Custom Vehicle Contracts Limited are authorised and regulated by the Financial Conduct Authority FRN 943984.
The information we ask you to provide by which you can be identified will only be used as detailed in this policy statement.
For the purposes of the General Data Protection Regulation (GDPR), we are both the and the (i.e. the company who is responsible for controlling and the processing of your personal data).
This policy document contains the following sections;
Information We Collect
· How We Use the Information We Collect
· How We Share the Information
· Automated Credit Scoring
· Retention of Your Personal Information
· Your Rights Under General Data Protection Law
· Third Party Websites
· Information Security
· Accessing and Changing Your Personal Information
· Lodging A Complaint with A Supervisory Authority
Information We Collect
We will collect personal information or personal data about you in various ways, including:
· When you apply for finance via an introducer, register an account, login to your account, complete an application form or a contact form.
· The information we collect in relation to an application, product or service may include but not restricted to; name, address, telephone number, email address, date of birth, employment details (including income), details of expenditure, passport information, driving license details, bank details, credit history, insurance details, dependants, associates, transaction, and credit card information.
· Should you advise us, or we identify you as a “Vulnerable Customer” then we may need to collect personal sensitive information i.e. health information regarding a disability, illness or impairment.
· This information, if mandatory as part of the application will have to be provided for us to continue with your application.
· Should you apply online to any of the group companies, we collect information about your computer hardware and software i.e. your IP address, browser type, domain names, access times and referring web site addresses. This information is used by Custom Vehicle Contracts Limited to maintain the quality of the service and to provide general statistics regarding the use of the web site.
· When you participate in any market research or promotions provided by Custom Vehicle Contracts.
· Information provided to the business, from business partners, and from other organisations such as credit reference agencies and fraud prevention agencies.
· If you require assistance from us relating to a product or service we offer, or to make or assist with a complaint.
· Should you apply to us for a job vacancy or take employment with Custom Vehicle Contracts or its subsidiaries.
How We Use the Information We Collect
We use the information collected from you to provide you with the services we offer and for the lawful processing of the data based on the following;
· The data subject has given consent to the processing of his or her personal data for one or more specific purposes;
· Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract:
Subject to applicable laws we will monitor and record calls, email, text messages, social media messages and other communications. In particular, telephone calls between us and you in connection with the application and any loan may be recorded for these purposes.
· Provide you with information you require or have requested
· Assess any credit application, which will include confirming your identity and the prevention of fraud or money laundering.
· Where you have chosen to be made aware of our products and services.
· To deliver marketing communications, website improvements, new products & services to you relating to our business via email, phone, SMS or post as requested. You have the right to opt out at any time by putting your request in writing along with your full name and email it to firstname.lastname@example.org
· Send you other business-related communications.
· Responding to any communication you send us.
· To handle any enquiry or complaint you make relating to our business or websites.
· To carry out our HR activities and payroll operation, including third party employment suppliers and governing bodies.
How We Share the Information We Collect
We may share your personal information with the following parties;
· Other companies owned and operated by Custom Vehicle Contracts Ltd.
· Our legal & professional advisors such as our auditors, legal advisors in the event of the sale or restructuring of our business
· Third party loan service providers and administration companies who undertake the day to day servicing of our business. Your information will be submitted to the most appropriate lender from our selected panel of lender
· Other third parties acting on our behalf such as our IT software and maintenance providers for analytical and storage purposes (HubSpot CRM, DVS, AutoConvert, Codeweavers).
· We may also use or disclose information to the extent required by law, court order, as requested by other government law enforcement authority, or to enforce legal rights
· Law enforcement agencies and regulatory bodies if necessary such as HMRC, the Financial Conduct Authority and the Information Commissioners Office.
· Courts, in order to comply with a legal agreement for the administration of justice.
· Fraud Prevention Agencies.
· Credit Reference Agencies (See below)
Callcredit Ltd, Experian Ltd, Equifax Ltd
A full list of our lenders can be provided upon request and we will make you aware of the lenders/brokers we are working with for your application, before any application is submitted.Anglo Scottish Asset Finance Ltd, CarMoney Ltd, ALD Automotive, Hitachi Capital, LeasePlan, Ogilvie Fleet, JVF.
HubSpot CRM, AutoConvert, Codeweavers, DVS
LeaseLoco, Facebook, Leasing.com, Twitter, Instagram, Linkedin
Credit Reference Agencies
In processing your application, we will carry out a credit search, to determine the most suitable lender to meet your requirements, however this will not impact your credit score.
We may share your information with more than one finance provider, which could result in one or more further credit searches being carried out by the chosen lender/s. They will/may perform credit and identity checks on you with one or more credit reference agencies (“CRAs”), which will/may result in their search being visible to other organisations that make credit searches.
