signed up for, and trainings completed.  *With whom do we share your personal information?* We share your information with third parties engaged by us to administer and execute the driver safety programs, as well as with our Clients (your employer). See also section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’.  4.3.5 ONLINE PORTALS AND APPS **4.3.5.a Various portals and apps for drivers** *What does this purpose entail?* Depending on the country you live in, we provide online portals and apps that have a number of functionalities. For example, through our portals and apps you can find practical information about your lease vehicle, change your name, contact details and other personal information, report damage to your vehicle, schedule appointments for repairs, maintenance or changing tyres through online appointment planners, contact our Driver Contact Centers, view and pay fines claim (fuel) expenses and, in case you have an electric vehicle, manage charging. We may also provide you with dashboard-type overview that can provide you insight into your use of the vehicle (such as your average fuel efficiency, your damages, etc.). This processing is based on our legitimate interest and this is also related to delivering the Service to you and your employer under the performance of the lease agreement that we have with your employer) or with your consent. *Which personal information do we process for this purpose?* We receive your name and email address from your employer (our Client) to provide you with LeasePlan generated log-in data (username and temporary password) so that you can access our various online portals and apps.  *With whom do we share your personal information?* See section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’. **4.3.5.b MyFleet** *What does this purpose entail?* MyFleet entails dashboard reporting on a country and/or international level to our Clients (your employer). MyFleet allows Clients for instance to access and evaluate the mileage or the remaining lease period of individual vehicles. We also use the data contained in this fleet reporting tool to provide (aggregated) insights to our Clients (your employer) into key aspects of their country’s fleet management (such as cost and risk issues) for the purpose of implementing a balanced fleet management approach (cost, environment and safety), managing fleet policy implementation, having the ability to report on global carbon emission as part of the Client’s corporate social responsibility obligations and compliance, assessing the effectiveness of policy changes and proactively communicating relevant fleet developments. This processing is based on our legitimate interest and is also related to delivering the Service to you and your employer under the performance of the lease agreement that we have with your employer). By way of example, on the basis of such dashboard reporting, each Client has access to (i)various data pertaining to the CO2 emissions of its vehicle fleet per country, and (ii) measures proposed by LeasePlan to reduce the fleet’s environmental impact. LeasePlan and the Client can then study and discuss the company’s fleet/vehicle policies and set targets in order to achieve a lasting reduction of fuel, CO2 emissions and other car expenses. Thus, based on such information, each Client can take informed decisions aimed at reducing CO2 emissions within its fleet in a certain country, e.g., by providing eco-driving style training to its Drivers or acquiring more climate neutral vehicles. *Which personal information do we process for this purpose?*  For this purpose, we may process the following personal information: - From our Client (your employer): Driver name, Client-generated Driver ID, name and contact details of Client’s contact person, (email) address, telephone number, nationality, social insurance number (optional: only if required by applicable law or for fiscal purposes) and use of fuel card (optional). - Ourselves: vehicle details (e.g., make, model, registration number, vehicle registration number), remaining contract duration, damages sustained by a vehicle, fuel type, number and type of fuel card, fuel consumption and insurance data. - From Driver: mileage and description of damages sustained by a vehicle involved in a car accident. - Data received from others (such as police, local authorities, service garage/center): traffic and/or parking fines, mileage and information on vehicle maintenance and repairs. *With whom do we share your personal information?* We share this information with the authorised (International) Fleet Manager of the Client. See also section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’ 4.3.6 LEASEPLAN BUSINESS PURPOSES **4.3.6.a Management reporting** *What does this purpose entail?* We process your personal information for various business purposes, for which we have a legitimate interest to process these data, such as data analysis, audits, developing new products, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities. To facilitate your use of our online services or applications, we may analyse data that we collect when using our digital media and combine it with information collected via cookies. For example, to better understand which digital channel (Google search, e-mail, social media) or device (desktop, tablet or mobile) you prefer, we can optimize or limit our communication and marketing activities by channel and by device. *Which personal information do we process for this purpose?* For this purpose, we may process various information that we collect in the context of providing our Services (such as your name, contact details, vehicle details etc.), as needed for one of the purposes set out above. *With whom do we share your personal information?* See section '[Sharing data with third parties](targetSelf:#Paragraph14)'. **4.3.6.b Compliance with laws and legal obligations and protection of LeasePlan assets and interests** *What does this purpose entail?