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COOKIE AND PRIVACY POLICY 

1 IMPORTANT NOTICE 

1.1 This Cookie and Privacy Policy (the “Policy”) applies to your use of all Microlease Ltd, and its subsidiaries, (“Microlease”) websites: including http://www.microlease.com and http://www.livingston.com (the “Website(s)”). “We,” “us,” and “our” refer to the Microlease entity which runs the applicable Website. 

1.2 Microlease complies with the European Union General Data Protection Regulation. For the purposes of the GDPR, to the extent applicable and relevant, Microlease is the “data controller”. 

1.3 Please read the following Policy to understand how we may collect, use, store, and transfer the personal data you provide or which we collect about you. By using the Website, you consent to this Policy and our stated collection, use, storage, and any applicable transfers of your personal data. 

1.4 This Policy may vary from time to time so please check it regularly. 


2 THE PERSONAL DATA WE COLLECT 

2.1 We may collect the following personal data (“personal data”) about you: 

2.1.1 personal data you provide if you contact us using the “Information Request” form or by filing in other forms on our Website (not we do not scrap unsubmitted forms); 

2.1.2 personal data you provide if you contact us (including by telephone) to register, subscribe, or request information on or to have us provide services or products; 

2.1.3 personal and payment data you provide when making a purchase or rental; 

2.1.4 personal data you provide when you apply for a job advertised or submit a speculative job application and/or your CV or résumé; 

2.1.5 personal data gathered using cookies; 

2.1.6 personal data you provide if you enter into a competition or promotion; 

2.1.7 details of your visits to our Website, including, but not limited to, traffic data, location data, weblogs, and other similar data; 

2.1.8 information about your computer including, where available, your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is aggregated, statistical data about our users’ browsing actions and patterns, and does not identify any individual. 

2.1.9 The following are some examples of personal data we may collect based upon the above types of data:

·   Name

·   Mailing address

·   E-mail address

·   Phone (or mobile) number

·   Date of birth or age

·   GDPR Special category data (for job seekers)

·   Driver’s license number

·   Credit/debit card number

·   Purchase/return/exchange information

·   Registry or list information

·   Your mobile device information (e.g., device model, operating system version, device date and time, unique device identifiers, mobile network information)

·   How you use our sites and mobile applications, search terms, pages you visit on our mobile applications and application performance, as discussed further below

·   Geo-location and in-store location

·   Social media information (e.g., ID, profile picture, gender, age range, friends’ IDs)

2.1.10 If you choose not to provide information, we may not be able to provide you with requested products, services, or information.


3 HOW WE USE PERSONAL DATA COLLECTED 

3.1 We may use and process the personal data you provide for the purposes outlined below as well as for any purposes specified at the time of collection: 

3.1.1 to send you information you have requested; 

3.1.2 to fulfil orders which you have placed for products and services; 

3.1.3 to deal with your enquiries; 

3.1.4 to contact you by telephone, SMS, post and/or email about other offers, products, promotions, developments or services which we think may be of interest to you, to the extent permitted by applicable law and regulation. Please make it clear when you provide personal data to us, should you not wish to receive such information; 

3.1.5 to develop, deliver, and improve our products or services or marketing; 

3.1.6 to help us develop this Website to be more useful to you; 

3.1.7 for Website user our processing research or analysis including to collect statistics, responses to any surveys and questionnaires, traffic patterns, and related site information. (We aggregate this data and it does not identify any Website users); 

3.1.8 for internal purposes for research, analysis, testing, monitoring, customer communication, risk management, and administrative purposes; and/or 

3.1.9 to send you important notices; 

3.1.10 to send you product information, newsletters, and other relevant and targeted promotional communications; 

3.1.11 to provide or manage benefits associated with your order (such as warranty or promotional credits);

3.1.12 deliver coupons, newsletters, emails, or social media messages;

3.1.13 prevent fraudulent transactions, monitor against theft or misuse of service or products, and otherwise protect our interests and our customers;

3.1.14 for consideration of your request to apply for a job at our company;

3.1.15 for legal compliance such as assist law enforcement or regulatory inquires;

3.1.16 for any other legitimate interest allowable under the GDPR which applies to our business.


