At Fowlers Finance , we understand the importance of looking after you, our customer, and the information you have entrusted to us. Our promise to you is that:
· We will keep your personal information safe and secure.
· We will be open and transparent with you about how we use, process and share your personal information.
· We will never send your personal information to third parties without your consent, unless we have a legitimate legal reason for doing so.
Fowlers Finance is Authorised and Regulated by the Financial Conduct Authority, our Firm Reference Number is 712300. You can find out more about us on our website www.fowlersfinance.com, including how we use your information in our Privacy Notice. Fowlers Finance is Authorised and Regulated by the Financial Conduct Authority, our Firm Reference Number is 712300. You can find out more about us on our website www.fowlersfinance.com , including how we use your information in our Privacy Notice.
During your application for car finance with us, we ask for personal information about you, including your name, date of birth and address history. As a finance company, to help us consider your application for car finance, we will also ask for additional information about your employment and financial circumstances such as your income and outgoings.
If you are approved and proceed to take out finance with us the types of personal information we collect may change. If you would like more in depth information about the type of information we ask for please click on the links below:
· Personal information identifying you – your name and date of birth.
· Contact information – your address, telephone numbers and your email address.
· Consent Information – Any permissions, consents or preferences you make us aware of. This includes information regarding how we contact you for marketing purposes.
· Personal information identifying you – Such as your name and date of birth.
· Contact information – Such as your address, telephone numbers and your email address.
· Employment information – Such as your employment status and employment history.
· Financial Information – Your income, payment frequency, bank details and regular expenditure to enable us to assess your ability to afford the car finance repayments.
· Locational information – such as the IP address of your personal device used to view our website and apply online.
· Consent Information – Any permissions, consents or preferences you make us aware of. This includes information regarding how we contact you for marketing purposes.
· Proof of identification – If we are unable to prove your identity via our electronic checks, we will ask you to provide proof of identity. We also conduct Fraud Prevention checks to aid us in confirming your identity and to help us protect both you and us from potential fraud.
· Credit History – We perform Credit Reference checks. The checks provide us with information about your current credit commitments and your financial history. To find out more about how we and credit reference agencies use your data please see the section titled "Credit Reference Agencies (CRAs)."
· Driving offence and penalty points – With your permission, we, or an authorised representative, will request information from the DVLA to confirm you have a valid driving license, and whether you have any driving offences that need to be considered to ensure you are in a position to afford the insurance for your new vehicle. We will ask you for consent to conduct this check.
· Transaction information – We will keep a record of your repayments, including the date payment has been made and the total paid per instalment.
· Communications from you – We will learn about changes to your personal information and circumstances based on any communication you make with us. This may include new contact details, changes of name, and recording changes of circumstances via emails, phone calls, text messages, social media and customer surveys. Copies of communications with you and recordings of any telephone conversations will be stored on our systems.
· Information we receive about you from approved companies – We outsource certain aspects of our business to approved companies. As they act on our behalf, they may provide us with information about you to aid us in managing your account. For more information about the firms we work with, please see “Who do you share my personal information with.”
· Sensitive information about you – Should you have a change in circumstance we may ask you to provide us with additional information to aid us in managing your account. This could include information about your mental and physical health. Where we believe there is a benefit to capture this information, we will inform you why it would be appropriate for us to hold it, including any pros or cons. We will request explicit consent from you to store and use this information.
· Payment information – If paying via a debit card we will process your card payment via our card merchant. We do not store your card information for one off payments.
· Organisations who introduce you to us – Should you come though a credit broker, price comparison website, or any other type of credit introducer we may need to share your details with them, whether you were approved for finance and went on to take out a finance agreement with us.
· Approved Car Dealerships – If you require help finding a vehicle to finance, we will pass information about you to one of our approved dealers to provide assistance. We will give them some basic information to contact you and discuss any available options. We will inform you about the car dealer and request your permission to share your personal information before doing so.
· Credit Reference and Fraud Prevention Agencies – We share your information with these agencies to aid us in making credit decisions. For more information about how we interact with Credit Reference Agencies click here.
· Payment Reminder System (PRS) agents – If you enter into a Hire Purchase Agreement with Fowlers Finance, as part of your terms and conditions you will need to have a PRS device installed. We may need to pass approved device fitters personal information in order to fit your PRS at your car dealership, your home or at an agreed location.
· Warranty Companies – If purchasing a car from Fowlers Finance, we may include a warranty, provided by Warrantywise, to aid in the repair of any potential faults for a fixed period. If a warranty is provided we will share some of your personal information to enable Warrantywise to set up your warranty cover and manage any claim you may make. For more information on how Warrantywise use your information please click here.
· Finance Companies – If purchasing a vehicle we will share your information with companies on our approved list of finance providers to aid them in making a decision to provide you with finance. You can find out more about how these companies use the information we share by viewing their Privacy Notice. A link is provided below for each of the firms we share data with:
· HM Revenue and Customs.
