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PRIVACY POLICY


FLEETCOR EUROPE PRIVACY POLICY

This policy was lasted updated on 16 April 2021.

At Fleetcor Technologies, Inc., through our affiliates operating the Allstar,
epyx, Fleetcor, The Fuelcard Company, Keyfuels, r2c, Travelcard 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

 * 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 you 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 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.

 * 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 “Who should you
contact with questions?”.


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”.

To find out more please click here.


HOW DO 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 MAY WE 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.


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 Address

Postal Address

Austria

Shell Card

FleetCor Tankkarten GmbH

Darren Pascoe

dsb@fleetcor.at

Teinfaltstraße 8/4, 1010 Wien.

Belgium

Shell Card

FleetCor Belgium Sprl

Darren Pascoe

dpo@fleetcorcards.be

Avenue Du Port 86c/204, 1000 Bruxelles.

Belgium

Shell Card

FleetCor Belgium bvba

Darren Pascoe

dpo@fleetcorcards.be

Havenlaan 86c Bus 204, 1000 Brussel.

Czech Republic

Shell Card

FleetCor Czech Republic s.r.o.

Darren Pascoe

dpo@fleetcor.cz

Voctářova 2500/20a, 180 00 Praha 8 Chlumčanského 497/5, 180 00 Praha 8, Czechia.

Czech Republic

CCS Bonus Fleet, CCS Bonus Plus, CCS Bonus, CCS Carnet CCS Limit Exclusive, CCS
Limit Plus, CCS Limit, CCS Toll, UTA/CCS card.

CCS česká společnost pro platební karty s.r.o

Darren Pascoe

dpo@fleetcor.cz

Voctářova 2500/20a, 180 00 Praha 8 Chlumčanského 497/5, 180 00 Praha 8, Czechia.

Denmark

1link Services

epyx Limited

Darren Pascoe

dpo@fleetcor.com

Heath Farm Hampton Lane, Meriden, Coventry CV7 7LL.

France

1link Services

Epyx France SAS

Darren Pascoe

dpo@fleetcor.com

35 Allée des Impresssionistes, Le Cézanne,93420 Villepint.

France

Shell Card

Epyx France SAS

Darren Pascoe

dpo@fleetcor.fr

Le Cézanne, Paris Nord II.

Germany

Shell Card

FleetCor Deutschland GmbH

Darren Pascoe

dsb@fleetcor.de

Frankenstraße 150 c, 90461 Nürnberg.

Hungary

Shell Card

FleetCor Hungary Kft

Darren Pascoe

adatvedelem@fleetcor.hu

1062 Budapešť, Andrássy út 100.

Ireland

1link Services

epyx Limited

Darren Pascoe

dpo@fleetcor.com

Heath Farm Hampton Lane, Meriden, Coventry CV7 7LL.

Luxembourg

Shell Card

Venturo Technologies s.a.r.l.

Darren Pascoe

dpo@fleetcor.lu

15, rue Edward Steichen, 4th Floor, L-2540 Luxembourg

Netherlands

Shell Card

FleetCor Technologieёn B.V.

Darren Pascoe

dpo@fleetcor.nl

P.J. Oudweg 4, 1314CH Almere.

Netherlands

TravelCard

TravelCard B.V.

Darren Pascoe

dpo@fleetcor.com

P.J. Oudweg 4, 1314CH Almere.

Poland

Carnet, Shell Card Plus & Shell Card Plus Travel

FleetCor Poland sp. z.o.o.

Darren Pascoe

daneosobowe@fleetcor.pl

Generation Park Z ul. Towarowa 28 00-839 Warszawa Polska

Slovakia

CCS Bonus Fleet, CCS Bonus Plus, CCS Bonus, CCS Carnet. CCS Limit Exclusive, CCS
Limit Plus, CCS Limit, CCS Toll & UTA/CCS card

CCS Slovenská spoločnosť pre platobné karty s.r.o.

Darren Pascoe

dpo@fleetcor.sk

Galvaniho 15/C Bratislava - Ružinov 821 04.

Slovakia

Shell Card

FleetCor Slovakia s.r.o.

Darren Pascoe

dpo@fleetcor.sk

Galvaniho 15/C Bratislava - Ružinov 821 04.

Switzerland

Shell card

Venturo Technologien Swiss GmbH

Darren Pascoe

dsb@fleetcor.ch

Grafenaustrasse 5 6304 Zug.