4 DISCLOSURE OF YOUR PERSONAL DATA 

4.1 We may disclose your personal data to our selected third party business partners (including but not limited to Original Equipment Manufacturers, Google Analytics, Amazon Web Services, Oracle Cloud, Salesforce,  Pardot, and any regulatory agency we are subject to) to fulfil an order for products or services, respond to an enquiry, perform market analysis, market to you current or future products and services, or to help us improve your experience on this Website. 

4.2 We may also disclose your personal data to affiliates and third party data processers who may process data on our behalf to enable us to carry out our business practices. 

4.3 We may also disclose your personal data to third parties in the following circumstances: 

4.3.1 to undertake the activities listed above; 

4.3.2 to conform to legal requirements or comply with legal process; 

4.3.3 to assist in the investigation of suspected illegal or wrongful activity. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction; 

4.3.4 to protect and defend our rights or property; 

4.3.5 to deal with any misuse of the Website; 

4.3.6 to sell, make ready for sale or dispose of our business in whole or in part including to any potential buyer or their advisers; or 

4.3.7 in order to enforce or apply our Terms of Use, terms and conditions and agreements with third parties. 

4.4 We do not sell, trade, or rent any of your personal information. 


5 COOKIES & OTHER TRACKING TECHNIQUES

5.1 What are cookies? 

5.1.1 Like many other websites, this Website uses cookies. Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies are useful because they allow a website to recognise a user’s device. You can find more information about cookies at: www.allaboutcookies.org and www.youronlinechoices.eu for a video about cookies visit www.google.com/policies/technologies/cookies/

5.1.2 Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improve the user experience. They can also help to ensure that adverts you see online are more relevant to you and your interests. 

5.2 Which cookies are used on this Website? 

5.2.1 The cookies used on this Website have been categorised based on the categories found in the ICC UK Cookie guide. 

5.2.2 A list of all the cookie types used on this Website by category is set out below. 

Strictly necessary cookies 

These cookies are essential in order to enable you to move around the Website and use its features, such as accessing secure areas of the Website. Without these cookies, services you have asked for cannot be provided. 

Performance cookies 

These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works. 

Functional cookies 

These cookies allow the Website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites. 

Google Analytics 

These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. For further details visit: http://www.google.com/analytics/learn/privacy.html 

5.3 How can the cookies be removed? 

5.3.1 You may refuse to accept cookies by activating the setting on your internet browser which allows you to refuse the setting of cookies. For more information about cookies including how to set your internet browser to reject cookies please go to www.allaboutcookies.org 

5.3.2 To opt out of Google Analytics visit http://tools.google.com/dlpage/gaoptout 

5.3.3 Please be aware however that blocking cookies may hamper the Website’s functionality or restrict how much of the Website you can access. 

5.3.4 Do we use Automated Information Collection?

5.3.4.1 Yes.  We may connect information collected automatically with information we already have about you in order to identify you as a Website guest. If we are able to identify you as a Website guest we may, for example, link your activity on our website to your activity on one of our mobile applications. This allows us to provide you with a personalized experience regardless of how you interact with us – online, mobile, etc.

5.3.4.2 In order to provide the best guest experience possible, we also use automated information collection technologies for reporting and analysis purposes. We examine metrics such as how you are shopping on our website, in our stores, and on our mobile applications, the performance of our marketing efforts, and your response to those marketing efforts.

5.3.5 Do we use Targeted Automated Collection?

5.3.5.1 Yes.  We and our service providers use cookies, web beacons, and other technologies to receive and store certain types of information whenever you interact with us or third-parties that use our services. This information helps us recognize you, customize your website experience, store items in your cart between visits and make our marketing messages more relevant. Examples of this information include but are not limited to: pages you visit, ads you click on, type of browser/device/hardware, purchase information, IP based geographic location and search terms. These technologies also enable us to prevent fraud (using Flash Cookies) or other harmful activities.