· The Financial Conduct Authority, Information Commissioners Office and other regulatory authorities.
· Independent complaint resolution services such as The Financial Ombudsman Service.
· Fraud agencies such as the National Crime Agency, Police and Action Fraud.
· Other 3rd parties such as The Department Work and Pensions, Local councils where car fines have been issued and DVLA
· Parties that have a vested interest in your account, such as loan funders who enable the firm to lend.
· We may choose to sell, transfer, or merge parts of our business, or our assets. Or we may seek to acquire other businesses or merge with them.
· During any such process, we may share your personal information with other approved companies. We’ll only do this if they agree to keep your personal information safe and private.
· If a change to Fowlers Finance happens, then other parties may use your personal information in the same way as set out in this notice.
· To fulfil a contract we have with you, or
· When it is our legal duty, or
· When it is in our legitimate business interest, or
· When you consent to it.
Explanation of a legitimate business interest
· To carry out marketing activities and send you marketing communications.
· When we ask you to allow us to share your information – for example firms acting on your behalf.
· When processing any sensitive personal information about you.
· To confirm you hold a valid driving license and validate the affordability of your loan - We will ask for your consent to conduct this check by asking you to provide us with a code from the DVLA. This allows us to view your license via their database. You can withdraw your consent at any time in the process. Please be aware that should you withdraw your consent, or do not consent to us performing this check, we will be unable to complete your loan application.
· You can change/withdraw your consent at any time. For more information please contact us.
· Delivery of our product in line with your contract.
· Providing guidance on how best to manage your account.
· To make and manage payments made to us.
· To manage fees, charges, and interest due on your loan agreement.
· To trace your whereabouts and contact you about your account.
· To collect and recover money that is owed to us.
· To collect or recover the vehicle.
· To exercise our rights as set out in your loan agreement.
· To ensure any offer made is in your best interests, as required by Financial Conduct Regulators. Specifically, that the agreement is legally enforceable, adequately explained to you and is affordable for you to repay.
· To detect, investigate, report, and seek to prevent financial crime.
· To obey laws and regulations that apply to us.
· To respond to complaints and seek to resolve them as required by Financial Conduct Regulators.
Customer & business focused activities
• To manage our relationship with you.
• Keeping our records up to date, working out which of our products and services may interest you and telling you about them.
• To monitor emails, calls, other communications and activities on your agreement to ensure we treat you fairly.
Reviewing communications between you and us to ensure you are receiving
the correct information from us to make informed decision about your
• To develop new ways to meet our customers’ needs and to grow our business.
• Developing products and services, and what we charge for them.
• To test new products
• Defining types of customers who are our appropriate users of any product we create or launch.
• To develop and carry out marketing and communication strategies.
• Defining types of customers for new products.
• To contact you towards the end of your agreement to make you aware of future products and services that may be relevant to you.
• Ensuring you are aware of any product or service we provide that you may like to consider.
• To study how our customers, use our products.
• Being efficient about how we fulfil our legal duties.
• To protect our customers and ourselves from fraud.
• To ensure we only lend to legitimate customers.
• To manage how we work with other companies that provide services to us and our customers.
• Being efficient about how we fulfil our legal and contractual duties.
• To manage risk for us and our customers.
• Developing and improving how we deal with financial crime, and other business and regulatory risks as well as doing our legal duties in this respect.
• To run our business in an efficient and proper way. This includes managing our financial position, business capability, planning, communications, corporate governance, and audit.
• Complying with regulations that apply to us.
• To monitoring communications with you.
• Training and monitoring purposes.
• To monitor the location of your vehicle
In line with your contract with us, should your account go into arrears
we will monitor the location of the vehicle via the PRS installed in
• For the establishment and defence of legal rights.
• In the event of legal proceeding, we will use the information available to us, including personal information, to aid us in building or defending a legal case.
• To anonymise personal information for various legitimate business needs.
• We anonymise personal information to ensure our customers are not personally identifiable to the users of that information.
We use systems to make certain automated decisions based on personal information we have or are allowed to collect from others and about you. This helps us to make sure our decisions are quick, fair, efficient and correct, based on what we know. These automated decisions can affect the products, services or features we may offer you now or in the future, or the price that we charge you for them.
All of our automated loan decisions are reviewed by one of our underwriting team to ensure our automated decisions are fairly assessed before issuing a final loan decision. You can ask for your application to be reviewed by a second underwriter if you feel the decision is unfair or incorrect.
Here are the types of automated decisions we make:
· Your application form.
· Credit reference agencies.
· Information we receive from approved companies.
As a person you have rights over automated decisions.
· You can ask that we do not make our decision based on the automated score alone.
· You can object to an automated decision and ask that a person reviews it.
All our automated loan decisions are reviewed by one of our underwriting team to ensure automated decisions are fairly assessed before issuing a final loan decision. If you want to know more about these rights, please contact us.