United Kingdom

1link Services

Epyx Limited

Darren Pascoe

dpo@fleetcor.com

Heath Farm Hampton Lane, Meriden, Coventry, CV7 7LL.

United Kingdom

Allstar Expense, Allstar Monitor, Allstar One, Allstar Plus (Vehicle Restricted)
Allstar Plus Monitor, Allstar One, Allstar Plus, Allstar Supermarket+, Allstar
Prepaid, Allstar Plus, Allstar Premier Programme, Allstar Classic, Allstar
Supermarket and Allstar Supermarket+

Allstar Business Solutions Limited

Darren Pascoe

dpo@fleetcor.com

Allstar Business Solutions Limited, PO BOX 1463, Canberra House, Lydiard Fields,
Swindon, Wiltshire, SN5 6PS.

United Kingdom

Allstar Universal, Diesel Advance, Esso Commercial, Esso Commercial, Esso Multi,
Esso Single, Shell Fleet List, Shell Multi, Shell Multi, Shell CRT, Shell Single
Texaco and Fastfuel

The Fuelcard Company UK Limited

Darren Pascoe

dpo@fleetcor.com

Unit 3 St James Business Park, Grimbald Crag Court, Knaresborough, North
Yorkshire, HG5 8QB.

United Kingdom

Fuelvend, Keyfuels and MYFUEL

C H Jones Limited

Darren Pascoe

dpo@fleetcor.com

Unit 3 St James Business Park, Grimbald Crag Court, Knaresborough, North
Yorkshire, HG5 8QB.

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.

--------------------------------------------------------------------------------




FLEETCOR EUROPE PRIVACY POLICY (LONG FORM)

This policy was lasted updated on 1 May 2020.

At Fleetcor Technologies, Inc., through our affiliates operating the Allstar,
epyx, Fleetcor, The Fuelcard Company, Keyfuels, r2c, Travelcard and CCS brands,
and servicing the euroShell 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

 * 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 or 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 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

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
markets 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.

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 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.

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

- Initiate applications for accounts you request, notify you of the application
status or request additional information in relation to your application.

- Obtain know your client and credit information when you apply for a product or
subsequently.

Categories of data processed

- Contact information - Financial information - Know your client information

Legal basis It is in our legitimate business interests to process your personal
data as part of the customer application process.

Provide the services our customers have signed up for

- In order for our customers to receive the service(s).

Categories of data processed :

- Contact information - Financial information - 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

- We will use your contact information and unique fuel card identifiers to
process fuel card payments when you purchase fuel.

- We will keep a record of your transaction history information relating to your
card in order to calculate the fees owed to us by you and/or your employer and
provide them with evidence of the transactions.

Categories of data processed :

- Contact information - Financial information - Transaction history

Legal basis It is our legitimate business interest to provide the fuel card
services that we are contracted to perform in our contract with our customers.

Administer our customer’s online accounts

- Allow us to authenticate your user credentials when you login to your online
account.

- Respond to enquiries you may make in relation to your account.

- Allow you to access certain information about your account with us, such as
your transaction history.

Categories of data processed:

- Contact information - Login details - Transaction history

Legal basis It is in our legitimate interests to administer and manage the
account of our customer as provided for under our contract with our customer.

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

- Review and monitor your transaction history to identify any potential fraud,
money laundering or other unlawful behavior in relation to your account.

- Carry out know your client and sanctions 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.

Categories of data processed :

- Contact information - Transaction history - Financial information - Know your
client information

Legal basis It is necessary for compliance with legal obligations to which we
are subject to.

Provide you with information about our products and services

- If you have requested to receive such information from us, then we may contact
you from time to time by email, post, telephone and/or SMS about our products
and services and any products and services of third parties.

Categories of data processed:

- Contact information - Transaction history

Legal basis We will only send you information about our products and services if
you have consented to receiving them or based on our legitimate interests (where
we are permitted to do so under applicable law).

Allow you to participate in interactive features

- If you interact with the “chat” function on our websites.

- If you interact with us via our Facebook, Twitter or Linked In accounts.

Categories of data processed :

- Contact information - Information about your characteristics and preferences

Legal basis 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, products and services

- Recording of telephone calls and online chats that we have with you for
training or quality assurances.

- Monitor the use of and improve our interactive assets.