When your information is shared by us or by the chosen lender/s with a CRAs, the CRAs will provide back personal information. This will include information about your financial situation and financial history. CRAs will supply to them/us both public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information. This information will be used to:
· Assess your creditworthiness and whether you can afford to take the product;
· Verify the accuracy of the data you have provided to us;
· Prevent criminal activity, fraud and money laundering;
· Ensure any offers provided to you are appropriate to your circumstances.
The identities of the CRAs, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRAs are explained in more detail at each of the three CRAs websites – clicking on any of these three links will take you to the same CRAIN document:
Searches will also be made in respect of Directors and Partners of firms applying for credit. Information held about you by the credit reference agencies may already be linked to records relating to other people with whom you have a financial association. In connection with your application you may be treated as financially linked with them and assessed with reference to any such associated records.
If you provide personal information about someone else, for example a joint application you must only do so with the consent of the other person. If you enter into a product jointly with another person your data will be shared with the other person. If you provide information about others, you confirm that the other person has given you authority to act on their behalf and has agreed that you can provide their personal data
Automated Credit Scoring
Several companies in our lending panel operate automated credit scoring systems as part of their assessment process. However, your application is also subject to a manual assessment by our underwriting team. If your application is rejected solely based on a credit scoring system, you can request that your application is manually assessed as part of the reconsideration.
Retention of Your Personal Information
If your application for finance is declined or if your application is accepted but you do not proceed, we will retain your information for 3-years or as long as necessary to deal with any queries you may have. If your application is accepted and you proceed, then we will retain your information for as follows:
· Retention in case of queries – We will retain it in case of queries from you
· Retention in case of claims – We will retain certain parts of your personal information for the period in which you might legally bring claims against us and,
· Retention in accordance with legal and regulatory requirements – We carefully consider whether we need to retain your personal information after the period described above in case of a legal or regulatory requirement.
We may hold your information for a longer or shorter period from that described above where:
· the law requires us to hold your personal information for a longer period, or delete it sooner;
· you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law; and
· in limited cases, the law permits us to keep your personal information indefinitely provided we put certain protections in place.
Your Rights Under General Data Protection Law
Your personal information is protected under data protection law, and you have a number of rights which you can enforce against us as your data controller. You should be aware that these rights do not apply in all circumstances. If you seek to exercise one against us it will at that stage, be explained to you whether the right does apply to you based on the facts. Your rights are as follows:
· To have your personal information corrected if it is inaccurate and to have incomplete personal information completed in certain circumstances.
· The right in some cases to object to processing of your personal information
· The right in some cases to restrict processing of your personal information.
· The right to have your personal information erased also known as the “Right to be Forgotten”
· To request access to the personal information held about you and to obtain certain prescribed information about how we process it.
· To move, copy, transfer certain personal information also known as Data Portability.
Third Party Websites
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure we have put in place suitable procedures to safeguard and secure the information we collect online.
We currently protect personal data using safeguards such as firewalls and data encryption and password protection. Our buildings have secure access on all floors and staff operate under strict data controls.
Whilst we will use all reasonable efforts to protect such personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data which are transferred from you or to you via the internet.
Accessing and Changing Your Personal Information
If for any reason you are concerned that the personal information we hold about you is incorrect, or if you would like your personal information removed from our records please contact us by email at email@example.com and we will be happy to review, update or remove information as appropriate.
If you asked to be removed from our database, we will mark your account “Closed” but will keep your information as per the retention period requirements. However, if you close your account then your personally identifiable information will not be used by us for any further purposes, nor sold or shared with third parties unless required by law.
In accordance with the General Data Protection Regulation you may request details of personal information we hold about you. Any requests should be made to: Compliance Manager, Custom Vehicle Contracts Ltd, Broomhouse Farm, Parkneuk Road, Auchentibber, G72 0TP
Custom Vehicle Contracts Ltd may also use your information for the administration of any products or services provided to you by us.
We may also provide you with information about other products and services that we offer.
If you have provided your consent, we may also share your information with marketing agencies, who provide marketing services on behalf of the Custom Vehicle Contracts Ltd, to promote the products and services provided by us. If you have previously agreed to us using your personal information for marketing purposes, you may change your mind at any time by putting your request in writing along with your full name or by email it to firstname.lastname@example.org
Please be aware that we will not sell or otherwise disclose any personal data provided to us to any other party without your express permission.
Lodging a Complaint with The Information Commissioner’s Office
Under the General Data Protection Regulation, you have the right to report a concern with a Supervisory Authority which in the United Kingdom is The Information Commissioner’s Office. (ICO)
You can report concerns via the ICO website, but please allow us the opportunity first to understand your issue and see if we can resolve matters with you.
You can visit its website for more information:
Contacting Custom Vehicle Contracts Limited
Custom Vehicle Contracts Ltd
Phone 0330 912 1899
Please note that this policy will be reviewed, and may change, from time to time. The revised policy will be posted to this page so that you are always aware of the information we collect, how we use it and under what circumstances we disclose it.