Privacy Policy

1. Scope of This Policy

This policy covers information that INGRAM JUNIPER, LLC collects through its website, through email and telephone correspondence, and through the administration of lease engagements. It also covers information that a client organisation supplies to the firm so that lease schedules, asset ledgers and compliance files can be prepared and maintained.

This policy does not cover the practices of third parties. Where a lease is funded by a lender or arranged through a dealer, the privacy practices of that lender or dealer are governed by their own notices. The firm encourages clients to read those notices carefully before signing any financing agreement. Similarly, software platforms that a client chooses to run may process information under their own terms, and this policy does not extend to those systems.

2. Information We Collect

The information the firm collects falls into four broad groups: contact information, engagement and lease information, technical information generated by website visits, and correspondence. The precise mix depends on how a person interacts with the firm. A visitor who only reads the website provides far less information than a client whose lease portfolio is under administration.

The firm collects information that is necessary for the purposes described in this policy. It does not seek information that is irrelevant to lease administration, and it asks clients to avoid sending sensitive personal information that is not needed for the work at hand.

• Contact details such as name, organisation, postal address, email address and telephone number.
• Engagement details such as the asset types involved, term length, payment schedule and renewal dates.
• Business information needed for credit and compliance review, such as entity name and registration details.
• Technical information such as browser type, device category and pages viewed on the website.
• Correspondence content, including emails, messages sent through the contact form and notes of telephone calls.

3. Information You Provide Directly

Most of the information the firm holds arrives directly from the person or organisation that contacts it. When a person sends an enquiry through the contact form, the firm receives the name, email address, subject and message content entered into that form. Because the form hands the message to a local email client rather than storing it on a server, the information reaches the firm as ordinary email.

When an engagement begins, clients supply lease documents, asset lists, insurance certificates and similar records. That material is needed to build the register, draft schedules and satisfy the review standards of funding partners. Clients decide what to send, and the firm asks for the smallest set of documents that will support the work. Where a client sends more than is needed, the firm stores it with the rest of the engagement file and applies the same safeguards to all of it.

4. Information Collected Automatically

The website is built as a set of static pages and does not run advertising trackers or behavioural profiling scripts. When a browser requests a page, the hosting infrastructure may record technical details such as the requested address, the time of the request, the referring page and a coarse indication of network origin. These records are used to keep the site available and to detect abuse.

The firm does not attempt to identify individual visitors from technical records. It does not combine technical records with lease files, and it does not sell or rent technical information. Where analytics are introduced in future, this policy will be updated before those tools are activated, and any change will be described in plain language.

5. Business and Lease Programme Data

Lease administration depends on records that describe equipment, schedules and events. Those records may include the make and model of an asset, its purchase or lease value, its deployment location, its service history, the identity of its operator, and the dates of payments, inspections and renewals. Some of this information relates to a business rather than to a person, but some of it may identify an individual, such as a driver assigned to a vehicle or a manager who signs a delivery receipt.

The firm treats all lease programme data as confidential business information. It is used to administer the programme, to prepare notices and reviews, and to respond to the reasonable requests of the client, the lender and any auditor the client authorises. It is not used for marketing, and it is not disclosed to unrelated parties. Where tracking or telemetry data is collected, it is tied to the asset and to the administration of the lease, not to surveillance of individuals.

6. How We Use Information

Information is used for a limited set of purposes that are set out below. Each purpose is connected to the services the firm provides, and each is carried out with the minimum amount of information needed.

• Responding to enquiries and preparing proposals or scopes of work.
• Building and maintaining lease registers, schedules and asset ledgers.
• Issuing renewal, extension, buyout and return notices before their deadlines.
• Preparing credit packages and supporting compliance and insurance review.
• Administering payments, accruals and reconciliations in coordination with the client.
• Maintaining the security, integrity and availability of the website and files.
• Meeting legal, tax, accounting and record keeping obligations.
• Improving the clarity of templates, forms and client communications.

7. Legal Bases for Processing

Where applicable law requires a legal basis for processing, the firm relies on one or more of the following. Performance of a contract covers processing needed to deliver lease administration under an engagement. Legitimate interests cover processing needed to run and improve a professional practice, provided those interests are not outweighed by the rights of the individual. Legal obligation covers processing required by tax, accounting or regulatory rules. Consent covers any processing that is optional, such as a voluntary newsletter, and consent may be withdrawn at any time.

Where a client provides information about its own employees or contractors, the client is responsible for having a lawful basis to share that information with the firm. The firm processes such information only as needed to administer the lease programme and only on the instructions of the client.

8. When We Share Information

The firm does not sell personal information. It does not trade it, rent it or exchange it for advertising. Information is shared only in the limited circumstances described in this policy and only to the extent required.

• With the client organisation whose programme is under administration.
• With lenders, lessors and funding partners when the client has authorised the engagement.
• With insurers, auditors and advisers when needed for a review the client has requested.
• With service providers who support the firm under confidentiality obligations.
• With authorities where the law requires disclosure or where rights must be protected.

Where information is shared with a lender or funding partner, the disclosure is limited to what that party needs to evaluate or administer the financing. Where a client asks the firm to share a file with a successor administrator, the file is transferred intact and the client is informed.

9. Service Providers and Vendors

The firm relies on a small number of service providers for functions such as website hosting, email delivery and document storage. These providers receive only the information necessary to perform their function, and they are expected to protect it and to use it only for the service they provide to the firm.

Providers are selected with care. The firm favours providers that offer clear security commitments and that do not repurpose client information for their own marketing. Where a provider is replaced, the firm takes reasonable steps to ensure that information held by the outgoing provider is returned or destroyed and that the incoming provider receives only what is required to continue the service.