- Perform data analyses (including anonymisation) of your data.

Categories of data processed:

- Contact information - Transaction history - Content you provide to us -
Technical information about your device and website usage - Information about
your characteristics and preferences

Legal basis It is our legitimate business interest to review and improve our
business, products and 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

- See the section entitled “Data we share and receive” for more information.

Categories of data processed :

- All personal data we hold about you

Legal basis 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 notice. In the case of
third party marketing we only share your personal data if you have provided
consent.

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

- To audit compliance with our legal obligations including regulatory
requirements.

Categories of data processed :

- All personal data we hold about you

Legal basis It is necessary for compliance with legal obligations to which we
are subject.

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

- To provide contract updates and service(s) updates

Categories of data processed :

- All personal data we hold about you

Legal basis It is in our legitimate business interests and 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

- We may keep records of your data, such as your transactions for evidential
purposes in order to defend ourselves against or issue one or more future legal
claims.

Categories of data processed :

- Contact information - Login details - Content you provide to us - 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 you 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 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 personal 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”.

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 DO 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 MAY WE 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 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 hold

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

To request us to give you access to it

This is confirmation of:

- whether or not we process data about you; - our name and contact details; -
purpose of the processing; - categories of data concerned; - the categories of
persons with whom we share the data and, where 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
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 or update it

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

To request us to erase 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 again,
unless you tell us you want us to delete all personal data 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.

To request us to restrict our processing of it

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 legitimate interests

(if you make use of your right in these cases, we will tell you before we use
the data again). 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.

To object to our processing it

You have two rights here:

- if we use data about you for direct marketing: you can “opt out” (without the
need to justify it) and we will comply with your request; and - 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 consent to our using it

This right applies to any data which we have collected and process based on your
consent. You have the right at any time to withdraw the consent you have
provided to us.

To data portability

This right applies: (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. 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 with the supervisory authority in your country

Each European Union country must provide for one or more public authorities for
this purpose. You can find their contact details here:
http://ec.europa.eu/justice/data-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 Address

Postal Address

Austria

Shell Card

FleetCor Tankkarten GmbH

Darren Pascoe

dsb@fleetcor.at

Teinfaltstraße 8/4, 1010 Wien.

Belgium

Shell Card

FleetCor Belgium Sprl

Darren Pascoe

dpo@fleetcorcards.be

Avenue Du Port 86c/204, 1000 Bruxelles.

Belgium

Shell Card

FleetCor Belgium bvba

Darren Pascoe

dpo@fleetcorcards.be

Havenlaan 86c Bus 204, 1000 Brussel.

Czech Republic

Shell Card

FleetCor Czech Republic s.r.o.

Darren Pascoe

dpo@fleetcor.cz

Voctářova 2500/20a, 180 00 Praha 8 Chlumčanského 497/5, 180 00 Praha 8, Czechia.

Czech Republic

CCS Bonus Fleet, CCS Bonus Plus, CCS Bonus, CCS Carnet CCS Limit Exclusive, CCS
Limit Plus, CCS Limit, CCS Toll, UTA/CCS card.

CCS česká společnost pro platební karty s.r.o

Darren Pascoe

dpo@fleetcor.cz

Voctářova 2500/20a, 180 00 Praha 8 Chlumčanského 497/5, 180 00 Praha 8, Czechia.

Denmark

1link Services

epyx Limited

Darren Pascoe

dpo@fleetcor.com

Heath Farm Hampton Lane, Meriden, Coventry CV7 7LL.

France

1link Services

Epyx France SAS

Darren Pascoe

dpo@fleetcor.com

35 Allée des Impresssionistes, Le Cézanne,93420 Villepint.

France

Shell Card

Epyx France SAS

Darren Pascoe

dpo@fleetcor.fr

Le Cézanne, Paris Nord II.

Germany

Shell Card

FleetCor Deutschland GmbH

Darren Pascoe

dsb@fleetcor.de

Frankenstraße 150 c, 90461 Nürnberg.

Hungary

Shell Card

FleetCor Hungary Kft

Darren Pascoe

adatvedelem@fleetcor.hu

1062 Budapešť, Andrássy út 100.

Ireland

1link Services

epyx Limited

Darren Pascoe

dpo@fleetcor.com

Heath Farm Hampton Lane, Meriden, Coventry CV7 7LL.

