WEBSITE PRIVACY POLICY

 

Introduction

The website https://www.carloan2day.co.uk/ (the “Site”) is operated by Penrican Credit Limited (Company Number 2443952), trading as CarLoan2Day (“we” or “us”).  We are what is known as the ‘controller’ of personal information we gather and use. This means that we are responsible for, and control the processing of, your personal information in accordance with data privacy laws.

This  Privacy Policy (the “Policy”) relates to your use of our Site. This Policy should be read in conjunction with our Site Terms and Conditions (the “Terms”).

We take your privacy very seriously and we ask that you read this Policy carefully, as it contains important information on:

• the personal information we collect about you;
• what we do with your information; and
• who your information might be shared with.

 

Information which we may collect

We collect personal information about you from both you directly (e.g. when you register with us, contact us or when you submit an application for credit on our Site) and, by indirect means, for example from third party motor dealers or through cookies (see ‘Cookies and Tracking’ below).

We may collect the following personal information, which includes that information of any joint applicants:

• a) full name;
• b) postal address;
• c) email address;
• d) telephone numbers;
• e) marital status;
• f) date of birth;
• g) employment details; and
• h) your income details.

We may also collect personal data about you from other sources (such as credit reference agencies) which we will add to the information we already hold about you in order to help us to improve our products and services, and make credit decisions about you. Further details about this is set out below in ‘How we use your information”.

Where and when we need your consent – There will be circumstances where we will only process your data if we have your consent to do so. For example, if you provide us with data that is classed as a special category of data such as health information, criminal records of convictions and offences, or allegations of criminal offences. We will only process this with your permission (unless we feel the processing is necessary to protect your vital interests or if the law allows us to do so). You have a right at any time to ask us to stop the processing of that specific data.

 

How we use your information

We will collect your personal information for the following purposes on the basis that it is necessary for the performance of, or as part of the steps requested by you prior to entering into, the contract for our services:

• a) process your application for car finance;
• b) verify your identity, address (both previous and current) and assess your application for finance;
• c) perform a credit search with one or more credit reference agencies (“CRAs“) and make credit-related decisions about you. Some of these credit-related decisions may include automated decision making – see ‘CRAs, Third Party Lenders and Automated Decision Making’ below;
• d) introduce you to third party lenders; and
• e) notify you of any changes to our Site or to our services that may affect you.

We may also collect and process your personal information for the following purposes on the basis that it is necessary for the purposes of our legitimate interest to do so and we ensure that our legitimate interest does not override your interest or fundamental rights and freedoms.

• a) conduct research, statistical analysis and behavioural analysis;
• b) detect and prevent fraud;
• c) customise our Site and its content to your particular preferences;
• d) carry out security vetting; and
• e) improve our products and services.

If you agree, we may collect and process your personal information to let you know about other products or services that may be of interest to you – see ‘Marketing’ section below.

 

Special Category Data

Where and when we need your consent – There will be circumstances where we will only process your data if we have your consent to do so. For example, if you provide us with data that is classed as a special category of data such as health information, criminal records of convictions and offences, or allegations of criminal offences. We will only process this with your permission (unless we feel the processing is necessary to protect your vital interests or if the law allows us to do so). You have a right at any time to ask us to stop the processing of that specific data.

 

CRAs, Third Party Lenders and Automated Decision Making

In order to process your application for credit, we may perform credit and identity checks on you with one or more CRA.

To do this, we will supply your personal information to CRAs and they will give us information about you. The information provided to us will include information from your credit application about your financial situation and financial history. CRAs will supply to us both public (including electoral register) and shared credit, financial situation and financial history information and fraud prevention information.

We will use this information to:

• Assess your creditworthiness and whether you can afford the product;
• Verify the accuracy of the data you have provided to us;
• Prevent criminal activity, fraud and money laundering;
• Manage your account(s);
• Trace and recover debts; and
• Ensure any offers provided to you are appropriate to your circumstances.

We will continue to exchange information about you with CRAs while you have a relationship with us. We will also inform the CRAs about your settled accounts. If you borrow and do not repay in full and/or on time, CRAs will record the outstanding debt. This information may be supplied to other organisations by CRAs.

When CRAs receive a search from us they will place a search footprint on your credit file that may be seen by other lenders.

