Privacy Policy

Information about EASY LEASE.

LUX BROKERAGE SARL, whose registered office is at 68 Avenue de la Liberté, L-1930 Luxembourg, registered in the Trade and Companies Register of the Grand Duchy of Luxembourg under number B181188, acting under the trade name EASY LEASE (here- after referred to as “EASY LEASE” or “we”) is a provider of mobility solutions as an intermediary, specializing in long-term operational leasing and company vehicle fleet management services.

As part of its activities and services, EASY LEASE processes, among other things, the personal data of its customers, and of its customers' employees (drivers). Regarding these activities processing, EASY LEASE acts as "controller", and is responsible for the protection of your personal data. As such, EASY LEASE strives to comply with the legislation in force in terms of data protection, in particular, from 25 May 2018, to European General Data Protection Regulation 2016/679 (the “Regulation” or “GDPR”) and applicable national laws implementing EU Directive 95/46 on data processing personal or supplementing the GDPR. Respecting your privacy is a priority for us.

EASY LEASE aspires to be a trusted partner and, for this reason, strives to respect and protect your personal data or that of your employees. This privacy policy aims to explain how we collect, store, use and disclose your personal data when you use our products and services, our websites or when you interact with us. This personal data protection policy also describes your rights and explains how you can exercise them. Please read this Personal Data Protection Policy carefully, so that the processing of your personal data is as transparent as possible.

Please also make sure that your employees are aware that their data personal data are processed by EASY LEASE, and that their consent to this data processing, described in this Personal Data Protection Policy, is obtained if necessary.

The following principles are at the heart of how we handle your personal data.

• Transparency and fairness: when we collect and process your personal data, we tell you the people who collect and receive this data, as well as the reasons forthis collection.
• Legitimacy: EASY LEASE does not collect or process personal data without a legitimate reason. Where required by law, we always ask for your prior consent (for example, to the extent necessary, before launching a direct marketing campaign).
• Purpose: we only use your personal data for relevant professional purposes (eg, to provide services, to manage customer relationships, to manage customer vehicle fleets, to execute accurate billings, for marketing activities, to better serve customers, to conduct satisfaction surveys, to write reports and comply with our legal obligations). We never use your personal data for purposes incompatible with the purposes described in this Privacy Policy or which are communicated to you elsewhere.
• Necessity and proportionality: we only collect the personal data necessary for data processing, in accordance with this Data Protection Policy personal. We only collect sensitive information when it is relevant. We take all reasonable steps to ensure that your personal data is accurate, complete and up to date. We only provide your data to business partners and suppliers to the extent necessary to provide our services to you or to comply with legal obligations.
  These principles are detailed in several sections below.

This Policy concerns all data sources collected and processed by EASY LEASE as part of its various commercial activities, in particular the submission of your request to our leasing and financing partners, the rental of professional vehicles, the rental of cars for individuals, fleet management, mobility solutions (bicycle rental, etc.), vehicle sales, use of our websites or mobile applications, etc.

We may collect and process your personal data if you fall into the following categories:

• clients (professionals or individuals);
• customer employees or other persons authorized by customers to benefit from a contract between the customer and EASY LEASE (i.e. the drivers of the vehicles);
• customer contact persons;
• fleet managers;
• prospects;
• buyers of used vehicles;
• guarantors;
• website visitors / users;
• directors of companies;
• shareholders;
• etc.

EASY LEASE can collect your personal data in different ways.

• We collect your personal data directly from you, when we interact with you (for example, when you contact EASY LEASE, EASY LEASE may keep a record of this correspondence), when you complete an online form (request form, voucher order, accident report form, etc.), when you create an account on one of our sites, etc.
• We may ask you to respond to surveys used for research or improvement, although you are not obligated to respond.
• We may record certain details about your visits to our websites, including but not limited to traffic, location data, weblogs and other data relating to the communication and resources you access.
• We may collect information about your computer or device, includingIP address, operating system or browser type. This information is collected to ensure the proper management and functioning of our websites. Cookies are used to collect this information.
• We may receive personal data from your employer with whom EASY LEASE has received a mandate (contact details, category of vehicle, etc.).
• We may receive personal data about you from our suppliers providing services as part of the performance of any contract (supplier of fuel cards for example, etc.).
• We may receive your personal data from the authorities (for example in the context of fines).

