Fleetcor Europe Privacy Policy

This policy was lasted updated on 26 October 2020.

At Fleetcor Technologies, Inc., through our affiliates operating the Allstar, epyx, Fleetcor, The Fuelcard Company, Keyfuels, r2c, Travelcard, Tankpas.nl, Transit card and CCS brands, and servicing the Shell fuel card (collectively, “Fleetcor”, “we”, “our” or “us”), we respect your privacy. We have implemented this privacy policy to outline how Fleetcor uses personal data relating to its customers, prospective customers, fuel card holders, web users and other individuals who interact with us.

If you are applying for a role at one of our companies, then please see our dedicated job applicant privacy policy instead.

Fleetcor considers your privacy to be important. We are committed to protecting the privacy of the information you provide to us, including your personal data. This policy describes the types of personal data we collect, how we use that data, with whom we share it, the choices you can make about our use of such data, your privacy rights and how the law protects you. We also describe the measures we take to protect the security of your personal data and how you can contact us about our privacy practices.

Who we are

To understand who your data controller is please see the section entitled “How to reach us”.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to our privacy policy and how we handle your personal data. Details about how to contact our DPO can be found in the “How to reach us” section of this privacy policy.

Information we collect

As a provider of fuel card and expense management, and vehicle network services to businesses, we may have a direct relationship with you, and you may choose to provide personal data to us in connection with that relationship or we may collect it via other means. The data we collect about you may include:

Contact information

Login details

Financial information

Content you provide to us

Technical information about your device and website usage

Transaction history

Information about your characteristics and preferences

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Vehicle registration numbers and location

Information including your ID – date of issue, expiry, number, issuing body and address (for identification purposes).

To find out more please click here.

How we collect your information

We use different methods to collect data from and about you, depending upon the nature of our relationship. This may include through direct interactions we have with you, through the use of automated technologies (e.g. cookies) and from third parties or publicly available sources.

To find out more please click here.

How we use your data

Depending on the nature of our relationship with you, we may use your data to:

Process an application for an account you apply for.

Provide the services our customers have signed up for.

Process your transactions.

Administer your online account.

Protect ourselves against fraud and money laundering, verify your identity and to detect, investigate and prevent crime.

Provide you with information about our products and services.

Allow you to participate in interactive features e.g. via the website such as via our live chat function.

Operate, evaluate and improve our business.

Perform analysis (including anonymisation) of your data.

Comply with our legal obligations, applicable industry standards and our policies.

Administer the contracts we have with our customers, including to update contracts and to correspond with our customers about our services and the contracts.

Other ways which we notify you of at the time of its collection or use.

To find out more please click here.

Data we share and receive

We do not sell or otherwise disclose your data, except as described in this privacy policy. We may share your data with the following parties:

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Other members of the Fleetcor group.

If you are a fuel card holder, we will share transaction history and data usage information with your employer/the company you represent.

If you are a 1link user, other subscribers of the 1link services.

Providers of transaction services, such as card issuers, merchants, payment processors and other suppliers to assist with the transactions and administration of the fuel card services.

Marketing and data analytics companies.

Our commercial partners who sell similar products and services.

Partners who provide features on our websites.

IT suppliers.

Risk and fraud prevention agencies and monitoring providers.

Credit reference agencies.

Our insurers and professional advisers.

Regulators and other government agencies including, but not limited to, public authorities, regulators, the police and other law enforcement agencies.

Any company to whom we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets, along with its professional advisers.

We do not authorise any third parties that we share data with to use or disclose your data except as necessary to perform certain services on our behalf, to comply with legal requirements or as detailed under the Credit Reference Agencies section of this policy. We require these third parties, through our contractual arrangements with them, to appropriately safeguard the privacy and security of the data they process on our behalf.

We may also receive data about you from the following third parties:

Social media platforms.

Your employer.

Credit reference agencies: information relating to credit score/suitability for products.

Data brokers.

Our commercial partners.

Public databases.

Regulators and other government agencies.

If you would like to receive a full list of our suppliers and other third parties who we share your data with or receive your data from then you can get in touch with us using the details provided in the section “How to reach us?”.

Credit Reference Agencies

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In order to process applications we will supply personal information you provide to credit reference agencies (CRAs) and they will give us information about you, such as about your financial history. We do this to assess creditworthiness and product suitability, check your identity, manage your account, trace and recover debts and prevent criminal activity. We will also continue to exchange information about you with CRAs on an ongoing basis, including about your settled accounts and any debts not fully repaid on time. CRAs will share your information with other organisations.

CRAIN (Credit Reference Agency Information Notice) is a document produced by the three Credit Reference Agencies- Experian, Equifax and TransUnion (formerly Callcredit)- that explains the use of personal data they receive from third parties about individuals and/or their businesses in relation to credit activity. CRAIN has been produced in conjunction with the Information Commissioner’s Office (ICO).

The CRAIN, the identities of the CRAs and the ways in which they use and share personal information, are explained in more detail at http://www.experian.co.uk/crain/index.html.

Where your data may be sent

As with any multinational organisation, we are often required to transfer data internationally. Accordingly, your personal data may be transferred globally (if your data is collected within the European Union, this means that your data may be transferred outside of it).