* To comply with a legal obligation or where we have a legitimate interest, we process your personal information as appropriate or necessary: (a) under applicable law, including laws outside your country of residence and including sectorial recommendations (e.g., counterparty due diligence, money laundering, financing of terrorism and other crimes); (b) part of credit check process (c) to comply with legal process; (d) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (e) to enforce our terms and conditions and other applicable policies; (f) to protect our operations; (g) to protect our rights, privacy, safety or property, and/or that of yours or others; and (h) to allow us to pursue available remedies or limit the damages that we may sustain. If you and your employer have given consent, LeasePlan can also analyse information about your vehicle(s) if you have already leased a car via LeasePlan, for example to determine the lease price of your new lease car. *Which personal information do we process for this purpose?* For this purpose, we process your name, your contact information, your correspondence with LeasePlan, your use of Services and any other information mentioned in this Privacy Statement, if such is required for one of the purposes mentioned in the previous paragraph. *How We Make Decisions About You* We may use automated systems to help us make some of our decisions, for example, when you apply for products and services, to make credit decisions and to carry out fraud and money laundering checks, as described elsewhere in this statement. Using automated decisions helps us to make sure they are quick, fair, efficient and correct, based on what we know. This processing is necessary for our own legitimate interests of protecting our business from risk and ensuring compliance with regulatory requirements. You may have a right to certain information about how we make these decisions and to ask for an automated decision to be reviewed or made by a person. See Section 9 ‘[Your Rights and Contacting Us](targetSelf:#Paragraph18)’ for more information. *With whom do we share your personal information?* Only if we are required to do so by law or sectorial recommendation to which LeasePlan is subject, your personal information will be provided to supervisory agencies, fiscal authorities and investigative agencies. See also section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’.

4.4 DATA PERTAINING TO PRIVATE LEASE CLIENTS (INCLUDING SOLE TRADERS AND PARTNERSHIPS) AND PROSPECTIVE CLIENTS

4.4.1 SIGN UP **4.4.1.a To be able to accept you as a client** *What does this purpose entail?* We collect information when you sign up (via our website or otherwise) as a client. This processing is required for the conclusion and performance of the lease agreement, including assessment, verification of your identity and acceptance of you as a client and any credit checks.. *Which personal information do we process for this purpose?* For this purpose, we collect your name, gender, title, address, contact details (including your email address, telephone number, driver’s license, delivery address or pick-up location, transaction data (such as order, amount(s) to be paid, date of payment), your bank account number and the authorization you give to LeasePlan.   *With whom do we share your personal information?* We share your information with a third party with whom we have an agreement for making online payments, such as the deposit payment and the monthly payments of the lease amount. We only share information that is necessary for the execution of the payments. See also section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’. **Credit Reference Checks** This section is only relevant to you if you are an individual, sole trader or partnership who applies to lease a vehicle from us. Credit reference checks are conducted to assess your financial position, to verify the accuracy of the data you have provided to us and to meet our regulatory expectations in respect of financial crime and integrity and conduct risk management. This process may include personal data. The information used for these checks is the information, including any personal data, you have provided to us in the vehicle application process. Furthermore we may use external credit reference agencies to conduct these checks for us and thus supply your data to them or to have you supply your data directly to them. External credit reference agencies will also use publicly available information about you. This is necessary for our own legitimate interests of protecting our business from financial crime and compliance and integrity risk and it is also necessary for our compliance with legal obligations. The identities of the Credit Reference Agencies (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 within the Credit Reference Agencies Information Document (CRAIN) available on their websites. You have a right to apply to the CRAs for a copy of your file. The information they hold may not be the same and there is a small fee that you may need to pay to each agency. Here are links to the information notice for each of the three main Credit Reference Agencies: [https://www.equifax.co.uk/crain/](targetBlank:https://www.equifax.co.uk/crain/) [https://www.transunion.co.uk/legal/consumer-centre#pc-credit-reference](targetBlank:https://www.transunion.co.uk/legal/consumer-centre#pc-credit-reference) [https://www.experian.co.uk/legal/crain/](targetBlank:https://www.experian.co.uk/legal/crain/) **Fraud Checks** The personal data that we have collected from you or which has otherwise been disclosed to us in relation to you will be shared with Fraud Prevention Agencies (FPAs). We and FPAs will use this information to prevent fraud and money-laundering and to verify your identity, and we use compliance screening software tools. This is necessary for our own legitimate interests of protecting our business from financial crime and compliance and integrity risk and it is also necessary for our compliance with legal obligations. If fraud is detected, or the outcome of these screenings is negative and do not meet LeasePlan requirements you