We collect the following types of personal data:

• Identification and contact data, including your name, first name, address, telephone number / mobile or e-mail address;
• Professional information, in particular your function, your department or your professional contact details;
• Financial or credit information, including the date of acceptance of your credit (s) or information about your contract, bank account, loans, etc .;
• Personal characteristics, including your gender, date of birth, nationality, language, marital status, etc. ;
• Your voice, which can be recorded during a call to EASY LEASE Customer Service;
• Data concerning you as a driver, in particular the number / duplicate of the driver's license or employee driver code;
• Data relating to the operations carried out on the vehicle and the use of the vehicle, in particular information on the vehicle (for example the license plate of the vehicle, the date of the last maintenance of the vehicle, etc.) and its use (for example, fuel consumption);
• Data on driver behavior, such as information provided by our suppliers' programs (average speed, etc.), taxes linked to the use of the vehicle (parking fees and taxes, etc.), accident history.

We are also sometimes required to collect sensitive data. For these data, we refer to section 12.

In order to improve your experience, when you visit our websites or use our mobile applications, we collect certain information by automated means, in particular through cookies, pixel tags, browser analysis tools, server logs and web beacons (eg Google Analytics).

If you use our websites, we may collect information about the browser that you use and your browsing behavior.

If you use our mobile app, we may collect your GPS location. We could also look at how often you use the app and where you downloaded it.

EASY LEASE processes your personal data for the following purposes, as the case may be, and for any other purpose that may be compatible with them:

• To undertake customer checks, credit checks and to get to know our customer through the “Know Your Customer” process: process and undertake assessments customers before entering into a contract or before the sale of a used vehicle.
• To comply with legal obligations and protect the rights and assets of EASY LEASE: we use personal data to respond to legitimate requests from the authorities monitoring and tax authorities, to detect and prevent money laundering, to conduct a due diligence of a counterparty, etc.
• To create and administer customer accounts.
• To communicate with you: you can contact us by various means (via our website, by phone, by e-mail, ...) in order to ask questions, request information, send comments, etc. We will use your personal data to communicate with you or to answer your questions.
• To provide you with services related to the vehicle and mobility included in the contract:
  • leasing or financing offer through our partners
  • vehicle control,
  • delivery of the vehicle,
  • repair, maintenance and tires,
  • vehicle insurance,
  • management of accidents and repairs,
  • management of fuel cards,
  • road assistance,
  • replacement vehicle,
  • management of the return of the vehicle (collection of the vehicle, etc.).
• To provide drivers with driving control applications (ecological or safety driving program) or provide managers with fleet management tools.
• In connection with the use of web portals and applications.
• To produce fleet reports for customers, linked to vehicle use (fuel consumption, accident history, etc.).
• For invoicing and accounting (invoicing, collection of payments, etc.).
• To manage conflicts (recovery of unpaid amounts, legal files, ...)
• To manage fines and all taxes, fees and administrative penalties related to the use of the vehicle, including parking, as well as all offenses.
• To inform customers of the results of satisfaction surveys.
• For administrative reports, in particular audits, internal control, data analysis.
• To keep business and professional records for legal, administrative and audit purposes. We also use the information to meet legal, insurance and processing requirements.
• To manage access and security of EASY LEASE premises and assets.
• For the sale of vehicles.
• For marketing purposes: we may use your information to contact you regarding new offers or services and special offers that we think may be useful, or to send you advertising messages or newsletters; we may analyze your profile and preferences as a customer, and undertake multi-channel advertising campaigns through automated tools, contact you by text message, email or send you brochures.
• For customer / driver satisfaction surveys based on marketing tools and targeted analytics, we may send you qualitative surveys about our products and services.
• We may also invite you to participate in events, games or advertising quizzes, through our mobile applications and / or websites.
• For websites, cookies and newsletters: we may collect information through cookies to gain experience and to give us a better idea of ​​your browsing type, in particular to store your preferences and settings in order to save time (including language preferences), to enable connection, to fight against fraud and to analyze the performance of our website and our services. This information helps us to improve our websites and applications, as well as to learn more about the products and services that you prefer. We also use cookies for web analytics to determine website activity as well as the most visited areas of websites. While we may set functional cookies to make it easier for you to visit our websites or applications, you may indicate your preferences regarding cookies used for behavioral targeted advertising, using your privacy settings choices. browser, in order to prevent the storage of information on the computer or the processing of information already on this computer, unless you activate the functionality to authorize this storage or processing.
• For profiling: in order for us to better understand what interests you and your concerns, we may use your personal data to improve our website and our services, to personalize your experience with us and to adapt our marketing activities to your needs and interests.