This includes transfers that have been identified in the previous section “Who do we share your data with and for what purposes”.

To find out more please click here.

How we keep your information secure

Fleetcor will take appropriate technical and organisational security measures to secure your personal data and to protect it from loss, misuse or alteration. Personal data that we hold about you is stored on our secure servers or those of our appointed suppliers. Our web pages that collect your data are secured with Secured Socket Layers (SSLs).

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share this password with anyone.

Fleetcor maintains an information security program that is designed to:

Secure and maintain confidentiality of your personal data.

Protect against anticipated threats or hazards to security or integrity of your data.

Protect against unauthorised access to or use of your data that could result in substantial harm or inconvenience to you or your entity if compromised.

Comply with applicable laws.

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How long we may keep your data

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data can be requested by contacting the DPO.

In some circumstances you can ask us to delete your data, please see “Your Rights and Choices”.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with or be used to identity you) for research or statistical purposes in which case we may use such data indefinitely without further notice to you.

Children’s privacy

Fleetcor’s websites are not intended for use by children, especially those under the age of 18. No one under the age of 18 should provide any personal data or participate in any forums, chats, or online discussions. Minors under the age of 18 are prohibited from applying for emails, newsletters and/or products or services, on our websites. If we identify that we have received any such personal data we will delete it.

Your rights and choices

You may have some or all of the following rights in respect of personal data about you that we hold:

Request us to give you access to it.

Request us to rectify it, update it, or erase it.

Request us to restrict our using it, in certain circumstances.

Object to our using it, in certain circumstances.

Where legally possible, withdraw your consent to our using it.

Data portability, in certain circumstances.

Opt out from or objecting to our using it for direct marketing.

Lodge a complaint with the supervisory authority in your country (if there is one).

You are able to exercise these rights by contacting us using the details set out at in the “How to reach us” section below.

Please visit our cookie policy to learn about how you can also exercise your rights in relation to our use of cookies, web beacons and similar technologies.

To find out more please click here.

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How to reach us

If you have any questions about our privacy policy, including any requests to exercise your legal rights in relation to the data we hold on you, then please contact the relevant DPO using the details set out below:

Country

Product

Data Controller

DPO

Email

Postal Address

Address

Austria

Shell card

FleetCor

Darren

dsb@fleetcor.

Teinfaltstraße

Tankkarten

Pascoe

at

8/4, 1010 Wien.

GmbH

Belgium

Shell card

FleetCor

Darren

dpo@fleetcorc

Avenue Du Port

Belgium Srl

Pascoe

ards.be

86c/204, 1000

Bruxelles.

Shell card

FleetCor

Darren

dpo@fleetcorc

Havenlaan 86c

Belgium bv

Pascoe

ards.be

Bus 204, 1000

Brussel.

TravelCard

Travelcard B.V.

Darren

dpo@fleetcorc

Rue de Colonies

Pascoe

ards.be

11, 1000

Brussel.

Czech

Shell card

FleetCor Czech

Darren

dpo@fleetcor.

Voctářova

Republic

Republic s.r.o.

Pascoe

cz

2500/20a, 180

00 Praha 8.

CCS Bonus

CCS Česká

Darren

dpo@fleetcor.

Voctářova

Fleet,

společnost pro

Pascoe

cz

2500/20a, 180

CCS Bonus

platební karty

00 Praha 8.

Plus,

s.r.o

CCS Bonus,

CCS Carnet,

CCS Limit

Exclusive,

CCS Limit

Plus,

CCS Limit,

CCS Toll,

UTA/CCS

card.

Denmark

1link Services

epyx Limited

Darren

dpo@fleetcor.

Heath Farm

Pascoe

com

Hampton Lane,

Meriden,

Coventry CV7

7LL, United

Kingdom.

France

1link Services

Epyx France

Darren

dpo@fleetcor.

35 Allée des

SAS

Pascoe

com

Impresssioniste

s, Le

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Cézanne,93420

Villepinte.

Shell Card

Epyx France

Darren

dpo@fleetcor.

35 Allée des

SAS

Pascoe

fr

Impresssioniste

s, Le

Cézanne,93420

Villepinte.

Germany

Shell Card

FleetCor

Darren

dsb@fleetcor.

Frankenstraße

Deutschland

Pascoe

de

150 c, 90461

GmbH

Nürnberg.

Hungary

Shell Card

FleetCor

Darren

adatvedelem

1062 Budapešť,

Hungary Kft

Pascoe

@fleetcor.hu

Andrássy út

100.

Ireland

1link Services

epyx Limited

Darren

dpo@fleetcor.

Heath Farm

Pascoe

com

Hampton Lane,

Meriden,

Coventry CV7

7LL, United

Kingdom.

Lithuania

Transit Card

UAB Transit

Darren

dpo@fleetcor.l

Mindaugo g. 44-

Card

Pascoe

t

82, LT-01311,

International

Vilnius.

Luxembourg

Shell Card

Venturo

Darren

dpo@fleetcor.l

46A, avenue

Technologies

Pascoe

u

J.F. Kennedy, L-

s.a.r.l.