could be refused certain services, finance or employment in future, or you could be refused a contract or business relationship or have this terminated. If fraud is found the record may be retained for up to six years and passed to law enforcement by FPAs. For further details of how your information will be used by us and the FPAs, and your data protection rights, please contact us using the webform for individuals’ rights or contact the FPAs using the details below. These Checks and related sharing of personal data are relevant at the application stage and periodically during the term of this Agreement. You are entitled to request a copy of information held about you by the FPAs. This is known as a data subject access request. For further information please contact the FPAs using the contact details in the links below. FPAs and other organisations we share data with for these purposes may send personal data to countries outside the UK. When they do, they must ensure the recipient protects the data to the same standard as the UK. Here is the link to the information notice for the Fraud Prevention Agency we use: CIFAS [https://www.cifas.org.uk/fpn](targetBlank:https://www.cifas.org.uk/fpn) to submit a data subject access request https://www.cifas.org.uk/dsar National Hunter [https://www.nhunter.co.uk/privacypolicy/](targetBlank:https://www.nhunter.co.uk/privacypolicy/) *How We Make Decisions About You* We may use automated systems to help us make some of our decisions, for example, when you apply for products and services, to make credit decisions and to carry out fraud and money laundering checks, as described above. Using automated decisions helps us to make sure they are quick, fair, efficient and correct, based on what we know. This processing is necessary for our own legitimate interests of protecting our business from risk and ensuring compliance with regulatory requirements. You may have a right to certain information about how we make these decisions and to ask for an automated decision to be reviewed or made by a person. See Section 9 ‘[Your Rights and Contacting Us](targetSelf:#Paragraph19)’ for more information. **4.4.1.b Portals and apps**  *What does this purpose entail?* Depending on the country you live in, we offer you online portals or apps. Via these portals or apps, you can find practical information on your lease car, your contact information and other personal information, report changes thereto, report damage to your vehicle, record appointments for repairs, maintenance or tyre change, contact our customer service, consult and pay fines. This processing is required for the performance of the lease agreement or done with your consent. *Which personal information do we process for this purpose?* For this purpose, we collect your name and email address to send you a temporary password, which you will need to use the platform and apps. *With whom do we share your personal information?* See section '[Sharing data with third parties](targetSelf:#Paragraph14)'. 4.4.2 CONTACT **4.4.2.a To communicate with you** *What does this purpose entail?* You can contact us by various means (such as via email, telephone, our website). In this case we use your personal information to answer your question/request. We can also contact you in relation to the private lease contract. This processing is required for the performance of the lease agreement or with your consent. *Which personal information do we process for this purpose?* For this purpose, we may process your name, your contact information, your correspondence with LeasePlan pertaining to your question/request and all other personal information you provide to us and/or which is necessary to appropriately respond to you, (incl. your vehicle registration number), the agreed term of the private lease contract and your financial obligations to us. *With whom do we share your personal information?* See section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’. **4.4.2.b For surveys or other (marketing) communication.** *What does this purpose entail?*  We process your personal information when we send you periodic surveys to request your feedback on our Services and other services performed on the vehicle, for which we have a legitimate interest to process these data. With your consent or where we have a legitimate interest we may send you marketing communication, to keep you updated on events, special offers, possibilities and current and future products and services of LeasePlan. When we contact you in regard of surveys or marketing communication, we will do so either by email or by postal mailings (newsletters/brochures/magazines). To understand what is relevant to you, we can use manual and automatic tools to analyse your personal information. If you would no longer like to receive surveys or marketing communication from us, please use the opt out options in the communication or contact your local LeasePlan entity via their [webform](targetBlank:https://privacyportal-eu.onetrust.com/webform/396c853c-7bbe-43bb-9c80-0001fd327955/a92e1963-3828-444d-be01-0f0e551a86da) for individuals’ rights on their local website or see the general contact details below. *Which personal information do we process for this purpose?* For this purpose, we process your name, your address, your email address, your vehicle registration number and topics you may be interested in (as may be indicated by you on our website)..  *With whom do we share your personal information?* See section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’. 4.4.3 VEHICLE SERVICES **4.4.3.a Management of the vehicle** *What does this purpose entail?* We process your information in relation to administering your use of the vehicle and to handle the day-to-day management of the vehicle. This processing is required for performance of the lease agreement.  *Which personal information do we process for this purpose?