Privacy
Privacy Notice
This notice explains what information we collect when you enquire, apply or rent a vehicle, why we use it, and the rights you have over it.
This document is a draft prepared for legal review. It has not been reviewed or approved by a solicitor and should not be relied on until it has been.
Who controls your information
- Data controller
- LR Brands Ltd
- Trading name
- LR Vehicle Rentals
- Registered address
- 5 Brayford Square, London E1 0SG
- Privacy contact
- lrbrandsltd@gmail.com
- ICO registration number
- This information is being confirmed.
The controller is the business that decides how and why your information is used. Where a value above is still being confirmed, it will be published before the website is launched.
What information we collect
What we hold depends on how far your enquiry progresses. Not everything below applies to every person.
When you submit an initial application
- The vehicle you selected
- Your intended start date and expected rental duration
- Your intended use of the vehicle
- Full name
- Date of birth
- Home postcode
- Email address and telephone number, and your preferred contact method
- The country that issued your driving licence, and how long you have held it
- Declared claims or accidents in the last five years
- Anything else you choose to tell us in the additional information field
The application form does not ask for penalty points, convictions, your driving licence number, DVLA share code, passport number or National Insurance number, and it cannot accept file uploads.
If your application progresses
- Full address
- Driving licence details
- DVLA share code and the driving record it discloses
- Licence endorsements or convictions disclosed by that check
- Identity document
- Proof of address
- Insurance records
- Details of any additional driver
During a rental
- Signed agreements
- Payment and security deposit records
- Vehicle condition photographs and video
- Mileage, and fuel or charge level
- Collection and return records
- Incidents, accidents and insurance claims
- Damage assessments
- Fines, tolls and penalty notices
- Correspondence between us
- Recovery or seizure records
- Vehicle location recorded by the tracker fitted to the vehicle
How we collect it
- Directly from you, through the website forms, WhatsApp, email or telephone
- From the DVLA, when you provide a share code
- From insurers or brokers, when an insurance position is being arranged or verified
- From issuing authorities, when a fine, toll or penalty notice relates to a rental
- From repairers, recovery providers or third parties involved in an incident
Why we use it, and our proposed lawful basis
The table below sets out each purpose, what it involves and the lawful basis we propose to rely on. These are proposals prepared for legal review, not settled positions.
| Purpose | Information | Proposed lawful basis | Shared with | Retention |
|---|---|---|---|---|
| Assessing an initial rental application | Vehicle selected, intended dates and use, name, date of birth, postcode, contact details, licence country and duration | Proposed: steps taken at your request before entering a contract | Form processing and business email providers | 12 months from the date of application. |
| Contacting you about your application | Name, email, telephone, preferred contact method | Proposed: steps taken at your request before entering a contract | Messaging and email providers | 12 months from the date of application. |
| Declared claims history in the initial application | Declared claims or accidents in the last five years. The form does not ask about penalty points or convictions. | Proposed: steps taken at your request before entering a contract | Insurers or brokers where a quotation is required | 12 months from the date of application. |
| Identity, address and driving licence checks | Full address, driving licence, DVLA share code, driving record, identity document, proof of address | Proposed: performance of a contract. The driving record may disclose endorsements or convictions, which additionally requires a Data Protection Act 2018 condition. That condition has not yet been selected. | DVLA, insurers or brokers, document storage provider | Being confirmed |
| Arranging or verifying the insurance position | Driver details, driving history, intended use, additional driver details | Proposed: performance of a contract, and legitimate interests | Insurers, brokers | Being confirmed |
| Preparing and issuing the rental agreement | Applicant details, vehicle details, agreed commercial terms | Proposed: performance of a contract | Document signing provider | Being confirmed |
| Taking payment and handling the security deposit | Payment and deposit records, bank reference details | Proposed: performance of a contract, and compliance with legal obligations for financial records | Banks and payment providers | Being confirmed |
| Managing the rental, collection and return | Condition photographs and video, mileage, fuel or charge level, collection and return records | Proposed: performance of a contract | Storage provider, repairers where relevant | Being confirmed |
| Incidents, damage, recovery and insurance claims | Incident and accident records, damage assessments, claims information, recovery or seizure records | Proposed: performance of a contract, legitimate interests, and establishing or defending legal claims | Insurers, repairers, recovery providers, professional advisers, enforcement bodies | Being confirmed |
| Fines, tolls, penalty notices and enforcement correspondence | Notices received, driver details, rental period records | Proposed: compliance with legal obligations, and legitimate interests in recovering amounts due | Issuing authorities, enforcement bodies | Being confirmed |
| Vehicle tracking, theft recovery and immobilisation | Vehicle location while you have it, and the times it was recorded | Proposed: legitimate interests in protecting the vehicle and recovering it if stolen or not returned. The balancing assessment has not been completed. | Insurers, recovery providers, the police | Being confirmed |
| Handling complaints | Correspondence and the records relevant to the complaint | Proposed: legitimate interests, and compliance with legal obligations where applicable | Professional advisers where required | Being confirmed |
| Keeping the website and forms secure | Submission timing and a hidden anti-spam field. No analytics or advertising technology is used. | Proposed: legitimate interests in preventing misuse | Hosting provider | Being confirmed |
We do not rely on consent for the administration of an application or a rental. Consent would be the wrong basis, because you cannot meaningfully withdraw it partway through a contract we are both performing.
Driving convictions, endorsements and penalty points
Motoring convictions, endorsements and penalty points are criminal offence data. They are treated as a separate, more restricted category and are not held alongside ordinary application information.