1855,

Luxembourg.

Netherlands

Shell Card

FleetCor

Darren

dpo@fleetcor.

P.J. Oudweg 4,

Technologieёn

Pascoe

nl

1314CH Almere.

B.V.

TravelCard

TravelCard B.V.

Darren

dpo@fleetcor.

P.J. Oudweg 4,

Pascoe

com

1314CH Almere.

Tankpas.nl

Travelcard B.V.

Darren

dpo@fleetcor.

P.J. Oudweg 4,

Pascoe

com

1314CH Almere.

Poland

Shell Card,

FleetCor Poland

Darren

daneosobowe

Generation Park

Allstar Mondo,

sp. z o.o.

Pascoe

@fleetcor.pl

Z

FLEETCOR

ul. Towarowa

Carnet,

28,

Shell Card

00-839

Plus Business

Warszawa.

Transit Card

Transit Card

Darren

daneosobowe

Al. Solidarności

International

Pascoe

@fleetcor.pl

117/606,

Polska Sp. z

00-140

o.o.

Warszawa.

Slovakia

CCS Bonus

CCS Slovenská

Darren

dpo@fleetcor.

Galvaniho 15/C

Fleet,

spoločnosť pre

Pascoe

sk

Bratislava –

CCS Bonus

platobné karty

Ružinov 821 04.

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Plus,

s.r.o.

CCS Bonus,

CCS Carnet,

CCS Limit

Exclusive,

CCS Limit

Plus,

CCS Limit,

CCS Toll &

UTA/CCS card

Shell Card

FleetCor

Darren

dpo@fleetcor.

Galvaniho 15/C

Slovakia s.r.o.

Pascoe

sk

Bratislava –

Ružinov 821 04.

Switzerland

Shell card

Venturo

Darren

dsb@fleetcor.

c/o Silvia

Technologien

Pascoe

ch

Margraf

Swiss GmbH

Advokatur und

Notariat,

Industriestrasse

47, 6300 Zug.

United

1link Services

Epyx Limited

Darren

dpo@fleetcor.

Heath Farm

Kingdom

Pascoe

com

Hampton Lane,

Meriden,

Coventry, CV7

7LL.

Allstar

Allstar Business

Darren

dpo@fleetcor.

Allstar Business

Expense,

Solutions

Pascoe

com

Solutions

Allstar Monitor

Limited

Limited, PO

Allstar One,

BOX 1463,

Allstar Plus

Windmill Hill,

(Vehicle

Restricted)

Whitehill Way,

Allstar Plus

Swindon, SN5

Monitor,

6PS.

Allstar One,

Allstar Plus,

Allstar

Supermarket+,

Allstar

Prepaid,

Allstar Premier

Programme,

Allstar Classic,

Allstar

Supermarket

Allstar

The Fuelcard

Darren

dpo@fleetcor.

Unit 3 St James

Universal,

Company UK

Pascoe

com

Business Park,

Diesel

Limited

Grimbald Crag

Advance,

Court,

Esso

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Commercial,

Knaresborough,

Esso Multi,

North Yorkshire,

Esso Single,

HG5 8QB.

Shell Fleet

List,

Shell Multi,

Shell CRT,

Shell Single

Texaco and

Fastfuel

Fuelvend,

C H Jones

Darren

dpo@fleetcor.

Unit 3 St James

Keyfuels and

Limited

Pascoe

com

Business Park,

MYFUEL

Grimbald Crag

Court,

Knaresborough,

North Yorkshire,

HG5 8QB.

R2C Services

R2C Online

Darren

dpo@fleetcor.

2 Vantage

Limited

Pascoe

com

Drive, Sheffield,

S9 1RG

If your country of residence has a data protection authority, you have a right to contact it with any questions or concerns. If we cannot resolve your questions or concerns, you also have the right to seek judicial remedy before a national court.

Updates to this privacy policy

We will update this policy from time to time to reflect changes in our business. We will inform you of these changes as required under applicable laws.

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Fleetcor Europe Privacy Policy (Long Form)

This policy was lasted updated on 26 October 2020.

At Fleetcor Technologies, Inc., through our affiliates operating the Allstar, epyx, Fleetcor, The Fuelcard Company, Keyfuels, r2c, Travelcard, Transit card, Tankpas.nl and CCS brands, and servicing the Shell fuel card (collectively, “Fleetcor”, “we”, “our” or “us”), we respect your privacy. We have implemented this privacy policy to outline how Fleetcor uses personal data relating to its customers, prospective customers, fuel card holders, web users and other individuals who interact with us.

If you are applying for a role at one of our companies, then please see our dedicated job applicant privacy policy instead.

Fleetcor considers your privacy to be important. We are committed to protecting the privacy of the information you provide to us, including your personal data. This policy describes the types of personal data we collect, how we use that data, with whom we share it, the choices you can make about our use of such data, your privacy rights and how the law protects you. We also describe the measures we take to protect the security of your personal data and how you can contact us about our privacy practices.

Who we are

To understand who your data controller is please see the section entitled “How to reach us”.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to our privacy policy and how we handle your personal data. Details about how to contact our DPO can be found in the “How to reach us” section of this privacy policy.

