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.
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.
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:
EASY LEASE can collect your personal data in different ways.
We collect the following types of personal data:
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:
EASY LEASE processes your personal data on the basis of the following legal grounds, and as the case may be:
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:
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:
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.
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:
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:
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:
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: firstname.lastname@example.org.
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.
You can check the date of the last revision of this Data Protection Policy at the very beginning of this document.