We carry out credit and identity checks when you apply for a product or services for you or your business. We use Credit Reference Agencies to help us with this.
If you use our services, from time to time we may also search information that the CRAs have, to help us manage your account.
· Name, address and date of birth.
· Your credit application.
· Details of any shared credit.
· Financial situation and history, including debt judgements, insolvency and bankruptcy information.
· Public information, from sources such as the electoral register and Companies House.
· Outstanding balance due.
· Details of your repayments.
· Information confirming whether you repay in full and on time.
We’ll use this personal information to:
· Assess your affordability, to ensure you can afford the agreed repayments.
· Make sure what you’ve told us is true and correct.
· Help detect and prevent financial crime.
· Manage accounts with us.
· Trace and recover debts and assets.
· Make sure that we tell you about relevant offers.
· Who they are.
· Their role as fraud prevention agencies.
· The information they hold and how they use it.
· How they share personal information.
· How long they can keep your information.
· Your information protection rights.
We need to confirm your identity before we provide products or services to you. Once you have become a customer of ours, we will also share your personal information as needed to help detect fraud and money-laundering risks. We use a Fraud Prevention Agencies to help us with this. We or an FPA may allow law enforcement agencies to access your personal information. This is to support their duty to detect, investigate, prevent and prosecute crime.
· Confirm your identity.
· Help prevent fraud and money laundering.
· Fulfil any contract you have with us.
· Date of birth.
· Residential address.
· History of where you have lived.
· Contact details, such as email addresses and phone numbers.
· Financial information.
· Information relating to your loan.
· Employment details.
· Vehicle details.
· Information that identifies computers or other devices you use to connect to the internet. This includes your Internet Protocol (IP) address.
We will send some of your personal information outside of the European Economic Area (EEA). When we do, we will only send your personal information to a country whose data protection laws have been confirmed by the European Commission as being “adequate”, or where there is a contract in place to make sure the recipient protects the information to the same standard as the EEA, or where the approved company receiving your information is confirmed as being in compliance with EU data protection standards via an approved scheme. This may include following international frameworks for making information sharing secure.
· Transfer it to a non-EEA country with privacy laws that give the same protection as the EEA.
· Put in place a contract with the recipient that means they must protect it to the same standards as the EEA.
· For personal information sent to the USA, transfer it only to organisations that are part of Privacy Shield. This is a framework that sets privacy standards for personal information sent between the US and EU countries. It makes sure those standards are similar to what is used within the EEA.
We use your personal information to tell you about relevant products and offers. This is what we mean when we talk about ‘marketing’.
The personal information we have for you is made up of what you tell us, and personal information we collect when you use our services, or from third parties we work with.
We study this to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
We will keep your personal information for as long as you are a customer of Fowlers Finance.
If you have an agreement with us
After you stop being a customer, we may keep your personal information for six years from the end of your agreement for one of these reasons:
· To respond to any questions or complaints.
· To show that we treated you fairly.
· To maintain records according to rules that apply to us.
· To defend any legal claim brought against us.
We will keep your personal information for longer than 6 years if we cannot delete it for legal, regulatory or technical reasons. We may also keep it for research or statistical purposes. If we do, we will make sure that your privacy is protected and only use it for those purposes.
If you do not take up your loan offer or are refused finance
We will hold your information for 12 months to enable us to answer any questions or complaints you may have. During the 12 month retention period we will refer back to previous application decisions, and the personal information supplied, to aid us in our decisioning.
You have the right to object to our use of your personal information, or to ask us to delete, remove, or stop using your personal information if there is no need for us to keep it. This is known as the ‘right to object’ and ‘right to erasure’, otherwise known as the ‘right to be forgotten’.
There may be legal or other official reasons, including lawful reasons, why we need to keep or use your personal information. But please tell us if you think that we should not be using it. You have the right to object to how we use your data. We will consider your request and provide you with a decision and the reason behind our stance.
We may sometimes be able to restrict the use of your personal information. This means that it can only be used for certain things, such as legal claims or to exercise legal rights. In this situation, we would not use or share your information in other ways while it is restricted.
· It is not accurate.
· It has been used unlawfully but you don’t want us to delete it.
· It is not relevant any more, but you want us to keep it for use in legal claims.
· You have already asked us to stop using your personal information, but you are waiting for us to tell you if we are allowed to keep on using it.
· Information being processed incorrectly.
· Information being processed using inaccurate information.
· Information being processed in a way that was not stated or explained to you.
If you would like to speak to us about how we use your personal information you can ask us by contacting us via:
Unit 1 & 2 Berryhill Industrial Estate,
Stoke on Trent,
· Telephone: 01782 940215
· E-mail: firstname.lastname@example.org
· Sales E-mail: email@example.com
· After sales E-mail: firstname.lastname@example.org