Information we collect

As a provider of fuel card and expense management, and vehicle network services to businesses, we may have a direct relationship with you, and you may choose to provide personal data to us in connection with that relationship or we may collect it via other means. The data we collect about you may include:

Contact information

Login details

Financial information

Content you provide to us

Technical information about your device and website usage

Transaction history

Information about your characteristics and preferences

Vehicle registration numbers and location

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Information including your ID – date of issue, expiry, number, issuing body and address (for identification purposes).

Contact information

If you are a customer of ours, a card holder or otherwise interact with us (e.g. through our website) then we will collect certain basic contact information about you. This may include your name, postal address, email address, phone number and fax number.

In the event that you are a representative or employee of one of our customers then we may also collect the name of your employer/the company your represent, your role at the company and job title. If you are a customer of our vehicle tracking service then this may include the location of your vehicle and its journey history.

Login details

If you have an online account with us, then we will store your username and password in order to manage your access to our platforms.

Financial information

This may include your fuel card number, credit/debit card details, bank account information and details we collect about your credit status if we conduct a credit report.

Know your client information

This may include your date of birth and personal address, passport number, driving licence number and/or national insurance number.

If you are a director or beneficial owner of a prospective customer then we may capture and use your personal data to conduct credit and anti-money laundering checks.

Please bear in mind that we may collect and consult your personal data in public registers and public sources (e.g. via the internet) as part of the know your client process.

Content you provide to us

For instance, you may get in touch with us via our website or by telephone, we may email you or vice versa or you may send us feedback via a survey form.

Technical information about your device and website usage

If you use our website or mobile applications then we will install certain cookies and web beacons on your device. The details of how we use these technologies is further outlined in our cookie policy.

Through cookies, web beacons and similar technologies we may collect details about your device, such as IP address, internet browser type and operating system. We may also collect information about your browsing activity, such as how you use our website, the pages you have visited, the date and time of each visit and the URLs of any websites that re-directed you to our website.

Transaction history

If you are a card holder, then we will collect records of your transactions on that card, including the location date and time of the transaction and the cost of the fuel, goods or services.

Location data

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If you are a card holder, then we will collect information on the location of any transactions carried out on the card.

With your consent, we will access location-based information or collect location markers from your mobile device or based on your IP address. We will use this information to provide you with notifications related to our locations. We do not use this information to specifically locate you for any reason other than to provide you with the service. If you have allowed us to utilise your location information in the past and wish to revoke the permissions, please change the settings on your device.

Vehicle location data

Some of our services may involve the use of a vehicle telematics system. Some telematics systems provide us with use of, disclosure of or access to location information and mileage as permitted by law.

Use of the telematics system is subject to the terms and conditions and privacy policy posted by the applicable telematics systems provider.

Information about your characteristics and preferences

We may collect certain details about you and your preferences (as a prospective customer, customer and/or card holder). This may include your purchasing behaviour and preferences.

How we collect your information

We use different methods to collect data from and about you, depending upon the nature of our relationship. This may include through direct interactions we have with you, through the use of automated technologies (e.g. cookies) and from your employer, third parties or publicly available sources.

Direct interactions

You may provide us with your data by completing forms (e.g. through our website) or by corresponding with us by post, phone, email or otherwise. This includes data you provide when you:

Apply for a product or service on our website or through one of our sales associates.

Create an account on our websites.

Sign up to receive information (e.g. subscribe to our email marketing list).

Participate in promotions or surveys.

Provide us with feedback.

Otherwise communicate with us.

Automated technologies

As part of the processing of your personal data, decisions may be made by automated means. This means we may automatically decide that you pose a fraud or money laundering risk if our processing reveals your behaviour to be consistent with money laundering or known fraudulent conduct, or is inconsistent with your previous submissions, or you appear to have deliberately hidden your true identity. You have rights in relation to automated decision making: if you want to know more please contact the DPO.

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If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services or financing you have requested, or to employ you, or we may stop providing existing services to you.

As you interact with our website, we may automatically collect technical information about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

Third party or publicly available sources

We may receive personal data about you from various third parties and public sources, including financial institutions and payment processors, credit reference agencies, credit institutions and commercial information services. For further details about the third parties that Fleetcor may collect and provide your personal data to see the section of this privacy policy entitled ”Data we share and receive”.

How we use your data

Depending on the nature of our relationship with you, we may use your data to:

Process an application for an account you apply for.

Provide the services our customers have signed up for.

Process your transactions.

Administer your online account.

Protect ourselves against fraud and money laundering, verify your identity and to detect, investigate and prevent crime.

Carry out checks in relation to your creditworthiness.

Provide you with information about our products and services.

Allow you to participate in interactive features e.g. via the website such as via our live chat function.

Operate, evaluate and improve our business.

Perform analysis (including anonymisation) of your data.

Comply with our legal obligations, applicable industry standards and our policies.

Administer the contracts with our customers, including to update contracts and to correspond with our customers about our services and the contracts.

Other ways which we notify you of at the time of its collection or use.

