Global Privacy Policy

CSI Leasing Inc.

Global Privacy Policy

Effective date: July 3, 2018

Revision date: June 17, 2021

Purpose: In the course of our business activities, CSI must collect and process personal data of its customers, potential customers, suppliers, business associates, and employees. This policy, which is posted on CSI’s website, describes how and why we process personal data and the measures we take to protect the privacy of the data subjects and remain compliant with relevant data protection laws.

Scope: This policy applies to all employees CSI Leasing, Inc., and its subsidiaries worldwide.

Policy:

Introduction

Your privacy is important to CSI Leasing, Inc., and its global affiliates (collectively “CSI” or “we” or “our”). This Policy explains what Personal Data we collect from you, why we collect and process your Personal Data, when and with whom your Personal Data is shared, and your rights with respect to your Personal Data.

In this Policy the term “Personal Data” means data that identifies or may be used to identify an individual person, including, but not limited to, a person’s name, date of birth, job title, address, email, phone number, or employer.

In order to provide outstanding service, we must collect, maintain and process certain Personal Data about our customers, suppliers and other business contacts. We recognize and respect your privacy concerns and expectations about how we use this information. We want you to know about our privacy policies and practices, and what we do to protect your Personal Data.

Personal Data We Collect on our Website

In general, you can visit CSI websites without telling us who you are and without giving any Personal Data about yourself. There are times, however, when we may need information from you. When you select the “Contact CSI” button, we will ask you to read and agree to this Privacy Policy before you submit your Personal Data to us.

If you apply for a job through our websites, we may collect and process Personal Data you submit to us such as name, address, references, and employment history in order to evaluate your qualifications for a job and contact your references. We will retain your information until the position is filled and for up to six months after the position is filled in case other positions become available.

In all cases in which you submit personal information to us, you may tell us that you do not want us to use this information to make further contact with you beyond fulfilling your requests, and we will respect your wishes. If you give us personal information about someone else, such as a spouse, a reference, or a work colleague, we will assume that you have that person’s permission to do so. In any case, we will only retain your Personal Data for as long as we have a legitimate and lawful reason to do so.

When you visit our websites, CSI may collect certain non-Personal Data by various means, one of which is “cookies.” Cookies tell website operators to recognize your computer when you revisit a site. Cookies help to improve the use of the website. Cookies also allow Web sites to analyze aggregate traffic on the site, in order to streamline navigation and keep the content fresh for all visitors. You can configure your browser to reject cookies. When you visit our websites, you will be prompted to either accept all cookies or accept only those cookies that are necessary to operate the website. The cookies we use do not contain Personal Data, nor can they read or transmit any data on your computer’s hard drive. We do not use cookies to identify or track a user’s activity outside of our websites. Regardless of cookies, all web-browsers transmit the IP address of the computer on which they are running. For most users accessing our websites from an Internet Service Provider (ISP), the IP address will be different every time you log on. IP addresses may be used for various purposes, including to: (1) diagnose service or technology problems reported by our users or engineers that are associated with the IP addresses controlled by a specific Web company or ISP, (2) develop the most appropriate advertising based on geographic area or information derived from IP addresses, (3) estimate the total number of users visiting CSI from specific countries or regions of the world, (4) assist CSI to track visits to our Web site, and (5) help determine which users have access privileges to certain CSI Web site content.

Personal Data We Collect from Customers and Suppliers

In order to carry out our business and to fulfill our contractual obligations, CSI must collect and process Personal Data of employees of prospective and existing customers or suppliers. Examples of the types of Personal Data that CSI may collect from its customers, suppliers and other business contacts are:

Name, title, address, email, and telephone number
Proof of address such as copies of utility bills
Copies of passports or other government issued identification
Tax identification numbers
Signatures on legal contracts
Payment information
Financial statements or other financial information

Why We Collect Personal Data

CSI only collects Personal Data for lawful purposes. These include:

To provide customers with our products or services
To facilitate the approval of transactions
To obtain financing in connection with our products or services
To provide information on leasing, equipment finance or IT disposal.
To respond to requests from the customer, financier, or supplier
To detect or prevent fraud
To assess or manage risk
To perform internal audits
To comply with anti-terrorism, anti-bribery, or anti-money laundering laws or other laws
To comply with legal process, subpoenas, or other requests from government bodies
As part of a sale, merger, acquisition, or similar change of control
To ensure data security

Specific Rights regarding Personal Data of European Citizens

If you are a citizen of Europe residing within the European Economic Area, you may have the following rights under the General Data Protection Regulation:

to be informed of this Policy and how CSI uses and processes your Personal Data;
to request a copy of the Personal Data we have collected;
to request that we correct any Personal Data that is inaccurate or incomplete;
to request that we delete or transfer to your possession such Personal Data which we no longer have lawful reason to keep;
to object to the processing of your Personal Data and to lodge a complaint with the relevant data protection authority.

