1. Introduction & Our Details
Lease Transfer ("we", "us", "our") is committed to protecting your privacy and ensuring you have a positive experience on our website and platform. This Privacy Policy explains what personal data we collect, why we collect it, and how we use and protect it.
Lease Transfer is a trading name of Apany LTD, a company registered in England and Wales with company number 15187824.
We are the data controller for any personal data you provide to us. If you have any questions about this policy or our privacy practices, please contact us at contact@apany.co.uk.
2. Data We Collect
2.1 Account & Profile Data
When you register and use Lease Transfer, we collect: full name, email address, phone number (optional), business or personal address, and any profile data you choose to share.
2.2 Listing Data
If you create a lease transfer listing, we collect: vehicle registration details, vehicle specifications, photos, pricing information, location data, and any additional information you provide about the contract. This data is necessary to display your listing and allow interested parties to contact you.
2.3 Transactional Data
We store records of inquiries made, messages exchanged between parties, and listing history. Note that Lease Transfer facilitates the connection between parties; we do not directly process lease payments or hold transaction funds. Listing fees are processed by secure third-party payment providers in accordance with their own privacy policies.
2.4 Technical & Usage Data
We automatically collect: IP addresses, device information, browser type, pages visited, time spent on the website, and performance metrics. This helps us improve the user experience, diagnose technical issues, and provide aggregated analytics.
2.5 Communication Data
If you contact us via email, phone, or our contact forms, we keep records of your correspondence to respond to queries, provide support, and improve our service.
3. Legal Basis for Processing
Under UK GDPR, we only process your personal data where we have a lawful basis. We process your data on the following bases:
- Contractual necessity: To provide our services and fulfil your user agreement (e.g., publishing your listing).
- Legal obligation: To comply with UK law, tax requirements (HMRC), and regulatory obligations.
- Legitimate interests: To improve our services, prevent fraud, ensure network security, and operate our business efficiently.
- Consent: Where you have explicitly consented (e.g., opting in to marketing communications).
4. How We Use Your Data
- To provide, operate, and improve the Lease Transfer platform.
- To create and manage your user account.
- To authenticate your identity and manage secure access.
- To enable potential lease takers to review listings and contact you.
- To send essential service messages, billing receipts, and security alerts.
- To comply with legal and regulatory obligations.
- To analyse usage patterns and improve our services through aggregated insights.
- To detect, prevent, and address fraud or security issues.
5. Sharing & Disclosure
We may share your personal data in the following specific circumstances:
- With other users: When you create a listing, relevant vehicle and contract details are public. Contact is facilitated through our platform or via details you choose to share.
- With service providers: We use trusted third parties for hosting, email delivery, payment processing, analytics, and customer support — all bound by confidentiality agreements and data processing terms.
- Legal compliance: We may disclose data where required by law, court order, or regulatory authority.
- Business transfer: If Apany LTD is acquired or merges with another company, your data may be transferred as part of that transaction.
We do not sell your personal data to third parties for marketing purposes.
6. Cookies & Tracking
We use cookies and similar tracking technologies for:
- Session management and user authentication.
- Remembering your preferences and settings.
- Analytics to understand how visitors interact with our website.
- Security and fraud prevention.
You can control cookies through your browser settings. Some cookies are essential for the website to function properly. We provide a cookie consent mechanism on your first visit.
7. Data Security
We implement industry-standard security measures to protect your personal data, including:
- Encryption of data in transit (SSL/TLS).
- Secure storage of sensitive information.
- Access controls limiting data access to authorised personnel only.
- Regular security reviews.
While we take security seriously, no internet transmission is completely secure. If you suspect a data breach or security incident, please contact us immediately at contact@apany.co.uk.
8. Data Retention
We retain your personal data for as long as necessary to:
- Provide our services and fulfil our contractual obligations.
- Comply with UK legal and regulatory requirements (e.g., retaining financial records for 6 years for tax purposes).
- Resolve disputes or investigate complaints.
If you request account deletion, we will remove your personal data within 30 days, except for limited records we are legally required to retain.
9. Your Rights Under UK GDPR
Under the UK General Data Protection Regulation (UK GDPR), you have the following rights:
- Right of access: Request a copy of the personal data we hold about you.
- Right to rectification: Request correction of inaccurate or incomplete data.
- Right to erasure: Request deletion of your data ("right to be forgotten"), subject to legal exceptions.
- Right to restrict processing: Request that we limit how we use your data.
- Right to data portability: Request your data in a structured, commonly used format.
- Right to object: Object to processing for direct marketing or legitimate interests.
To exercise any of these rights, please contact us at contact@apany.co.uk. We will respond within one month. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at www.ico.org.uk.
10. Third-Party Links
Our website may contain links to third-party websites. We are not responsible for their privacy practices. We encourage you to review their privacy policies before providing personal data to them.
11. International Transfers
Apany LTD is based in the UK. If we transfer data outside the UK (e.g., to service providers in the USA or EEA), we ensure appropriate safeguards are in place, such as the UK International Data Transfer Agreement (IDTA) or equivalent adequacy decisions.
12. Marketing Communications
We may send you marketing communications about our services if you have opted in. You can opt out at any time by clicking the "unsubscribe" link in any email or contacting us directly.
13. Children's Privacy
Our services are not directed to children under 18 years of age. We do not knowingly collect personal data from children.
14. Changes to this Policy
We may update this Privacy Policy from time to time. Any material changes will be posted on this page with an updated revision date. Your continued use of Lease Transfer after changes constitutes acceptance of the updated policy.
15. Contact Us
For privacy queries, data subject requests, or concerns please contact us:
- Email: contact@apany.co.uk
- Company Name: Apany LTD (Trading as Lease Transfer)
- Registered in: England and Wales
- Registration Number: 15187824
Last updated: January 2025