The table below sets out further information about the purposes for which we use data about you, with the corresponding categories of data processed in each case and the legal basis that we rely upon for its use.

Purpose

Categories of data processed and legal

basis for processing

Process an application for a customer account

Categories of data processed

Contact information

Initiate applications for accounts you

Financial information

request, notify you of the application

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status or request additional information in

Know your client information

relation to your application.

Legal basis

Obtain know your client and credit

It is in our legitimate business interests to

process your personal data as part of the

information when you apply for a product

customer application process.

or subsequently.

Provide the services our customers have

Categories of data processed

signed up for

Contact information

In order for our customers to receive the

Financial information

service(s).

Know your client information

Legal basis

It is in our legitimate business interests and in

the legitimate business interests of our

customers to process your personal data as

part of the customer application process and

as part of the services, including to

correspond with you about the contract and

the services being provided to our customers.

Process your card transactions

Categories of data processed

We will use your contact information and

Contact information

unique fuel card identifiers to process fuel

Financial information

card payments when you purchase fuel.

Transaction history

We will keep a record of your transaction

Legal basis

history information relating to your card in

It is our legitimate business interest to provide

order to calculate the fees owed to us by

the fuel card services that we are contracted

you and/or your employer and provide

to perform in our contract with our customers.

them with evidence of the transactions.

Administer our customer’s online accounts

Categories of data processed

Allow us to authenticate your user

Contact information

credentials when you login to your online

Login details

account.

Transaction history

Respond to enquiries you may make in

Legal basis

It is in our legitimate interests to administer

relation to your account.

and manage the account of our customer as

Allow you to access certain information

provided for under our contract with our

customer.

about your account with us, such as your

transaction history.

Protect ourselves against fraud and money

Categories of data processed

laundering, verify your identity and to detect,

Contact information

investigate and prevent crime.

Transaction history

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Review and monitor your transaction

Financial information

Know your client information

history to identify any potential fraud,

money laundering or other unlawful

Legal basis

behavior in relation to your account.

It is necessary for compliance with legal

Carry out know your client and sanctions

obligations to which we are subject to.

checks on a request basis.

If fraud is detected, you could be refused

certain services. Further details of how

your information will be used by us and

these fraud prevention agencies, and your

data protection rights, can be found by

https://www.cifas.org.uk/fpn.

Provide you with information about our

Categories of data processed

products and services

Contact information

If you have requested to receive such

Transaction history

information from us, then we may contact

Legal basis

you from time to time by email, post,

We will only send you information about our

telephone and/or SMS about our products

products and services if you have consented

and services and any products and

to receiving them or based on our legitimate

services of third parties.

interests (where we are permitted to do so

under applicable law).

Allow you to participate in interactive features

Categories of data processed

If you interact with the “chat” function on

Contact information

our websites.

Information about your characteristics

and preferences

If you interact with us via our Facebook,

Legal basis

Twitter or Linked In accounts.

It is our legitimate business interest to provide

such features which you may choose to take

up for your enjoyment and convenience.

Operate, evaluate and improve our business,

Categories of data processed

products and services

Contact information

Recording of telephone calls and online

Transaction history

chats that we have with you for training or

Content you provide to us

quality assurances.

Technical information about your

device and website usage

Monitor the use of and improve our

Information about your characteristics

and preferences

interactive assets.

Legal basis

Perform data analyses (including

It is our legitimate business interest to review

anonymisation) of your data.

and improve our business, products and

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services to ensure that customer satisfaction

is as high as possible. We will conduct data

analyses (including benchmarking and

reporting to enable us to do so).

To share information with third parties

Categories of data processed

See the section entitled “Data we share

All personal data we hold about you

and receive” and “Credit Reference

Legal basis

Agencies” for more information.

It is our legitimate business interest to share

your personal data with trusted third parties.

We may share your personal data with third

parties who provide us with services relevant

to our business, such as those outlined in the

“Data we share and receive” section of this

privacy

policy and with credit reference

agencies as detailed in the “Credit Reference

Agencies” section of this privacy policy.

In the case of third party marketing we only

share your personal data if you have provided

consent.

Comply with our legal obligations, applicable

Categories of data processed

industry standards and our policies

All personal data we hold about you

To audit compliance with our legal

Legal basis

obligations including regulatory

requirements.

It is necessary for compliance with legal

obligations to which we are subject.

Administer the contracts with our customers,

Categories of data processed

including to update and to correspond with

All personal data we hold about you

our customers about our services and the

contracts

Legal basis

To provide contract updates and

It is in our legitimate business interests and

service(s) updates

those of our customers to correspond with our

customers (via you) in relation to their

contract, any updates to such contracts

(whether to reflect updates to the services or

the law) and to correspond with them about

the services.

It is necessary for compliance with legal

obligations to which we are subject.

Defend ourselves against or issue legal claims

Categories of data processed

We may keep records of your data, such

Contact information

as your transactions for evidential

Login details

purposes in order to defend ourselves

Content you provide to us

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against or issue one or more future legal claims.

Transaction history

Legal basis

It is our legitimate business interest to defend ourselves against and issue legal claims.

We may also share your personal data with third parties in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets, along with its professional advisers.