The application form does not collect this category at all.
We do not ask you to declare penalty points or convictions when you apply. This information reaches us only later, and only if your application progresses, through the DVLA check you authorise with a share code.
Processing this category lawfully requires an Article 6 lawful basis and, in addition, a specific condition under the Data Protection Act 2018. It is also likely to require a documented policy and restricted access.
What is still being confirmed
- Proposed route, for legal confirmation
- Superseded. The insurance condition was proposed and not adopted; see dpaCondition below.
- Data Protection Act 2018 condition
- Data Protection Act 2018, Schedule 1, Part 2: paragraph 10 (preventing or detecting unlawful acts) and paragraph 14 (preventing fraud). Paired with UK GDPR Article 6(1)(b), because eligibility cannot be verified without it and the rental contract cannot be performed, and Article 6(1)(f) for our legitimate interests in protecting our fleet and meeting our insurer's terms.
- Appropriate policy document
- Version 1.1, 29 July 2026. Held by LR Brands Ltd and available to the Information Commissioner on request. Not yet approved by a solicitor.
- Who can access this information
- Access is restricted to the director. The licence record is viewed to complete the check and is never downloaded or copied.
- How long it is kept
- The share code and the licence record itself are not retained: the record is viewed to complete the check and is never downloaded or copied. We keep only whether the check was passed or not passed. That outcome is kept for 12 months from your application, or, where a rental follows, for the rental term and six years afterwards. Where an application is declined on licence grounds, a note of the reason is kept for 6 months from the decision.
International processing and access
Some providers we use operate outside the United Kingdom, or may access information from outside it. Where that happens, a transfer safeguard recognised under UK data protection law is required.
The specific providers, the countries involved and the safeguard relied on for each are being confirmed and will be listed here before the website is launched.
How long we keep it
We keep information only as long as we need it for the purpose it was collected for, or as long as the law requires.
- Applications generally
- 12 months from the date of application.
- Unsuccessful applications
- 6 months from the date we tell you the application was unsuccessful.
- Successful applications
- This information is being confirmed.
- Identification documents
- This information is being confirmed.
- Driving licence information
- This information is being confirmed.
- Criminal offence data
- The share code and the licence record itself are not retained: the record is viewed to complete the check and is never downloaded or copied. We keep only whether the check was passed or not passed. That outcome is kept for 12 months from your application, or, where a rental follows, for the rental term and six years afterwards. Where an application is declined on licence grounds, a note of the reason is kept for 6 months from the decision.
- Rental records
- This information is being confirmed.
- Financial records
- This information is being confirmed.
- Vehicle photographs and video
- This information is being confirmed.
- Incident records
- This information is being confirmed.
- Security logs
- This information is being confirmed.
How we protect it
The application form does not accept file uploads. Identification and licence documents are requested separately, after an application has been reviewed, so sensitive documents are never submitted through an open web form.
Our access controls, storage arrangements and retention enforcement are being documented and will be summarised here before launch.
Automated decision-making
The website does not score, rank or decide applications. It validates what you have entered and passes it to us to review.
Whether the wider review process involves any automated element is being confirmed. Until that check is complete, this notice does not state that decisions are made solely by a person.
Vehicle tracking and immobilisation
Every vehicle we rent has a tracker and a remote immobiliser fitted.
We tell you this before you rent, not afterwards. While you have the vehicle, the tracker records information about where it is. Because the vehicle is linked to you, that information is personal data about you.
Why they are fitted
- Locating and recovering a vehicle that is stolen
- Locating a vehicle that has not been returned when the rental has ended
- Protecting the vehicle, which is a substantial asset
- Supporting an insurance claim where the insurer requires it
We do not use it to monitor how you drive day to day, and we do not share your location with anyone except where we are recovering a vehicle, dealing with a claim, or required to by law or the police.
The immobiliser
The immobiliser can prevent the vehicle from being started. It is there for theft and for a vehicle that is being unlawfully retained after a rental has ended.
It is not used against a vehicle that is moving, and it is not used to pursue a payment dispute. If a payment is in arrears we contact you.
What is still being confirmed
- What the tracker records
- Vehicle location and speed.
- Our lawful basis for tracking
- Our legitimate interests in protecting our vehicles from theft and unlawful retention, and in meeting our obligations to our insurer.
- How long tracking data is kept
- This information is being confirmed.
Where we rely on legitimate interests for this, you have the right to object, and we must then show that our reasons outweigh the effect on you. Contact us using the details above.
Your rights
Under UK data protection law you have rights over your information. Depending on the circumstances and the lawful basis involved, these include:
- The right to be told what we hold and to get a copy of it
- The right to have inaccurate information corrected
- The right to ask us to delete information
- The right to ask us to restrict how we use it
- The right to object to processing based on legitimate interests
- The right to receive certain information in a portable format
- The right to withdraw consent, where we have relied on consent
Some rights do not apply where we are required to keep information by law, or where we need it to establish or defend a legal claim.
- How to exercise a right
- lrbrandsltd@gmail.com
Complaints about your information
If you are unhappy with how we have handled your information, please contact us first so we can try to put it right.
You also have the right to complain to the Information Commissioner's Office, the UK data protection regulator, at ico.org.uk. You can do that without contacting us first.
Changes to this notice
We may update this notice. Each version carries a version number and effective date, and we keep a record of previous versions.
- Version
- 1.0
- Effective date
- 29 July 2026