ENGINE LEASE FINANCE CORPORATION
Your use of the Website
With regard to each of your visits to the elfc.com website, we may automatically collect the following information:
- Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
- Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through or from our Site (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs), and methods used to browse away from the page.
To the extent that this information includes Personal Data, it will be treated in the same manner as outlined in this Privacy Statement.
Who we are
Engine Lease Finance Corporation and the MUL group of companies (“Engine Lease Finance”) will collect and process the Personal Data of natural persons who are directors, officers, employees, agents and / or authorised signatories of Engine Lease Finance’s customers, suppliers, service providers, vendors and other commercial partners (“Individuals”) for the purposes of and in connection with Engine Lease Finance’s dealings with those commercial entities.
This Privacy Statement explains how Engine Lease Finance will manage the Personal Data of Individuals, why Engine Lease Finance uses it, and how Individuals may contact Engine Lease Finance in relation to the use of Personal Data. Personal Data means any information which Engine Lease Finance has or obtains, or which an Individual provides to Engine Lease Finance, and specifically his / her name, address, email address, phone number(s), title or position, from which that Individual can be directly or indirectly personally identified.
Use of Personal Data and Basis of Processing
Engine Lease Finance will use the Personal Data where necessary:
- where use is for a legitimate purpose of Engine Lease Finance, including:
- for the purposes of managing its contracts and relationships with its customers, suppliers, service providers, vendors and other commercial partners;
- for day to day operational and business purposes;
- board reporting and management purposes, including quality assurance;
- in the event of a merger, reorganisation or disposal of, or a proposed merger, reorganisation or disposal of Engine Lease Finance;
- to take advice from Engine Lease Finance’s external legal and other advisors;
- for compliance with Engine Lease Finance’s legal obligations, including:
- compliance with applicable tax and regulatory reporting obligations;
- where Engine Lease Finance is ordered to disclose information by a court with appropriate jurisdiction;
- where necessary to establish, exercise or defend its legal rights or for the purpose of legal proceedings;
- where an Individual has consented to use for a particular purpose. If an Individual gives consent for Engine Lease Finance to use his / her Personal Data for a particular purpose, that Individual has the right at any time to withdraw consent to the future use of his / her Personal Data for some or all of those purposes by writing to the address specified below.
Know Your Customer
We may collect certain documentation (which contains Personal Data) from you for KYC purposes. This documentation includes proof of identity (e.g. copy passport / driving licence) and proof of address (e.g. copy utility bill). We are not under a legal obligation to collect this documentation. However, we consider it a legitimate business interest of Engine Lease Finance to verify the identity of our customers for anti-money laundering and counter-terrorist financing and for sanctions screening purposes.
Applicants for jobs
Where you, or a third party recruitment agent acting for you, provide us with your CV and other Personal Data, we will use that information solely for the purposes of considering your application for a position with Engine Lease Finance, including checking your references. However, we will only hold Personal Data of applicants for positions for a period of 12 months from our final interaction with a candidate during the recruitment process. If you are a successful candidate, some of the Personal Data we obtain during the recruitment process will be held on your personnel file, which will be subject to our separate Employee privacy statement.
Sharing Personal Data
Engine Lease Finance will not disclose any Personal Data to any third party, except as outlined above and / or as follows:
- to enable Engine Lease Finance to carry out the obligations under and enforce its contracts with its customers, suppliers, service providers, vendors and other commercial partners;
- to anyone providing a service to Engine Lease Finance or acting as Engine Lease Finance’s agent, as data processors, for the purposes of providing services to Engine Lease Finance and on the understanding that they will keep the Personal Data confidential;
- where Engine Lease Finance needs to share Personal Data with its auditors, and legal and other advisors;
- in the event of a merger or proposed merger, any (or any proposed) transferee of, or successor in title to, the whole or any part of Engine Lease Finance’s business, and their respective officers, employees, agents and advisers, to the extent necessary to give effect to such merger;
- the disclosure is required by law or regulation, or court or administrative order having force of law, or is required to be made to any of Engine Lease Finance’s regulators.