If we use your personal data in ways that are not described above, we will provide you with notice of this before doing so.

Data we share and receive

We do not sell or otherwise disclose your data, except as described in this privacy policy. We may share your data with the following parties:

Other members of the Fleetcor group.

If you are a fuel card holder, we will share transaction history and data usage information with your employer/the company you represent.

If you are a 1Link user, other subscribers of 1Link services.

Providers of transaction services, such as card issuers, merchants, payment processors and other suppliers to assist with the transactions and administration of the fuel card services.

Marketing and data analytics companies.

Our commercial partners who sell similar products and services.

Partners who provide features on our websites.

IT suppliers.

Risk and fraud prevention agencies and monitoring providers.

Credit reference agencies.

Our insurers and professional advisers.

Regulators and other government agencies including, but not limited to, public authorities, regulators, the police and other law enforcement agencies.

Any company to whom we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets, along with its professional advisers.

We do not authorise any third parties that we share data with to use or disclose your data except as necessary to perform certain services on our behalf, to comply with legal requirements or as detailed under the Credit Reference Agencies section of this policy. We require these third parties, through our

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contractual arrangements with them, to appropriately safeguard the privacy and security of the data they process on our behalf.

We may also receive data about you from the following third parties:

Social media platforms.

Your employer.

Credit reference agencies: information relating to credit score/suitability for products.

Data brokers.

Our commercial partners.

Public databases.

Regulators and other government agencies.

If you would like to receive a full list of our suppliers and other third parties who we share your data with or receive your data from then you can get in touch with us using the details provided in the section “How to reach us?”.

Credit Reference Agencies

In order to process applications we will supply personal information you provide to credit reference agencies (CRAs) and they will give us information about you, such as about your financial history. We do this to assess creditworthiness and product suitability, check your identity, manage your account, trace and recover debts and prevent criminal activity. We will also continue to exchange information about you with CRAs on an ongoing basis, including about your settled accounts and any debts not fully repaid on time. CRAs will share your information with other organisations.

CRAIN (Credit Reference Agency Information Notice) is a document produced by the three Credit Reference Agencies- Experian, Equifax and TransUnion (formerly Callcredit)- that explains the use of personal data they receive from third parties about individuals and/or their businesses in relation to credit activity. CRAIN has been produced in conjunction with the Information Commissioner’s Office (ICO).

The CRAIN, the identities of the CRAs and the ways in which they use and share personal information, are explained in more detail at http://www.experian.co.uk/crain/index.html.

Where your data may be sent

As with any multinational organisation, we are often required to transfer data internationally. Accordingly, your personal data may be transferred globally (if your data is collected within the European Union, this means that your data may be transferred outside of it). This includes transfers that have been identified in the previous section “Who do we share your data with and for what purposes”.

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When using personal data as described in this privacy policy, it may be transferred either within or outside the country or territory where it was collected, including to a country, territory or international organisation that may not have EU equivalent data protection standards.

For example, we may transfer your personal data to our vendors based outside the European Union. In all cases, the transfer will be on the basis of a European Commission adequacy decision or we will implement adequate measures, for example the EU Model Contracts, and including appropriate security measures, for the protection of personal data in those countries, territories or international organisations in accordance with applicable data protection laws. If you would like more information about any of the data transfer measures on which we rely please contact us using the details provided in the section “How to reach us”?.

How we keep your information secure

Fleetcor will take appropriate technical and organisational security measures to secure your personal data and to protect it from loss, misuse or alteration. Personal data that we hold about you is stored on our secure servers or those of our appointed suppliers. Our web pages that collect your data are secured with Secured Socket Layers (SSLs).

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share this password with anyone.

Fleetcor maintains an information security program that is designed to:

Secure and maintain confidentiality of your personal data.

Protect against anticipated threats or hazards to security or integrity of your data.

Protect against unauthorised access to or use of your data that could result in substantial harm or inconvenience to you or your entity if compromised.

Comply with applicable laws.

How long we may keep your data

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data can be requested by contacting the DPO.

In some circumstances you can ask us to delete your data, please see “Your Rights and Choices”.

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In some circumstances we may anonymise your personal data (so that it can no longer be associated with or be used to identity you) for research or statistical purposes in which case we may use such data indefinitely without further notice to you.

Children’s privacy

Fleetcor’s websites are not intended for use by children, especially those under the age of 18. No one under the age of 18 should provide any personal data or participate in any forums, chats, or online discussions. Minors under the age of 18 are prohibited from applying for emails, newsletters and/or products or services, on our websites. If we identify that we have received any such personal data we will delete it.

Your rights and choices

You may have some or all of the following rights in respect of personal data about you that we hold:

Request us to give you access to it.

Request us to rectify it, update it, or erase it.

Request us to restrict our using it, in certain circumstances.

Object to our using it, in certain circumstances.

Where legally possible, withdraw your consent to our using it.

Data portability, in certain circumstances.

Opt out from or object to our using it for direct marketing.

Lodge a complaint with the supervisory authority in your country (if there is one).

You are able to exercise these rights by contacting us using the details set out at in the “How to reach us” section below.