EASY LEASE processes your personal data on the basis of the following legal grounds, and as the case may be:

• The execution of the mandate you have entered into with EASY LEASE or the preparation of a contract that you intend to enter into with EASY LEASE or its partners;
• Your prior informed consent, when required;
• Compliance with our legal obligations (for example: anti-money laundering legislation, the provisions of the law of July 25, 2015 establishing the control and sanction system automated, etc. ;
• The legitimate interests of EASY LEASE or of a third party, insofar as these rights prevail over your fundamental rights and freedoms, such as, where applicable, to detect and prevent money laundering, to conduct a due diligence of a counterparty, provide you with useful information, etc.

In order to provide our services, we sometimes need to engage partners or processors for the purposes described above. We limit the sharing of your personal data to the following categories of recipients:

• external services such as our leasing or financing partners
• internal services such as the Sales department, the Customer Service / Quality department, the Marketing department, the IT, Support and Maintenance department;
• our client (your employer);
• our service providers in particular: data hosting providers, IT service providers, marketing partners, call processing centers, third parties carrying out fittings, maintenance, mechanical repairs, tire changes, damage assessment, damage repairs, assistance, etc.
• the authorities when required by law, for example in response to a subpoena, including law enforcement and courts, requests from tax authorities,
• when necessary to sell or transfer business assets, in the context of bankruptcy, to assert our rights, protect your property or the rights, property or safety of others or as needed, to support external audit, compliance and corporate governance functions.

We know that you do not want to transmit your personal data directly to third parties for their own marketing purposes, without your consent. Please note that we may also use and disclose personal data relating to you which is not personally identifiable, i.e. personal data in aggregate form, which no longer allows you to be identified.

EASY LEASE aims to ensure that your personal data is:

• protected against accidental or intentional destruction / loss;
• correctly used; and
• inaccessible to unauthorized persons.

All the information you provide to us is stored on our secure servers. Your personal data is stored either in our databases or in the database of our service providers. As part of an international contractual relationship, data may be transferred, stored and processed in any country or territory where one or more of our leasing or financing partners are located, outside the European Economic Area ( in countries such as Algeria, Belarus, Brazil, Chile, China, Colombia, India, Kazakhstan, Morocco, Mexico, Peru, Russia, Serbia, Switzerland, Turkey and Ukraine) with the aim of managing customer relations on an international level or providing car rental services harmonized with a globalized vehicle fleet.

We may also pass your personal data on to service providers involved in maintenance and support services (located in countries such as India), or involved in providing any other tool used for the processing of personal data of our customers and prospects.

When we transfer information outside the European Economic Area, we provide adequate protection for the transfer of your personal information to recipients in those countries, by entering into data transfer agreements with those recipients based on the clauses European Commission standards if necessary.

In general, we keep your personal data for as long as necessary for the purposes described in section 7 of this Privacy Policy, or in accordance with applicable laws.
For example, we only keep your personal data for as long as necessary in the context of your commercial relationship with EASY LEASE and, where applicable, the end of it, or as long as necessary to comply with legal obligations for EASY LEASE.
In the event of a dispute, we may retain your personal data until the complete resolution of the litigation. We will delete or archive this data in accordance with applicable law.

We are sometimes required to process sensitive data, mainly judicial information, such as fines, traffic violations, criminal data relating to claims (police report, etc.).