* For this purpose, we process your name, address, (company) email address, lease category, vehicle registration number, make and model, service history and operational contact with you. In addition, you may provide certain information pertaining to vehicle management to us through the LeasePlan portal, or when you call LeasePlan. *With whom do we share your personal information?* See section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’.  **4.4.3.b Repair, maintenance, and tyres** *What does this purpose entail?* We process your information in relation to providing (scheduled) repair and maintenance Services and tyres Services for your vehicle and to analyse, predict and pro-actively steer on maintenance and repairs. for this processing we have a legitimate business interest and is required for performance of the lease agreement. *Which personal information do we process for this purpose?* For this purpose, we collect your name, address, (company) email address, vehicle registration number, make and model, service history and operational contact with you. In addition, you may provide certain information to us through the LeasePlan portal (e.g., your phone number to make an appointment for maintenance of the car), or when you call LeasePlan. *With whom do we share your personal information?* We share information with third parties performing maintenance/repair on the vehicle or changing or replacing tyres, such as dealers/garages, body repair shops or car fitters. See also section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’. **4.4.3.c Accident management** *What does this purpose entail?* We process your information by recording and administering accidents that you and/or your vehicle may have been involved in, to restore mobility and handle damage. We will do so by (i) giving you an opportunity to report accidents as they happen at our Customer Call Center, (ii) providing, where applicable, roadside assistance and/or a replacement vehicle and (iii) arranging repair and other necessary follow-up. This processing is required for the performance of the lease agreement. We may also use this information for assessing damage repairs under our damage handling and risk retention policies, for which we have a legitimate interest to process these data. We may also be required to process special category data. These may include (i) data relating to traffic or driving offences and our lawful reason for processing these would be that it is in the substantial public interest and that it is necessary for establishing or defence to legal claims if necessary or (ii) medical reports or similar health related information and if we do process these we will obtain your specific consent to do so and to share these with any necessary third parties. *Which personal information do we process for this purpose?* For this purpose, we collect the following personal information: - Ourselves: vehicle registration number, make and model, service history and operational contact with you. - From you: your name, contact details, vehicle details, accident details, damage details, photos of the incident, date of birth, number of passengers in the vehicle, information of witnesses to the accident (if applicable) and any other information you choose to provide to us in the context of the accident (including any information pertaining to possible injuries). - From third parties, such as individuals involved in the accident or insurance companies: information of third parties involved in the accident/incident (such as the identity of your passengers, driver and passengers of third-party vehicles, and other third parties involved), information of other third parties (such as witnesses, investigating police officers and others) insurance information, information about the incident and third-party claims. - From authorities (such as police): your name, address, vehicle registration number, information regarding the accident, police reports and witness statements. *With whom do we share your personal information?* We may share certain information with dealers/garages, body repair shops, car fitters, car insurance companies (which may be both affiliated and third-party car insurance companies) and professional experts employed on our behalf or on behalf of third parties (such as lawyers, medical experts, investigators, etc.) for the purpose of damage or claim resolution. See also section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’. **4.4.3.d EV Charging Card** *What does this purpose entail?* In case you have an Electric Vehicle, you may be provided with a charging card for charging your vehicle at charge points. This processing is required for the performance of the agreement. In addition, we may provide services in relation to placing a charging point. *Which personal information do we process for this purpose?* For this purpose, we collect the following information: your name, email address, e-Mobility card number, vehicle registration number, mileage and related costs. In case of re-imbursements, we may also need to collect bank account information. *With whom do we share your personal information?* LeasePlan needs to share the information with the E-Charging solution company/payment company. See also section '[Sharing data with third parties](targetSelf:#Paragraph14)'. **4.4.3.e Traffic and parking fines management** *What does this purpose entail?* The following may depend on the country where you may have committed traffic and/or parking violations: As the registered owner of the vehicles, traffic and/or parking fines incurred by drivers of the vehicles may be addressed to LeasePlan by the authority that issued a specific traffic or parking fine (such as police or local municipality). We process your personal information for the purpose of processing and managing the payment of the fine. This processing is required for the performance of the lease agreement. We may also be required to process special category data. These may include data relating to traffic or driving offences and our lawful reason for processing these would be that it is in the substantial public interest and that it is necessary for establishing or defence to legal claims if necessary. *Which personal information do we process for this purpose?