If you are making a joint application, or tell us that you have a spouse or financial associate, we will link your records together, so you should make sure you discuss this with them, and share with them this information, before lodging the application. CRAS will also link your records together and these links will remain on your and their files until such time as you or they successfully file for a disassociation with the CRAs to break that link.

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 period and your data protection rights with the CRAs are explained in more detail by the three main CRAs (Callcredit, Equifax and Experian); please find a copy of their Credit Reference Agency Information Notice (“CRAIN”) by clicking on any of these three links which will take you to the same CRAIN document: Callcredit click here Equifax click here Experian click here

Fraud Prevention Agency records will also be shared with other organisations to help make decisions on motor, household, credit, life and other insurance proposals and insurance claims, for you and members of your household, managing credit and credit related accounts or facilities and checking details of job applicants and employees. We and other organisations may access and use from other countries the information recorded by fraud prevention.

If false or inaccurate information is provided and fraud is identified, details will be passed to fraud prevention agencies to prevent fraud and money laundering. You may, by telephoning us using the contact details below, obtain details of those credit reference and fraud prevention agencies from whom we obtain and to whom we pass information about you. You have a legal right to these details. Further details explaining how the information held by fraud prevention agencies may be used can also be obtained by telephoning our Customer Services Department on 01132 581826.

By using this Site, you agree to us referring your information to suitable third party lenders. The third party lenders that we pass your information on to will be based on the credit search results. The relevant third party lender will perform a credit search and register this search with the CRAs in order to make a decision about your application. The results of this search may be recorded on your credit file in accordance with the procedures described above.

We, or third party lenders, may make automated decisions about you concerning your application for credit based on your credit history and the information provided. The logic behind this is to make an informed decision whether we or a third party lender will be able to offer you credit. The significance of this is that you may be automatically refused credit. Find further information in the ‘Your Rights’ section below.

If we, or a Fraud Prevention Agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services and financing you have requested or we may stop providing existing services to you.

 

Marketing

We may from time to time contact you about new products, special offers and other information which we think you may find interesting using the e-mail address that you have provided.

We may contact you by email, telephone (including automated calls), SMS text message or post. We will only send you marketing messages when you consent for us to do so (by ticking the relevant boxes when you provide us with your personal information) and you can opt out at any time by clicking the link at the bottom of the email, by telling us on the phone, by responding to the SMS as instructed or by following this link. Please see below for further information in relation to your right to ask us to stop contacting you with direct marketing.

We will not share your details to any third party for the purposes of marketing without your explicit consent.

If you do not consent to marketing, this will in no way affect your application for credit.

 

How long we will keep your personal information

We shall retain your information for the duration of our agreement with you and for an additional 6 years for the purposes of complying with our legal obligations, unless we are required by law to retain your personal information for a longer period.

 

Our approach to information security

To protect your information, we have policies and procedures in place to make sure that only authorised personnel can access the information, that information is stored in a secure and sensible manner and all systems that can access the information have the necessary security measures in place. To accomplish this, all employees, contractors, and sub-contractors have roles and responsibilities defined in those policies and procedures.

To make sure all employees, contractors and sub-contractors understand these responsibilities they are provided the necessary training and resources they require.

In addition to these operational measures, we also use a range of technologies and security systems to reinforce the policies.

To make sure that these measures are suitable, vulnerability tests are run regularly. Audits to identify areas of weakness and non-compliance are routinely scheduled. Additionally, all areas of the organisation are constantly monitored and measured to identify problems and issues before they arise.

 

Your Rights

In order to process any of the requests listed below, we may need to verify your identity for your security. In such cases your response will be necessary for you to exercise this right.

A. The right to access information we hold on you

At any point, you can contact us to request the information we hold on you as well as why we have that information, who has access to the information and where we got the information. Once we have received your request we will respond within 30 days.

B. The right to correct and update the information we hold on you

If the data we hold about you is out of date, incomplete or incorrect, you can inform us and we will ensure that it is updated.

C. The right to have your information erased

If you feel that we should no longer be using your data or that we are illegally using your data, you can request that we erase the data we hold. When we receive your request, we will confirm whether the data has been deleted or tell you the reason why it cannot be deleted.

D. The right to object to processing of your data

You have the right to request that we stop processing your data. Upon receiving the request, we will contact you to tell you if we are able to comply or if we have legitimate grounds to continue. If data is no longer processed, we may continue to hold your data to comply with other law or regulation.

E. The right to ask us to stop contacting you with direct marketing

You have the right to request that we stop contacting you with direct marketing. In order to process your request, we may need to verify your identity for your security.