5.3.5.2 We also allow third-party companies (e.g., Nielsen) to place tags on our digital properties. The tags may collect information from cookies placed by other third-party companies. Our Privacy Policy does not cover these third-party companies. Please contact these third party companies (e.g., Nielsen) directly for more information about their privacy policy and your choices regarding the tags and the information collected by the tags.

5.3.6 Do we use Cross-Context targeting?

5.3.6.1 Yes. We merge data collected from our own websites and mobile apps. Examples of the data collected include: cookie IDs, device Advertising IDs (such as Apple and Google’s Advertising Identifiers); transactions and browsing history; your interaction with our online and mobile advertisements, including advertisements we serve within our emails and advertisements that we serve on behalf of third parties; information about ads we serve, such as which ad was served, your interactions with the ads, and the URLs where the ads are served from marketing partners such as Google DoubleClick for Publishers and Google DoubleClick Campaign Manager; the email address we have on file for you; any Registry information you have provided us; demographic and other information regarding your likely commercial interests from third parties; and in-store transaction data. This combination of data enables us to see users’ and Guests’ web activity on our websites, app activity on our apps, and interactions with our online and mobile advertisements and advertisements that we serve on behalf of third parties, to create a single set of information from all of the various contexts with which we or our partners interact with you, and to understand how well our advertisements and advertisements that we serves for third parties perform in terms of translating to transactions online, in app, and in our stores and the stores of our third-party advertisers. It also helps us improve our users’ and Guests’ experience by delivering more personalized advertising, including email advertising, social media advertising, and paid search advertising, and helps us create more personalized online and in-app experiences. We share information on the performance of advertisements we serves for third parties with our advertising partners in aggregate form.

5.3.7 Do we use Cross-Device targeting?

5.3.8.1 Yes.  We may also link your various devices so that content you see on one device can result in relevant advertising on another device. This allows us to deliver more relevant and consistent advertising to you (for example, if you purchase a product on our website using your desktop, we’re able to avoid showing you an advertisement on the same product on your tablet. Instead, we may show you an ad on your tablet for complimentary products to the one you just purchased on our website). We also measure the performance of such ads and deliver information on advertising performance to our advertising partners in aggregate form.

5.3.9 Your Choices

5.3.9.1 To opt-out of the vendors we use for cross-device linking, go to the Digital Advertising Alliance’s Choices page at www.aboutads.info/choices and perform a global opt-out on each browser and device that you would like to be opted out on. Opting out in this manner means that the browser on the device from which you opt-out will no longer receive information collected on devices linked to it, that devices linked to it will not receive information collected from the opted-out device, and that the vendor will not transfer information collected from the opted-out device to a third party. Please note that this will not opt you out of cross-device linking or advertising across linked devices based solely on your visits to our websites or apps, or your interaction with advertisements for us. The opt-out tool described above is Cookie-based. Therefore, the opt-out will only function if your browser is set to accept third-party cookies, and it may not function where cookies are automatically disabled or removed. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt-out again.

5.3.10 Third-Party Automated Collection and Interest-Based Advertising

5.3.10.1 We may participate in interest-based advertising (IBA), also known as Online Behavioral Advertising. We use third-party advertising companies to display ads tailored to your individual interests based on how you browse and shop online, as well as to provide advertising-related services such as ad delivery, reporting, attribution, analytics, and market research. We will adhere to the Digital Advertising Alliance (DAA) self-regulatory principles for IBA.