Specific Rights regarding Personal Data of Residents of California

If you are a resident of the state of California you may have the following rights under the California Consumer Privacy Act “CCPA”:

to be informed of your rights under the CCPA and how CSI uses and processes your Personal Data;
to request a copy of the Personal Data we have collected;
to request disclosure of Personal Data processed for a business purpose;
to request that we delete or transfer to your possession such Personal Data which we no longer have lawful reason to keep;
and to be free of discrimination for exercising your rights under the CCPA.

Our Data Protection Principles:

CSI will treat your Personal Data as confidential. We respect your right to privacy. In all cases in which we collect your Personal Data according to this Policy, we will abide by the following principles:

We will only collect your Personal Data with your full knowledge
We will only collect and keep your Personal Data for a lawful purpose
We will only keep that Personal Data which is necessary for the lawful purpose
We will only keep your Personal Data for as long as the lawful purpose exists
We will keep your Personal Data accurate to the extent it is reasonably practicable to do so
We will store your Personal Data securely to prevent unauthorized or unnecessary disclosure
We will process your Personal Data in accordance with your rights under the relevant data protection laws
We will not transfer your Personal Data outside of its country of origin unless adequate protections are in place

Transfer or Sharing of Your Personal Data

Subject to the above Data Protection Principles and the terms of any valid and fully-executed non-disclosure agreement, CSI may transfer or share your personal data in the following circumstances:

Among our affiliates and wholly-owned subsidiaries, including our sole shareholder, Tokyo Century Corporation for the lawful purposes described in this Policy;
To third parties such as our banks, financiers, couriers and suppliers in order to deliver our services or to fulfill or enforce a contract;
To our attorneys, auditors, IT professionals or other third party service providers for the lawful purposes described in this Policy;
To government, regulatory, judicial or law enforcement bodies in response to official requests.

CSI may also utilize cloud based customer relationship management or IT service providers to store and process personal data. In all cases, CSI will take reasonable steps to ensure that adequate technical and organizational measures are in place so that the transfer and storage of your Personal Data is secure from unauthorized disclosure, alteration or deletion. CSI Leasing, Inc. has self-certified under the US-EU Privacy Shield Program. We have agreed to comply with the Privacy Shield Framework set forth by the US Department of Commerce with regard to the transfer of Personal Data of citizens of the European Union to the United States. Our Privacy Shield Policy can be found on our website. To learn more about the Privacy Shield Program and to view CSI’s certification, please visit https://www.privacyshield.gov.

CSI does not sell, rent, or disclose your Personal Data to third parties for their own marketing purposes.

Data protection provisions about the application and use of LinkedIn

Our site contains a link to the LinkedIn© network. The service is provided by LinkedIn Corporation, 100 West Maude Avenue, Sunnyvale, CA 94085, USA. Each time you click on the LinkedIn icon on our site, your browser establishes a direct connection to the LinkedIn© servers. LinkedIn is informed that you have visited our site from your IP address. If you use the LinkedIn© “Recommend” button and are logged into your LinkedIn© account, it is possible for LinkedIn© to associate your visit to our site to your LinkedIn© user account. CSI has no knowledge of the content of the data transmitted or how it will be used by LinkedIn©. More information can be found in the LinkedIn© privacy policy at https://www.linkedin.com/legal/privacy-policy.

Case Studies

CSI websites may contain “case studies” describing scenarios when CSI customers benefited from CSI’s services and expertise. Because no two customers are alike, these case studies should only serve as examples of other customers’ experiences, and thus may differ from your experience.

Anti-Spam Policy

CSI does not tolerate spam and is committed to proper Web practices and full compliance with the CANSPAM Act of 2003 (15 U.S.C. §7701.) We do not sell or rent e-mail addresses to any unauthorized third party. This does not mean that we can prevent all spam from happening on the internet. If you believe that you have received an unsolicited e-mail from us, please contact CSI at privacy@csileasing.com and we will investigate.

Children

CSI websites are not intended for visitors under 18 years of age. We do not knowingly solicit or collect personal data from or about children, nor do we knowingly market our products or services to children.

Notices and Revisions

CSI may revise this privacy policy from time to time. You should periodically check the revision date at the top of this Web page to learn of any revisions.

Contact CSI Leasing

To “opt out” or make other choices about your Personal Data or to exercise your rights, please email privacy@csileasing.com.

In the European Union, please contact:

Data Protection Officer

CSI LifeCycle Leasing GmbH

Martin-Behaim-Strasse 22

63263 Neu-Isenburg

Germany

Datenschutz@csilifecycle.de

In the United Kingdom, please contact:

Data Protection Officer

CSI Leasing (UK) Limited

1-2 Chambers Way, Newton Chambers

Thorncliffe Park

Chapeltown

Sheffield, S352PH

United Kingdom

Sarah.Wright@csirenting.com