Your privacy is important to us.
We respect your privacy and are committed to protecting your personal data. Personal data refers to any information or expression of opinion that may allow an individual to be identified, for example, their name, address, gender etc. The term data refers to any digital, automated data or manual information gathered by a company. We have put together the following guidelines to let you know how we hold and use the personal information you may provide to us directly or through our website.
The information we collect
We collect information about you when you engage with us either through the telephone, our website, other digital platforms or our partners. Some of this information does not identify you personally, but provides us with information about how you use our services and engage with us (we use this information to improve our services and make them more useful to you). The information we collect includes one of the following:
- Your personal details, including name, date of birth, address, employment and contact details
- Your banking and financial information where you have provided this including income, expenditure and previous credit history)
- Information about your lifestyle and home ownership
- Identifiers assigned to your computer or other devices, including your Internet Protocol (IP) address
- Cookie Information (see our Cookie Policy)
- Details of communication between us (for example emails and call recordings)
- Any other information which you may provide to us
How we use this information and the legal basis for processing
We will only process information that is necessary for the purpose for which it has been collected. The legal basis of processing will vary depending on the type of service you have requested, and we have listed some examples of our processing activities below:
- Administering your vehicle quotes and policies (as is necessary for performance of a contract between you and us and/or as is necessary for our legitimate interests).
- Carrying our anti-fraud and anti-money laundering checks and verifying your identity (as is necessary for compliance with our legal obligations and/or as is necessary for our legitimate interests).
- Assessing financial risks, including carrying out credit reference checks and credit scoring assessments, (as is necessary for the performance of a contract between you and us and/or as is necessary for our legitimate interests).
- Brokering your finance agreement and any related services (as is necessary for the performance of a contract between you and us and /or as is necessary for our legitimate interests.
- Using your payment details to process payments or refunds relating to a service provided by us (as is necessary for the performance of a contract between you and us and/or is necessary for our legitimate interests).
- Sending you information about your end of contract obligations and how to renew your vehicle hire agreement (as is necessary for compliance within our legal obligations)
- Communicating with you about your quotes and policies including responding to your enquiries (as is necessary for the performance of a contract between you and us and/or is necessary for our legitimate interests).
- Administering debt recoveries, where you owe us money under a contract or otherwise (as is necessary for the performance of a contract between you and us and/or is necessary for our legitimate interests).
- Undertaking market research and statistical analysis, including analysing your use of our website. This allows us to develop new, or improve existing products and services (as is necessary for our legitimate interests); and
- Fulfilling our obligations owed to a relevant regulator or authority (as is necessary for the performance of a contract between you and us and/or is necessary for our legitimate interests).
Our “legitimate interests” as referred to in this document include our legitimate business purposes and commercial interests in operating our business in a customer focussed, efficient and sustainable manner, in accordance with all applicable and regulatory requirements.
We will never make automated decisions when processing your data, nor will we use profiling techniques.
How do we share this information?
We do not sell your information to third parties, but we do work closely with third party suppliers who fulfil business activities for us. In these situations, we will only share the information that is necessary for the third party to perform the processing activity it was provided for, such as;
- Third party service providers who support the operation of our business, such as IT and Marketing suppliers, financial service providers, delivery companies, dealer groups and debt collection agencies (as is necessary for the performance of a contract between you and us and/or as is necessary for our legitimate interests).
- Third party insurance providers (as is necessary for the performance of a contract between you and us and/or as is necessary for our legitimate interests).
- Fraud prevention agencies and associations, (as is necessary for compliance with our legal obligations and/or as is necessary for our legitimate interests).
- Regulators and law enforcement agencies, including the police, the Financial Conduct Authority or any relevant authority who may have jurisdiction (as is necessary for compliance with our legal obligations.
Some of these third parties may also be considered a data controller in respect of holding your personal data. In these cases, we will provide you with the privacy statements of those parties.
How long do we keep your information for?
We will not hold your personal information for any longer than is necessary. If you are a customer or otherwise have a relationship with us we will hold personal information about you for a longer period than if we have obtained your details in connection with a prospective relationship. In any event, the retention period will be the statutory retention period unless there is a further legal or regulatory requirement to do so.
How can you manage the information we hold about you?
Under the data protection act you have certain rights in relation to the data we hold about you. Under GDPR these rights are extended and listed below:
- to obtain access to, and copies of the personal information we hold about you;
- to require that we cease processing your personal information if the processing is causing you damage or distress;
- to require us not to send you marketing communications;
- to require us to erase your personal information;
- to require us to restrict or object to our data processing activities;
- to receive from us the personal information we hold about you which you have provided to us, in a reasonable format, specified by you, including for the purpose of you transmitting that personal information to another data controller; and
- to require us to correct the personal information we hold about you if it is incorrect.
Please note that these rights may be limited by data protection legislation, and we may be entitled to refuse requests where exceptions apply.