Luxembourg

Shell Card

Venturo Technologies s.a.r.l.

Darren Pascoe

dpo@fleetcor.lu

15, rue Edward Steichen, 4th Floor, L-2540 Luxembourg

Netherlands

Shell Card

FleetCor Technologieёn B.V.

Darren Pascoe

dpo@fleetcor.nl

P.J. Oudweg 4, 1314CH Almere.

Netherlands

TravelCard

TravelCard B.V.

Darren Pascoe

dpo@fleetcor.com

P.J. Oudweg 4, 1314CH Almere.

Poland

Carnet, Shell Card Plus & Shell Card Plus Travel

FleetCor Poland sp. z.o.o.

Darren Pascoe

daneosobowe@fleetcor.pl

Generation Park Z ul. Towarowa 28 00-839 Warszawa Polska

Slovakia

CCS Bonus Fleet, CCS Bonus Plus, CCS Bonus, CCS Carnet. CCS Limit Exclusive, CCS
Limit Plus, CCS Limit, CCS Toll & UTA/CCS card

CCS Slovenská spoločnosť pre platobné karty s.r.o.

Darren Pascoe

dpo@fleetcor.sk

Galvaniho 15/C Bratislava - Ružinov 821 04.

Slovakia

Shell Card

FleetCor Slovakia s.r.o.

Darren Pascoe

dpo@fleetcor.sk

Galvaniho 15/C Bratislava - Ružinov 821 04.

Switzerland

Shell card

Venturo Technologien Swiss GmbH

Darren Pascoe

dsb@fleetcor.ch

Grafenaustrasse 5 6304 Zug.

United Kingdom

1link Services

Epyx Limited

Darren Pascoe

dpo@fleetcor.com

Heath Farm Hampton Lane, Meriden, Coventry, CV7 7LL.

United Kingdom

Allstar Expense, Allstar Monitor, Allstar One, Allstar Plus (Vehicle Restricted)
Allstar Plus Monitor, Allstar One, Allstar Plus, Allstar Supermarket+, Allstar
Prepaid, Allstar Plus, Allstar Premier Programme, Allstar Classic, Allstar
Supermarket and Allstar Supermarket+

Allstar Business Solutions Limited

Darren Pascoe

dpo@fleetcor.com

Allstar Business Solutions Limited, PO BOX 1463, Canberra House, Lydiard Fields,
Swindon, Wiltshire, SN5 6PS.

United Kingdom

Allstar Universal, Diesel Advance, Esso Commercial, Esso Commercial, Esso Multi,
Esso Single, Shell Fleet List, Shell Multi, Shell Multi, Shell CRT, Shell Single
Texaco and Fastfuel

The Fuelcard Company UK Limited

Darren Pascoe

dpo@fleetcor.com

Unit 3 St James Business Park, Grimbald Crag Court, Knaresborough, North
Yorkshire, HG5 8QB.

United Kingdom

Fuelvend, Keyfuels and MYFUEL

C H Jones Limited

Darren Pascoe

dpo@fleetcor.com

Unit 3 St James Business Park, Grimbald Crag Court, Knaresborough, North
Yorkshire, HG5 8QB.

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.

We have been serving businesses large and small for over 40 years. We have the
UK’s largest combined fuel and electric charging network, savings on diesel and
our online platform will help reduce your costs and admin.

Apply online now

or call 0370 419 5101



Want to get started but not sure how? Speak to one of our experienced team! Give
us a call on 0370 419 5101 or we can call you back Monday to Friday 9am —
5:15pm.

Request a callback

or call 0370 419 5101



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Allstar Business Solutions Limited, Post Office Box 1463, Canberra House,
Lydiard Fields, Swindon, Wiltshire, SN5 6PS, Registration Number 2631112 GB.

Allstar Business Solutions Limited is authorised by the Financial Conduct
Authority under the Electronic Money Regulations 2011 (register reference
900470) for the issuing of electronic money and the provision of payment
services. Allstar cards bearing the Visa symbol are payment instruments
regulated by the Financial Conduct Authority. All other cards issued by us are
not regulated by the Financial Conduct Authority and not subject to the rights
under the Payment Services Regulations 2017. Company Registration No.2631112.
Registered in England. VAT Registration GB747880191.

COPYRIGHT © 2023 ALLSTAR BUSINESS SOLUTIONS LIMITED.




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