We process this data exclusively for the following purposes:

• For the management of claims and related litigation (recovery of amounts in the context of claims incurred during the rental period, etc.). If necessary, this data can be transmitted to the client (employer), to insurers and brokers involved in the management of the claim, to professional experts appointed by us or by them (lawyers, legal experts in charge of the case), to any sub - contractors involved in the management of claims, as well as to authorities and courts.
• For the management of fines and administrative penalties as well as all offenses related to the use of the hired vehicle. EASY LEASE and its possible subcontractor responsible for managing fines, may be required to:
  • process information concerning traffic fines, administrative penalties as well as traffic violations, in particular the place of the violation, the date and time, the violation itself, the amount to be paid; and
  • transmit personal data to the competent authorities in order to allow identification (via fax / e-mail); and optionally,
  • transmit the data relating to the administrative fine or sanction to the customer (often the driver's employer) in order to allow the management and invoicing of the fine or sanction.

We protect your data with technical and organizational security measures against accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access, and against any other form of unlawful processing.

When we outsource data processing, we impose contractual obligations to protect your information.

You can exercise a number of rights with regard to the processing of your personal data with regard to EASY LEASE, to the extent that you actually have these rights under the applicable data protection legislation, such as the GDPR.
To exercise the rights set out in this section at any time, please contact the correspondent to EASY LEASE data protection (see section 15) which will process your request.

Opposition. You have the right to object at any time to the processing of your personal data based on a legitimate interest of EASY LEASE, for example when they are used for (direct) marketing purposes, for establishing your profile in order to send you targeted advertising or when sharing your data with third parties or with other EASY LEASE entities.

Withdrawal. If you have previously consented to the processing of your personal data, you can withdraw this consent at any time. However, the legality of processing based on consent before withdrawal is not affected.

Access. You can request access to the personal data that we keep about you, or request a copy. You can also request information on the purposes of the processing, the categories of data, the categories of recipients, the terms of data retention, etc.

Portability. You may have the right to obtain a copy of any personal data we hold about you on our records, in a compatible format to enable you to exercise your right to data portability.

Limitation. You have the right to request that the processing of your personal data be restricted in the following cases:

• for a period allowing EASY LEASE to verify the accuracy of your personal data, in the event that you dispute the accuracy of the latter;
• if the processing is unlawful and you want to restrict the use of your personal data rather than delete it;
• if you want EASY LEASE to keep your personal data because you need it to defend yourself in legal proceedings;
• if you have objected to the processing, but we need to check whether the legitimate reasons for this processing outweigh your own rights.

Rectification. You may also have the right to rectify inaccurate personal data and to complete incomplete personal data.

Erasure. You have the right to request the erasure of your personal data in the following cases:

• if your personal data are no longer necessary for the purposes for which they were collected or processed;
• if you have withdrawn your consent and there is no other legal basis for the processing;
• if you have objected to the processing of data and there is no compelling legitimate reason for EASY LEASE;
• if the personal data have been the subject of unlawful processing;
• if the personal data must be erased to comply with a legal obligation to which EASY LEASE is submitted.

In the event of erasure, we will take reasonable steps to inform other EASY LEASE entities that may be involved in the processing of such data of this erasure.

Complaint. You also have the right to lodge a complaint with the competent supervisory authority in case of doubts about the conditions of processing of your personal data by EASY LEASE (National Commission for Data Protection, Avenue du Rock'n Roll 1, L-4361 Esch-sur-Alzette, Luxembourg, www.cnpd.lu).

In this regard, all questions, complaints or comments regarding this Personal Data Protection Policy or our data processing principles should be sent by e-mail at the following address: contact@easylease.lu.
In order to avoid any ambiguity, that a first interlocutor does not have the competence of a data protection officer within the meaning of the GDPR. An EASY LEASE data protection officer will then act as a second point of contact for any question concerning (suspected) non-compliance with the regulations and / or laws in force in terms of data protection.

Our Privacy Policy may change from time to time to reflect changes in the way we treat your personal data. We encourage you to periodically check our websites for the latest information on our data protection principles. We will notify you of any material changes as required by law.
You can check the date of the last revision of this Data Protection Policy at the very beginning of this document.