* We process information that we receive from the competent authorities (such as police or local municipalities): your name, address and vehicle registration number, the nature, place and time of the offense/incident committed by you and the imposed fines. *With whom do we share your personal information?* See also section '[Sharing data with third parties](targetSelf:#Paragraph14)'. 4.4.4. MOBILITY SERVICES **4.4.4 a Roadside assistance** *What does this purpose entail?* When you experience a car malfunction, for example, a flat tyre or mechanical difficulties while on the road, LeasePlan is able to arrange roadside assistance, for which we work closely with contracted third parties. This processing is required for the performance of the lease agreement. *Which personal information do we process for this purpose?* For this purpose, we collect the following information: your name, email, mobile phone number, vehicle registration number and location of where assistance was needed and provided. *With whom do we share your personal information?* We share your information with third parties providing on the road repair services, towing services or a replacement car. See also section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’.4.4.5 LEASEPLAN BUSINESS PURPOSES **4.4.5.a Management reporting** *What does this purpose entail?* We process personal information for various LeasePlan business-related purposes for which we have a legitimate interest to process these data, such as data analysis, audits, developing new products, enhancing, improving or modifying our websites and Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities. To facilitate your use of our online services or applications, we may analyse data that we collect when using our digital media and combine it with information collected via cookies. For example, to better understand which digital channel (Google search, e-mail, social media) or device (desktop, tablet or mobile) you prefer, we can optimize or limit our communication and marketing activities by channel and by device. *Which personal information do we process for this purpose?* For this purpose, we may process your name, your email address, your IP address, gender, date of birth, place of residence, digits of your zip code and any other information mentioned in this Privacy Statement or otherwise provided to us by you, if such is required for one of the purposes mentioned in the previous paragraph. *With whom do we share your personal information?* See section '[Sharing data with third parties](targetSelf:#Paragraph14)'. **4.4.5.b Compliance with laws and legal obligations and protection of LeasePlan assets and interests** *What does this purpose entail?* To comply with a legal obligation or where we have a legitimate interest, we process your personal information as appropriate or necessary: (a) under applicable law, including laws outside your country of residence and including sectorial recommendations (e.g., counterparty due diligence, money laundering, financing of terrorism and other crimes); (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions and other applicable policies; (e) to protect our operations; (f) to protect our rights, privacy, safety or property, and/or that of yours or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain. *Which personal information do we process for this purpose?* For this purpose, we process your name, contact information, the date, place and country of birth, in case of a company of the ultimate beneficial owner of the company; we may also process the name, address and the date, place and country of birth of the person(s) who represent the company towards LeasePlan; your correspondence with LeasePlan, your use of Services and any other information mentioned in this Privacy Statement, if such is required for one of the purposes mentioned in the previous paragraph. *With whom do we share your personal information?* Only if we are required to do so by law or sectorial recommendation to which LeasePlan is subject, your personal information will be provided to supervisory agencies, fiscal authorities and investigative agencies. See also section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’.

4.5 Data pertaining to private buyers of used vehicles

4.5.1 PURCHASE **4.5.1.a Purchase of a LeasePlan Vehicle** *What does this purpose entail?* We process your information in relation to your (potential) purchase of a LeasePlan vehicle, if applicable, the trade in of your vehicle and other related Services. This includes the execution of the purchase agreement, the delivery of Services and the settlement of the payment transaction. This processing is required for the conclusion and performance of the agreement, including assessment, acceptance of you as a client and preliminary credit checks. *Which personal information do we process for this purpose?* For this purpose, we collect your name, gender, title, (business) contact details (including your email address, telephone number, name of your company), information related to your trade in vehicle and details needed to complete the transaction, including bank account details. *With whom do we share your personal information?* We may share this information with trade in parties or financial services partners. See also section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’.4.5.2 BUYER CONTACT **4.5.2.a To communicate with you** *What does this purpose entail?* We collect your information when you contact us via one of our online contact forms (or provide information in one of our vehicle centers), for example, when you send us questions, suggestions, compliments or complaints, or when you request a quote for our Services. We can contact you relating to a (potential) purchase of a vehicle. This processing is required for the performance of the agreement that you have with us or with your consent. *Which personal information do we process for this purpose?