F. The right to data portability

You have the right to request that we transfer your data to another data controller. Once we have received your request, we will comply where it is feasible to do so.

G. The right to object to automated decision making

You have the right to not be subject to a decision based solely on automated processing (without human intervention) which produces a legal effect concerning you or which significantly affects you.

H. Sharing your information

Where necessary, to fulfil our obligations to you, we may pass your details to third parties where this is necessary for the functioning of our product. These third parties include:

• a) Credit Reference Agencies (“CRAs”)

The details of this sharing have been set out above.

• b) Third Party Lenders

We may share your personal data with other Third Party Lenders to enable us to consider all financial products available to you. These third party lenders may carry out credit searches against you with the CRAs which may have the same effect on your credit file as set out under the ‘Credit Reference Agency’ section of this Policy.

Third Party Lender specific Privacy Policies can be located here:

Moneybarn No 1 Limited: https://www.moneybarn.com/privacy-policy/

•  c) Google

We work with third party Company Google to automatically collect information including: IP address; MAC (Media Access Control) address; unique identifier or other persistent or non persistent device identifier; device software platform and firmware, mobile phone carrier and geo location data to help us understand your use of our Site such as how often you return, what parts of the Site you visit, how you use the Site and how long you spend on the Site. The third party provider is prohibited from using our data for any other purposes. Go to http://www.google.com/analytics/terms/us.html to read Google Analytics Privacy Policy. We use the data we collect about your use of the Site to analyse trends across the data set of all customers worldwide, and to enable us to offer a better service to you.

•  d) Other

We may share your information where it is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other users, or anyone else who could be harmed by such activities. We also reserve the right to disclose user information when we believe in good faith that the law requires it.

In order to protect our customers and us from fraud and theft, we may pass on information that we obtain from making identity checks and other information in our customer records, including how you conduct your account, to third parties with whom we work with to provide our services to you and to financial and other organisations included in fraud prevention and detection, to use in the same way. Without limitation to the foregoing, we may disclose any information and data relating to you to the police or any regulatory or government authority in response to any request including requests in connection with the investigation of any suspected illegal activities.

 

Cookies and Tracking

A. Use of Cookies

A cookie is a small text file which is placed onto your computer (or other electronic device) when you access our Site. We use cookies on this site to:

• a) recognise you whenever you visit this Site (this speeds up your access to the Site as you do not have to log in each time);
• b) obtain information about your preferences, online movements and use of the internet;
• c) carry out research and statistical analysis to help improve our content, products and services and to help us better understand our customer requirements and interests;
• d) target our marketing and advertising campaigns more effectively by providing interest-based advertisements that are personalised to your interests; and
• e) make your online experience more efficient and enjoyable.

In most cases, we will need your consent in order to use cookies on this Site. The exception is where the cookie is essential in order for us to provide you with a product or service you have requested.

B. Consent

There is a notice on our Site which describes how we use cookies and which also provides a link to our Site cookie policy – you can also find the link here. If you use this Site after this notification has been displayed to you, we will assume that you consent to our use of cookies for the purposes described in this website cookie policy and our website privacy policy.

C. How to turn off cookies

If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of this Site. For further information about cookies and how to disable them, please go to the Information Commissioner’s webpage on cookies: https://ico.org.uk/for-the-public/online/cookies/.

 

Enquiries

When contacted with an enquiry, we will hold the entity name and contact details only for the purposes of handling the enquiry.

The online forms are subject to the same cookies and tracking as the rest of the Site.

Calls made to us may be recorded to protect the interests off all parties. Call records are deleted after 28 days unless needed for ongoing actions.

 

Contact Details

If you have any queries about this Policy, need further information or wish to lodge a complaint you can use the details below to contact the relevant party.

 

David Shoesmith

Data Protection Officer

Penrican Credit Limited trading as CarLoan2Day

First Floor,

257A New Road Side,

Horsforth,

Leeds.

LS18 4DR

david.shoesmith@penricancredit.co.uk

Customer Services Department: 01132 581826

 

Right to complain

If you are not happy with the way in which we process your personal data, then you have the right to complain to the Information Commissioners Office, who are the regulator for processing of personal data.

 

Changes to this Privacy Policy

We may change this Policy from time to time. You should check this Policy occasionally to ensure that you are aware of the most recent version that will apply each time you access the Site.