5.3.10.2  We allow third-party companies to collect certain information when you visit our websites or use our mobile applications. This information is used to serve ads for our products or services or for the products or services of other companies when you visit this website or other websites. These companies use non-personally-identifiable information (e.g., click stream information, browser type, time and date, subject of advertisements clicked or scrolled over, hardware/software information, cookie and session ID) and personally identifiable information (e.g., static IP address) during your visits to this and other websites in order to provide advertisements about goods and services likely to be of greater interest to you or advertising-related services, such as ad delivery, reporting, attribution, analytics, and market research. These parties typically use a cookie, web beacon or other similar tracking technologies to collect this information.

5.3.11 Our Do Not Track Policy

5.3.11.1 Some browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked. At this time, we do not respond to browser “do not track” signals, but we do provide you the option to opt out of interest-based advertising. To learn more about IBA or to opt-out of this type of advertising, visit the Network Advertising Initiative website and the Digital Advertising Alliance website. Options you select are browser- and device-specific.

5.3.12 Mobile Location Information

5.3.12.1 If you use a mobile device, your device may share location information (when you enable location services) with our websites, mobile applications, services, or our service providers. We use this information to improve our services, and provide you more relevant and personalized advertisements, services, and promotions. For example, precise geo-location can be used to help you find nearby our service centers, or location through the use of your phone’s Bluetooth signal, LED light chip technologies, or other technologies will permit us to find regional real-time deals, sweepstakes, and more. To manage your share of your device’s location settings, go to your devices settings tab.

5.3.13 User Experience Information

5.3.13.1 In order to improve guest online and mobile shopping experiences, help with fraud identification, and assist our guest relations representatives in resolving issues guests may experience in completing online purchases, we use tools to monitor certain user experience information: including login information, IP address, data regarding pages visited and ads clicked, specific actions taken on pages visited (e.g., information entered during checkout process), browser, and device information.

5.3.14 Social Media

5.3.14.1 We engage with guests on multiple social media platforms (e.g., Facebook, Twitter, and Pinterest). If you contact us on one of our social media platforms, request guest service via social media, or otherwise direct us to communicate with you via social media, we may contact you via direct message or use other social media tools to interact with you. In these instances, your interactions with us are governed by this privacy policy as well as the privacy policy of the social media platform you use.

5.3.15 Social Media Widgets

5.3.15.1 Our sites and mobile applications include social media features, such as the Facebook Like button, Google Plus, Pinterest, and Twitter widgets. These features may collect information about you such as your IP address and which page you’re visiting on our site. They may set a cookie or employ other tracking technologies to accomplish this. Social media features and widgets may be hosted by a third party. Your interactions with those features are governed by the privacy policies of the companies that provide them.

5.3.16 Social Media Ads

5.3.16.1 We may display targeted ads to you through social media platforms. These ads are sent to groups of people who share traits such as likely commercial interests and demographics. For example, we may target guests who have expressed an interest in shopping for groceries, cosmetics, clothing, etc. See the policies of each social media platform for additional information about these types of ads.

5.3.17 Information from Other Sources

5.3.17.1 We collect data that is publicly available. For example, information you submit in a public forum (e.g., a blog, chat room, or social network) can be read, collected or used by us and others, and could be used to personalize your experience. You are responsible for the information you choose to submit in these instances.

5.3.17.2 We also obtain information provided by third parties. For instance, we obtain demographic and other information from companies that can enhance our existing guest information to improve the accuracy and add to the information we have about our guests (e.g., adding address information).

5.4.17.3 These collection techniques improve our ability to contact you and increases the relevance of our marketing by providing better product recommendations or special offers that may interest you.


6 YOUR RIGHTS 

6.1 When you use this Website or provide us with your personal data you are agreeing that we may use your personal data for the purposes set out in this Policy. 