* For this purpose, we collect your name, gender, title, (business) contact details (including your email address, telephone number, name of your company) and any other information that you provide to us in the open field entry of the contact form, where you can, for example, pose your question, describe your suggestion, make a compliment or share a complaint. *With whom do we share your personal information?* See section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’. **4.5.2.b For surveys or other (marketing) communication** *What does this purpose entail?* We process your personal information when we send you a survey to request your feedback on our Services, for which we have a legitimate interest to process these data. With your consent or where we have a legitimate interest, we may send you marketing communication, to keep you updated on events, special offers, possibilities and current and future products and services of LeasePlan. When we contact you in regard of surveys or marketing communication, we will do so either by email or by postal newsletters/brochures/magazines (postal mailings). To understand what is relevant to you, we can use manual and automatic tools to analyse your personal information. If you would no longer like to receive surveys or marketing communication from us, please use the opt out options in the communication, contact the local LeasePlan entity via its [webform](targetBlank:https://privacyportal-eu.onetrust.com/webform/396c853c-7bbe-43bb-9c80-0001fd327955/a92e1963-3828-444d-be01-0f0e551a86da) for individuals’ rights or use the contact details below. *Which personal information do we process for this purpose?* For this purpose, we process your name, your address, your email address, and your interests (as indicated by you). *With whom do we share your personal information?* See section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’.4.5.3 LEASEPLAN BUSINESS PURPOSES **4.5.3.a Management reporting** *What does this purpose entail?* We process personal information for various LeasePlan business-related purposes for which we have a legitimate interest to process these data, such as data analysis, audits, developing new products, enhancing, improving or modifying our websites and Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities. To facilitate your use of our online services or applications, we may analyse data that we collect when using our digital media and combine it with information collected via cookies. For example, to better understand which digital channel (Google search, e-mail, social media) or device (desktop, tablet or mobile) you prefer, we can optimize or limit our communication and marketing activities by channel and by device. *Which personal information do we process for this purpose?* For this purpose, we may process your name, your email address, your IP address, gender, date of birth, place of residence, digits of your zip code and any other information mentioned in this Privacy Statement or otherwise provided to us by you, if such is required for one of the purposes mentioned in the previous paragraph. *With whom do we share your personal information?* See section ‘Sharing data with third parties’. **4.5.3.b Compliance with laws and legal obligations and protection of LeasePlan assets and interests** *What does this purpose entail?* To comply with a legal obligation or where we have a legitimate interest we process your personal information as appropriate or necessary: (a) under applicable law, including laws outside your country of residence and including sectorial recommendations (e.g., counterparty due diligence, money laundering, financing of terrorism and other crimes); (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions and other applicable policies; (e) to protect our operations; (f) to protect our rights, privacy, safety or property, and/or that of yours or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain. *Which personal information do we process for this purpose?* For this purpose, we process your name, contact information, the date, place and country of birth, in case of a company of the ultimate beneficial owner of the company; we may also process the name, address and the date, place and country of birth of the person(s) who represent the company towards LeasePlan; your correspondence with LeasePlan, your use of Services and any other information mentioned in this Privacy Statement, if such is required for one of the purposes mentioned in the previous paragraph. *With whom do we share your personal information?* Only if we are required to do so by law or sectorial recommendation to which LeasePlan is subject, your personal information will be provided to supervisory agencies, fiscal authorities and investigative agencies. See also section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’.

4.6 Data pertaining to professional buyers of used vehicles (Traders)

4.6.1 REGISTRATION AND PURCHASE **4.6.1.a Registration as a professional trader.** *What does this purpose entail?* To be able to purchase LeasePlan Vehicle on an auction or purchase a vehicle via our one of our car remarketing websites, traders need to be registered with LeasePlan as a professional trader. This processing is based on our legitimate interest (and also relates to the providing of Services under the performance of an agreement, including assessment, acceptance or credit checks) or based on a legal obligation.   *Which personal information do we process for this purpose?* For this purpose, we collect your name, contact details (including your email address, telephone number), your ID and information related to your company including Chamber of Commerce document and VAT certificate, *With whom do we share your personal information?* See section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’. **4.6.1.b Purchase of LeasePlan Vehicles** *What does this purpose entail?