Personal Data may be transferred outside the European Economic Area (the “EEA”) in connection with the uses described above, where an Individual has explicitly consented, and / or as otherwise required or permitted by law.
Many of the countries will be within the EEA, or will be ones which the European Commission has approved, and will have data protection laws which are the same as or broadly equivalent to those in the European Union. However, some transfers may be to countries which do not have equivalent protections, and in that case Engine Lease Finance shall use reasonable efforts to implement contractual protections for the Personal Data. While this may not always be possible, any transfers will be done in accordance with applicable data protection laws, including through the implementation of appropriate or suitable safeguards in accordance with such applicable data protection laws. In particular, Engine Lease Finance is a party to an Intra-Group Data Transfer Agreement which governs the transfer of Personal Data across all members of the MUL group of companies in a manner consistent with the requirements of applicable data protection laws.
Third Party Providers of Information
Engine Lease Finance may obtain Personal Data relating to Individuals from someone other than that Individual, such as his / her employer. The person providing the information will be asked to warrant that it will only do so in accordance with applicable data protection laws, and that it will ensure that before doing so, the Individuals in question are made aware of the fact that Engine Lease Finance will hold information relating to them and that it may use it for any of the purposes set out in this privacy statement, and where necessary that it will obtain consent to Engine Lease Finance’s use of the information.
Recipients of the Personal Data
In any case where Engine Lease Finance shares Personal Data with a third party data controller, the use by that third party of the Personal Data will be subject to the third party’s own privacy policies.
Updates to Personal Data
Engine Lease Finance will use reasonable efforts to keep Personal Data up to date. However, each Individual will need to notify Engine Lease Finance without delay in the event of any change in his / her personal circumstances, or those of the others mentioned above, so that Engine Lease Finance can keep the Personal Data up to date.
Retention of Personal Data
Engine Lease Finance is obliged to retain certain information to ensure accuracy, to help maintain quality of service and for legal and regulatory purposes, and for legitimate business purposes.
Information will be retained for no longer than is necessary for the purpose for which it was obtained by Engine Lease Finance or as required or permitted for legal and regulatory purposes, and for legitimate business purposes. In general, Engine Lease Finance (or its service providers on its behalf) will hold this information for a period of seven years after an Individual ceases to interact with Engine Lease Finance, unless it is obliged to hold it for a longer period under law or applicable regulations.
An Individual’s Rights in relation to Personal Data
An Individual may at any time request a copy of his / her Personal Data from Engine Lease Finance. This right can be exercised by writing to Engine Lease Finance at the address specified below.
An Individual also has the right to correct any inaccuracies in, and in certain circumstances, to request erasure, or restriction on the use, of his / her Personal Data, and to object to certain uses of his / her Personal Data, in each case subject to the restrictions set out in applicable data protection laws. Further information on these rights, and the circumstances in which they may arise in connection with Engine Lease Finance’s processing of Personal Data can be obtained by writing to Engine Lease Finance at the address specified below.
In any case where Engine Lease Finance is relying on an Individual’s consent to process his / her Personal Data, that Individual has the right to change his / her mind and withdraw consent by writing to the address specified below.
Where Engine Lease Finance is relying on a legitimate purpose of Engine Lease Finance or a third party recipient of the Personal Data, in order to use and disclose Personal Data, an Individual is entitled to object to such use or disclosure of his / her Personal Data, and if he /she does so, Engine Lease Finance will cease to use and process the Personal Data for that purpose unless Engine Lease Finance can show there are compelling legitimate reasons for it to continue or it needs to use the Personal Data for the purposes of legal claims.
An Individual also has the right to lodge a complaint about the processing of his / her Personal Data by Engine Lease Finance with the Data Protection Commission at firstname.lastname@example.org.
Contacting Engine Lease Finance
Any queries or complaints regarding the use of the Personal Data by Engine Lease Finance and / or the exercise of individual rights should be addressed to Engine Lease Finance at email@example.com (attention Human Resources).
Last updated 25 May 2018