Please visit our cookie policy to learn about how you can also exercise your rights in relation to our use of cookies, web beacons and similar technologies.

You have the rights set out in the table below:

Right in respect of the data about you that we Further detail (note: certain legal limits to all these rights apply) hold

This is confirmation of:

whether or not we process data about you;

our name and contact details;

the purpose of the processing;

the categories of data concerned;

To request us to give

the categories of persons with whom we share the data and, where

you access to it

any person is outside the EU and does not benefit from a

European Commission adequacy decision, the appropriate

safeguards for protecting the data;

(if we have it) the source of the data, if we did not collect it from

you;

(to the extent we do any, which will have been brought to your

attention) the existence of automated decision-making, including

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Right in respect of the

data about you that we

Further detail (note: certain legal limits to all these rights apply)

hold

profiling, that produces legal effects concerning you, or significantly

affects you in a similar way, and information about the logic

involved, as well as the significance and the envisaged

consequences of such processing for you; and

the criteria for determining the period for which we will store the

data.

On your request we will provide you with a copy of the data we hold.

To request us to rectify

This applies if the data we hold is inaccurate or incomplete.

or update it

This applies if:

The personal data we hold is no longer necessary in relation to the

purposes for which we use it;

we use the data on the basis of your consent and you withdraw

your consent (in this case, we will remember not to contact you

To request us to erase

again, unless you tell us you want us to delete all personal data

it

about you in which case we will respect your wishes);

we use the data on the basis of legitimate interests and we find

that, following your objection, we do not have an overriding interest

in continuing to use it;

the data was unlawfully obtained or used; or

to comply with a legal obligation.

This right applies, temporarily while we look into your case, if you:

contest the accuracy of the personal data we use; or

have objected to our using the personal data on the basis of

To

request us

to

legitimate interests

(if you make use of your right in these cases, we will tell you before we

restrict our processing

use the data again).

of it

This right applies also if:

our use is unlawful and you oppose the erasure of the data; or

we no longer need the data, but you require it to establish a legal

case.

You have two rights here:

if we use data about you for direct marketing: you can “opt out”

To

(without the need to justify it) and we will comply with your request;

object to

our

and

processing it

if we use the data about you on the basis of legitimate interest for

purposes other than direct marketing, you can object to our using it

for those purposes, giving an explanation of your particular

situation, and we will consider your objection.

To

withdraw

your

This right applies to any data which we have collected and process

consent to our using

based on your consent.

it

You have the right at any time to withdraw the consent you have

provided to us.

This right applies:

To data portability

(i)

to personal data that you have provided to us; and

(ii) if we use that data on the basis either of your consent, or on the

basis of discharging our contractual obligations to you.

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Right in respect of the

data about

you

that we

Further detail (note: certain legal limits to all these rights apply)

hold

If both (i) and (ii) apply, you have the right to receive the data back

from us in a commonly used format, and the right to require us to

transmit the data to someone else if it is technically feasible.

To

lodge

a complaint

Each European Union country must provide for one or more public

authorities for this purpose.

with

the

supervisory

You can find their contact details here:

authority

in

your

http://ec.europa.eu/justice/data-

country

protection/bodies/authorities/index_en.htm

How to reach us

If you have any questions about our privacy policy, including any requests to exercise your legal rights in relation to the data we hold on you, then please contact the relevant DPO using the details set out below:

Country

Product

Data Controller

DPO

Email

Postal Address

Address

Austria

Shell card

FleetCor

Darren

dsb@fleetcor.

Teinfaltstraße

Tankkarten

Pascoe

at

8/4, 1010 Wien.

GmbH

Belgium

Shell card

FleetCor

Darren

dpo@fleetcorc

Avenue Du Port

Belgium Srl

Pascoe

ards.be

86c/204, 1000

Bruxelles.

Shell card

FleetCor

Darren

dpo@fleetcorc

Havenlaan 86c

Belgium bv

Pascoe

ards.be

Bus 204, 1000

Brussel.

TravelCard

Travelcard B.V.

Darren

dpo@fleetcorc

Rue de Colonies

Pascoe

ards.be

11, 1000

Brussel.

Czech

Shell card

FleetCor Czech

Darren

dpo@fleetcor.

Voctářova

Republic

Republic s.r.o.

Pascoe

cz

2500/20a, 180

00 Praha 8.

CCS Bonus

CCS Česká

Darren

dpo@fleetcor.

Voctářova

Fleet,

společnost pro

Pascoe

cz

2500/20a, 180

CCS Bonus

platební karty

00 Praha 8.

Plus,

s.r.o

CCS Bonus,

CCS Carnet

CCS Limit

Exclusive,

CCS Limit

Plus,

CCS Limit,

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CCS Toll and

UTA/CCS card

Denmark

1link Services

epyx Limited

Darren

dpo@fleetcor.

Heath Farm

Pascoe

com

Hampton Lane,

Meriden,

Coventry CV7

7LL, United

Kingdom.

France

1link Services

Epyx France

Darren

dpo@fleetcor.

35 Allée des

SAS

Pascoe

com

Impresssioniste

s, Le Cézanne,

93420 Villepinte.

Shell Card

Epyx France

Darren

dpo@fleetcor.