6.2 You have the right to: 

6.2.1 request that we stop sending you marketing information; 

6.2.2 if you are located in the EEA, apply for a copy of the personal data we hold about you but there are some exemptions, which means you may not always receive all the information we process; and 

6.2.3 request that we correct or update any personal data which we hold about you which you believe is inaccurate or out of date; 

6.2.4 request that we delete any personal data which we hold about you in certain circumstances;

6.2.5 request that we restrict the processing of your information in certain circumstances;

6.2.6 right to object to processing unless we are able to process your information because of a legitimate interests or reason we legally hold to process your information;

6.2.7 request we transfer the information you gave us to another organisation of your choice or give it to you. The right only applies if we are processing information based on your consent or our processing of that data is automated.

6.3 You can exercise these rights by submitting a request to the Data Protection Officer at gdpr-sar@microlease.com. 

6.4 If you are a California resident and have an established business relationship with us, you can request a notice disclosing the categories of personal information we have shared with third parties, for the third parties’ direct marketing purposes, during the preceding calendar year. To request a notice, please submit your request to gdpr-sar@microlease.com or write to Microlease - Data Protection Officer, Ltd Unit 1, Waverley Industrial Park, Hailsham Drive, Harrow, Middlesex, HA1 4TR, United Kingdom or by phone at +44 (0) 20 84 200 200.


7 TRANSFERRING PERSONAL DATA 

7.1 The personal data we collect from you is currently held within the European Economic Area (“EEA”) or the United States. It is possible that in the future such personal data may be transferred, stored and/or processed outside the European Economic Area (“EEA”) or the United States. By submitting your personal data, you agree to this transfer, storing and/or processing. You should be aware that countries outside the EEA or the U.S. may not offer the same level of data protection as the United Kingdom or United States. However, we will only allow such data transfer outside the US or EEA if we have a legally allowable method.

7. 2 In connection with the sale or transfer of some or all of our business assets, we may transfer the corresponding information regarding our guests. We also may retain a copy of that guest information.


8 LINKS TO OTHER WEBSITES 

8.1 This Policy only applies to this Website. If you link to another website from here, you should remember to read and understand that website’s privacy policy as well. A link to a third party's website does not mean that we endorse it or that we are affiliated with it. We do not exercise control over third-party websites. We are not responsible for any use of your personal data that is made by other websites. 


9 SECURITY 

9.1 We maintain physical, electronic, and procedural safeguards to protect the confidentiality and security of information transmitted to us. However, no data transmission over the Internet or other network can be guaranteed to be 100% secure. As a result, while we strive to protect information transmitted on or through the Website, we cannot and do not guarantee the security of any information you transmit on or through the Website, and you do so at your own risk. 


10 CHILDREN’S PRIVACY 

10.1 The Website is intended for users who are 18 years old or older. We do not knowingly collect personal data from children under the age of 13. If we become aware that we have inadvertently received personal data from a child under the age of 13, we will delete such information from our records. 


11 CHANGES TO THIS COOKIES AND PRIVACY POLICY 

11.1 This Policy was last updated on October 2, 2018. We may update this Policy from time to time. When we change this Policy in a material way a notice will be posted on our Website along with a revised Policy. By accessing the Website after the revised Policy is posted, you consent to the revised Policy. 


12 HOW USERS CAN CONTACT US 

12.1 If you have any questions about this Policy, please contact the Data Protection Officer gdpr-sar@microlease.com or write to Microlease - Data Protection Officer, Ltd Unit 1, Waverley Industrial Park, Hailsham Drive, Harrow, Middlesex, HA1 4TR, United Kingdom or by phone at +44 (0) 20 84 200 200.


13 UPDATES

13.1  This policy may be updated from time to time as we see fit.  It is your responsibility to check which policy is in affect at the time you provide us your information or at the time you allow us to collect such information through automated means (vis you use of our website, electronic or oral or written communications with us, or through other means).  You further agree that as our policy changes we may continue to collect, store, process, and transmit your information, gathered prior to the latest version, pursuant to the latest version of this policy.  However, should you inform us of your desire for us to restrict or delete your data we will do so, unless we have a different legitimate purpose for engaging in any of those activities, regardless of the current version of this policy.  The date of this version of this policy is listed below.


This version is effective as of October 2, 2018.