* We process your information in relation to your(potential) purchase of LeasePlan vehicle(s) and other related Services via an auction or via our car remarketing website, this includes the execution of the purchase agreement, the delivery and the settlement of the payment transaction. This processing is based on legitimate interest (and also relates to the providing of Services under the conclusion and performance of the purchase agreement). *Which personal information do we process for this purpose?* For this purpose, we collect your name, contact details(including your email address, telephone number), your ID and information related to your company including Chamber of Commerce document and VAT certificate, details needed to complete the transaction, including bank account details.   *With whom do we share your personal information?* See section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’.   4.6.2 TRADER CONTACT **4.6.2.a To communicate with you** *What does this purpose entail?* We collect your information when you contact us via one of our online contact forms (or provide information in one of our vehicle centers), for example, when you send us questions, suggestions, compliments or complaints, or when you request a quote for our Services. We can contact you relating to a (potential) purchase of a vehicle. This processing is based on our legitimate interest (and also relates to the providing of Services under the performance of the agreement that we have with the Trader) or with your consent. *Which personal information do we process for this purpose?* For this purpose, we may process your name, your business contact details, your correspondence with LeasePlan pertaining to your question/request and all other personal information you provide to us and/or which is necessary to appropriately respond to you.   *With whom do we share your personal information?* See section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’.   **4.6.2.b For surveys or other (marketing) communication.** *What does this purpose entail?* We process your personal information when we send you a survey to request your feedback on our Services for which we have a legitimate interest to process these data. With your consent or where we have a legitimate interest, we may send you marketing communication, to keep you updated on events, special offers, possibilities and current and future products and services of LeasePlan. When we contact you in regard of surveys or marketing communication, we will do so either by email or by postal newsletters/ brochures/magazines (postal mailings). If you would no longer like to receive surveys or marketing communication from us, please use the opt out options in the communication, contact the local LeasePlan entity via its webform for individuals’ rights or use the contact details below.   *Which personal information do we process for this purpose?* For this purpose, we process your name, your address, your email address, and your interests (as indicated by you).   *With whom do we share your personal information?* See section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’. 4.6.3 LEASEPLAN BUSINESS PURPOSES **4.6.3.a Management reporting** *What does this purpose entail?* We   process   personal   information for various LeasePlan business-related purposes for which we have a legitimate interest to process these data, such as data analysis, audits, developing new products, enhancing, improving or modifying our websites and Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities. To facilitate your use of our online services or applications, we may analyse data that we collect when using our digital media and combine it with information collected via cookies. For example, to better understand which digital channel (Google search, e-mail, social media) or device (desktop, tablet or mobile) you prefer, we can optimize or limit our communication and marketing activities by channel and by device. *Which personal information do we process for this purpose?* For this purpose, we may process your name, your email address, your IP address, gender, date of birth, place of residence, digits of your zip code and any other information mentioned in this Privacy Statement or otherwise provided to us by you, if such is required for one of the purposes mentioned in the previous paragraph. *With whom do we share your personal information?* See section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’. **4.6.3.b Compliance with laws and legal obligations and protection of LeasePlan assets and interests** *What does this purpose entail?* To comply with a legal obligation or where we have a legitimate interest, we process your personal information as appropriate or necessary  (a)under applicable law, including laws outside your country of residence and including sectorial recommendations (e.g., counterparty due diligence, money laundering, financing of terrorism and other crimes);  (b)to comply with legal process; (c)to respond to requests from public and government authorities including public and government authorities outside your country of residence;  (d)to enforce our terms and conditions and other applicable policies;  (e)to protect our operations;  (f)to protect our rights, privacy, safety or property, and/or that of yours or others; and  (g)to allow us to pursue available remedies or limit the damages that we may sustain. *Which personal information do we process for this purpose?* For this purpose, we process your name, contact information, the date, place and country of birth, in case of a company of the ultimate beneficial owner of the company; we may also process the name, address and the date, place and country of birth of the person(s) who represent the company towards LeasePlan; your correspondence with LeasePlan, your use of Services and any other information mentioned in this Privacy Statement, if such is required for one of the purposes mentioned in the previous paragraph. *With whom do we share your personal information?* Only if we are required to do so by law or sectorial recommendation to which LeasePlan is subject, your personal information will be provided to supervisory agencies, fiscal authorities and investigative agencies. See section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’ .