35 Allée des

SAS

Pascoe

fr

Impresssioniste

s, Le Cézanne,

93420 Villepinte.

Germany

Shell Card

FleetCor

Darren

dsb@fleetcor.

Frankenstraße

Deutschland

Pascoe

de

150 c, 90461

GmbH

Nürnberg.

Hungary

Shell Card

FleetCor

Darren

adatvedelem

1062 Budapešť,

Hungary Kft

Pascoe

@fleetcor.hu

Andrássy út

100.

Ireland

1link Services

epyx Limited

Darren

dpo@fleetcor.

Heath Farm

Pascoe

com

Hampton Lane,

Meriden,

Coventry CV7

7LL, United

Kingdom.

Lithuania

Transit Card

UAB Transit

Darren

dpo@fleetcor.l

Mindaugo g. 44-

Card

Pascoe

t

82, LT-01311,

International

Vilnius.

Luxembourg

Shell Card

Venturo

Darren

dpo@fleetcor.l

46A, avenue

Technologies

Pascoe

u

J.F. Kennedy, L-

s.a.r.l.

1855,

Luxembourg.

Netherlands

Shell Card

FleetCor

Darren

dpo@fleetcor.

P.J. Oudweg 4,

Technologieёn

Pascoe

nl

1314CH Almere.

B.V.

TravelCard

TravelCard B.V.

Darren

dpo@fleetcor.

P.J. Oudweg 4,

Pascoe

com

1314CH Almere.

Tankpas.nl

Travelcard B.V.

Darren

dpo@fleetcor.

P.J. Oudweg 4,

Pascoe

com

1314CH Almere.

Poland

Shell Card,

FleetCor Poland

Darren

daneosobowe

Generation Park

Allstar Mondo,

sp. z.o.o.

Pascoe

@fleetcor.pl

Z, ul. Towarowa

FLEETCOR

28, 00-839

Carnet,

Warszawa.

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Shell Card

Plus Business

Transit Card

Transit Card

Darren

daneosobowe

Al. Solidarności

International

Pascoe

@fleetcor.pl

117/606

Polska Sp. z

00-140

o.o.

Warszawa.

Slovakia

CCS Bonus

CCS Slovenská

Darren

dpo@fleetcor.

Galvaniho 15/C

Fleet,

spoločnosť pre

Pascoe

sk

Bratislava –

CCS Bonus

platobné karty

Ružinov 821 04.

Plus,

s.r.o.

CCS Bonus,

CCS Carnet,

CCS Limit

Exclusive,

CCS Limit

Plus,

CCS Limit,

CCS Toll and

UTA/CCS card

Shell Card

FleetCor

Darren

dpo@fleetcor.

Galvaniho 15/C

Slovakia s.r.o.

Pascoe

sk

Bratislava –

Ružinov 821 04.

Switzerland

Shell card

Venturo

Darren

dsb@fleetcor.

c/o Silvia

Technologien

Pascoe

ch

Margraf

Swiss GmbH

Advokatur und

Notariat,

Industriestrasse

47, 6300 Zug.

United

1link Services

Epyx Limited

Darren

dpo@fleetcor.

Heath Farm

Kingdom

Pascoe

com

Hampton Lane,

Meriden,

Coventry, CV7

7LL.

Allstar

Allstar Business

Darren

dpo@fleetcor.

Allstar Business

Expense,

Solutions

Pascoe

com

Solutions

Allstar Monitor

Limited

Limited, PO

Allstar One,

BOX 1463,

Allstar Plus

Windmill Hill,

(Vehicle

Restricted)

Whitehill Way,

Allstar Plus

Swindon, SN5

Monitor,

6PS.

Allstar One,

Allstar Plus,

Allstar

Supermarket+,

Allstar

Prepaid,

Page 24 of 25

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Allstar Premier

Programme,

Allstar Classic,

Allstar

Supermarket

Allstar

The Fuelcard

Darren

dpo@fleetcor.

Unit 3 St James

Universal,

Company UK

Pascoe

com

Business Park,

Diesel

Limited

Grimbald Crag

Advance,

Court,

Esso

Knaresborough,

Commercial,

North Yorkshire,

Esso Multi,

Esso Single,

HG5 8QB.

Shell Fleet

List,

Shell Multi,

Shell CRT,

Shell Single

Texaco and

Fastfuel

Fuelvend,

C H Jones

Darren

dpo@fleetcor.

Unit 3 St James

Keyfuels and

Limited

Pascoe

com

Business Park,

MYFUEL

Grimbald Crag

Court,

Knaresborough,

North Yorkshire,

HG5 8QB.

R2C Services

R2C Online

Darren

dpo@fleetcor.

2 Vantage

Limited

Pascoe

com

Drive, Sheffield,

S9 1RG

If your country of residence has a data protection authority, you have a right to contact it with any questions or concerns. If we cannot resolve your questions or concerns, you also have the right to seek judicial remedy before a national court.

Updates to this privacy policy

We will update this policy from time to time to reflect changes in our business. We will inform you of these changes as required under applicable laws.

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