10. Lessors, Lenders and Funding Partners

Lease administration sits between a lessee and the parties that fund an agreement. To do that work, the firm must exchange information with lessors, lenders and funding partners. That exchange is limited to the lease, the asset and the compliance facts that support it. The firm does not pass marketing lists to those parties, and it does not permit them to use client information for purposes unrelated to the financing.

A lessee should understand that a lender holds its own record of the financing and applies its own privacy notice. The firm cannot control how a lender handles information after it is received, and it encourages clients to raise questions about lender practices directly with the lender.

11. How Long We Keep Information

Lease records are kept for as long as the programme is active and for a further period after it ends. The length of that further period is set by tax, accounting and contractual requirements, and it reflects the possibility that a lease may be reviewed, audited or disputed years after its final payment. As a general practice, engagement files are retained for the period required by applicable law and then securely destroyed.

Enquiries that do not lead to an engagement are kept only as long as needed to answer the enquiry and to maintain a record of the contact, after which they are removed. Technical records generated by website visits are kept for a short period for security and diagnostic purposes and then discarded or aggregated so that they no longer identify a visit.

12. How We Protect Information

The firm applies administrative, technical and physical safeguards to the information it holds. Access is limited to people who need it to perform the work. Files are stored in controlled locations, transmitted over encrypted connections where available, and protected by access controls on the devices and accounts that reach them.

No method of storage or transmission is perfectly secure, and the firm cannot promise absolute protection. It can promise that it takes security seriously, that it reviews its practices, and that it will notify affected parties and the relevant authorities where a breach occurs and notification is required by law. Clients can help by sending only the documents that are requested, by using secure channels for sensitive material, and by reporting anything that looks unusual to leasing@ingramjuniper.lat.

13. Cookies and Similar Technologies

The website is designed to work without advertising cookies. It may set a strictly necessary cookie or use local browser storage for basic functions such as remembering a navigation state during a visit. These do not track a visitor across other websites, and they are not used to build a profile.

A visitor may block or delete cookies through browser settings. Blocking strictly necessary storage may affect a small number of interface behaviours, but the content of every page remains readable without it. The firm does not use pixel tags, fingerprinting scripts or third party advertising networks on this site.

14. Your Privacy Choices and Rights

Depending on where a person lives, they may have rights regarding the information the firm holds about them. Those rights can include the right to know what is held, the right to request a copy, the right to ask for correction, the right to ask for deletion, the right to restrict certain processing, and the right to object to processing based on legitimate interests.

The firm honours these requests to the extent the law requires and to the extent the request does not conflict with a legal or contractual obligation to retain a lease record. Where a request concerns information that belongs to a client organisation, the firm may direct the request to that organisation, because the client controls the purpose of the processing. A request may be made by email to leasing@ingramjuniper.lat or by telephone at +13255504640.

15. Access, Correction and Deletion

A person who wishes to see, correct or remove information held by the firm should write to the leasing address with enough detail to identify the record. The firm may ask for proof of identity before acting, so that information is not released to the wrong party. Once identity is confirmed, the firm will respond within the time allowed by applicable law.

Where a request cannot be granted in full, the firm will explain why. Common reasons include a legal retention requirement, an active audit, or the fact that the record belongs to a client organisation and must be handled through that organisation. Where part of a request can be granted, the firm will grant that part. Corrections are recorded in a way that preserves the integrity of the underlying lease file.

16. Privacy for Children

The services of INGRAM JUNIPER, LLC are business services intended for organisations and their representatives. The website is not directed to children, and the firm does not knowingly collect personal information from children. If the firm learns that it has received information from a child without appropriate consent, it will delete that information promptly.

A parent or guardian who believes that a child has provided information to the firm should contact the leasing address so that the matter can be investigated and, where appropriate, the information removed. The firm does not market to children and does not design any part of its services for use by children.

17. Notice for California Residents

Residents of California may have additional rights under state privacy law. Those rights can include the right to know the categories of information collected and the purposes for which it is used, the right to request deletion, the right to correct inaccurate information, and the right not to be discriminated against for exercising a privacy right.

The firm does not sell personal information and has not sold it in the past. It does not share personal information for cross context behavioural advertising. Where a California resident wishes to exercise a right, the request may be sent to leasing@ingramjuniper.lat or made by telephone at +13255504640. The firm will verify the request and respond as required by law, and it will not charge a fee for a reasonable request.

18. International Data Transfers

The firm operates from the United States, and the information it holds is generally stored and processed there. Where a client or a vendor is located in another country, information may cross a border as part of the work. Where that happens, the firm takes reasonable steps to ensure that the information continues to receive protections consistent with this policy and with applicable law.

A person who contacts the firm from outside the United States should be aware that their information will be handled under United States law and under this policy. Questions about cross border handling may be directed to the leasing address, and the firm will explain the practical arrangements that apply to a given engagement.

19. Changes to This Policy

This policy may be updated to reflect changes in the services, in the law or in the way the firm operates. When a material change is made, the firm will revise the effective date and, where appropriate, provide notice through the website or by email to active clients. Continued use of the website or continued engagement after a change takes effect indicates acceptance of the revised policy.

The firm keeps prior versions of this policy so that a reader can understand what applied at an earlier time. A request for a prior version may be made to the leasing address. The firm encourages clients to review this page periodically, particularly before beginning a new engagement or renewing an existing programme.

20. How to Contact the Firm

Questions, requests and concerns about privacy may be sent to INGRAM JUNIPER, LLC at the following details. The firm aims to acknowledge every privacy enquiry promptly and to resolve it within the period required by applicable law.

If a person is not satisfied with the response to a privacy concern, they may have the right to complain to a supervisory authority in their jurisdiction. The firm would appreciate the opportunity to address the concern directly before any external step is taken.