4.7 Data pertaining to suppliers

4.7.1 SUPPLIER ACCOUNT MANAGEMENT **4.7.1.a To provide, manage and administer the Supplier account** *What does this purpose entail?* We collect your information to handle day-to-day management and administration of the Supplier accounts, such as maintaining contracts, and keep you informed of all important developments concerning the services you render and other information which is relevant for the Supplier contract and account. This processing is based on the agreement that we have with you or based on a legal obligation. *Which personal information do we process for this purpose?* For this purpose, we may process business contact details and log-in details to our Supplier online accounts. *With whom do we share your personal information?* See section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’. **4.7.1.b To communicate with you** *What does this purpose entail?* You can contact us by various means (such as email or telephone, or via our website). In this case we use your personal information to answer your question/request. We can also contact you, for example, regarding day-to-day management and administration of your Supplier account. This processing is based on the agreement that we have with you or with your consent. *Which personal information do we process for this purpose?* For this purpose, we may process your name, your business contact details, your correspondence with LeasePlan pertaining to your question/request and all other personal information you provide to us and/or which is necessary to appropriately respond to you. *With whom do we share your personal information?* See section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’. **4.7.1.c For surveys or other (marketing) communication** *What does this purpose entail?* We process your personal information to send you surveys, for which we have a legitimate interest to process these data. With your consent or where we have a legitimate interest, we may send you marketing communication, for example, to keep you updated on events, special offers, possibilities and current and future products and services of LeasePlan. We send you such surveys in the form of either a periodic email or an email to request your feedback on our communication and relationship. We may also send you postal mailings (newsletters/brochures/magazines). If you would no longer like to receive surveys or marketing communication from us, please use the opt out options in the communication, contact the local LeasePlan entity via its [webform](targetBlank:https://app-eu.onetrust.com/app/#/webform/a92e1963-3828-444d-be01-0f0e551a86da) for individuals’ rights or use the contact details below. *Which personal information do we process for this purpose?* For this purpose, we may process your name and your business contact details. *With whom do we share your personal information?* See section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’. 4.7.2 LEASEPLAN PREMISES **4.7.2.a Access to and security control of LeasePlan premises** *What does this purpose entail?* We may process your personal information when you visit us on our premises for the purpose of ensuring appropriate access controls and security, for which we have a legitimate interest (safety and security of our assets). *Which personal information do we process for this purpose?* For this purpose, we may process your name, your contact information and the person you are visiting. We may also process video and/or audio information about you through video/audio recording equipment, such as for instance CCTV. *With whom do we share your personal information?* See section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’. 4.7.3 SUPPLIER REPORTING **4.7.3.a MyFleet** *What does this purpose entail?* We provide the online reporting tool ‘MyFleet’. Clients’ contact persons can log onto these tools to review the status of their fleet, and to use other fleet reporting functionalities, such as dashboard reporting, trend analysis reporting, vehicle mileage and end of lease term. This processing is based on our legitimate interest (and also relates to the providing of Services under the performance of the lease agreement that we have with the Client). *Which personal information do we process for this purpose?* For this purpose, we collect contact details and job function (e.g., (International) Fleet Manager) of Client’s contact person, and login details (e.g., username and password). *With whom do we share your personal information?* See section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’. 4.7.4 LEASEPLAN BUSINESS PURPOSES **4.7.4.a  Management reporting** *What does this purpose entail?* We   process   personal   information for various LeasePlan business-related purposes for which we have a legitimate interest to process these data, such as data analysis, audits, developing new products, enhancing, improving or modifying our websites and Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities. To facilitate your use of our online services or applications, we may analyse data that we collect when using our digital media and combine it with information collected via cookies. For example, to better understand which digital channel (Google search, e-mail, social media) or device (desktop, tablet or mobile) you prefer, we can optimize or limit our communication and marketing activities by channel and by device. *Which personal information do we process for this purpose?* For this purpose, we may process your name, your email address, your IP address, gender, date of birth, place of residence, digits of your zip code and any other information mentioned in this Privacy Statement or otherwise provided to us by you, if such is required for one of the purposes mentioned in the previous paragraph. *With whom do we share your personal information?* See section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’. **4.7.4.b Compliance with laws and legal obligations and protection of LeasePlan assets and interests.** *What does this purpose entail?* To comply with a legal obligation or where we have a legitimate interest, we process your personal information as appropriate or necessary: (a) under applicable law, including laws outside your country of residence and including sectorial recommendations (e.g., counterparty due diligence, money laundering, financing of terrorism and other crimes);  (b) to comply with legal process;  (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence;  (d) to enforce our terms and conditions and other applicable policies;  (e) to protect our operations;  (f) to protect our rights, privacy, safety or property, and/or that of yours or others; and  (g) to allow us to pursue available remedies or limit the damages that we may sustain. *Which personal information do we process for this purpose?* For this purpose, we process the name, contact information, the date, place and country of birth of the ultimate beneficial owner of the counterparty that LeasePlan want to do business with; we may also process the name, address and the date, place and country of birth of the person(s) who represent the counterparty towards LeasePlan; your correspondence with LeasePlan, the services you render and any other information mentioned in this Privacy Statement, if such is required for one of the purposes mentioned in the previous paragraph. *With whom do we share your personal information?* Only if we are required to do so by law or sectorial recommendation to which LeasePlan is subject, your personal information will be provided to supervisory agencies, fiscal authorities and investigative agencies. See also section ‘[Sharing data with third parties](targetSelf:#Paragraph14)’.