DATA PRIVACY NOTICE

Who looks after your personal information?

Your personal information will be held and processed by the Allen Ford (UK) Ltd (including Allen Kia, Essex Auto Group & SMC). Visit www.allenford.com for more details on the Allen Ford Group.


Our full privacy notice

This privacy notice sets out our use and sharing of your personal information and the rights you have relating to it.


What data about you we process

Personal data that we’ll process in connection with all of our products and services, if relevant, includes: personal & contact details; date of birth; gender and/or age; your residency and/or citizenship status; records of your contact with us; products & services you have purchased, as well as have been interested in & have held, plus the associated payment methods used; marketing to you & analysing data; vehicle data; data about your use of products or services held with our business partners; data we obtained from third parties; data from Credit Reference Agencies & Fraud Prevention Agencies; fraud, debt & theft information; criminal records; information about your health or if you are a vulnerable customer; financial details about you; data about your employment status; and third party transactions.


How we use your information

We will use your personal information:

• To provide products and services, manage your relationship with us and comply with any laws, regulations or guidelines we are subject to (for example the laws that prevent financial crime or the regulatory requirements governing the products we offer).

• Where it is in our legitimate interests to do so, such as: to keep you and your vehicle safe; to save you money; to carry out monitoring and keep records of our communications with you and our staff; to administer our good governance requirements and those of other members of our Group, such as internal reporting and compliance obligations or administration required for AGM processes; for market research and analysis; for marketing communications and related profiling to help us to offer you relevant products and services, including deciding whether or not to offer you certain products and service (we will send marketing to you by SMS, email, phone, post, and social media and digital channels, e.g. using Facebook Custom Audiences & Google Custom Match); subject to the appropriate controls, to provide insight and analysis of our customers to business partners either as part of providing products or services, or to assess or improve our products, services or businesses; for some of our profiling and other automated decision making; where we need to share your personal information with people or organisations in order to run our business or comply with any legal and/or regulatory obligations.

• With your consent or explicit consent for some direct marketing communications; for some of our profiling and other automated decision making; and/or for some of our processing of special categories of personal data (e.g. health, criminal records or if you are a vulnerable customer).

• For a public interest, such as processing of special categories of personal data (e.g. your health, criminal records or if you are a vulnerable customer).

To support us with the above, we analyse information we know about you and how you use our products and services, including some automated decision making.


Who we share your personal information with

Your personal information will be shared within Allen Ford Group and other companies that provide services to you or us, so that we and any other companies in our Group can look after your relationship with us. By sharing this information it enables us to better understand our customers’ needs, run accounts and policies, and provide products and services efficiently. This processing may include activities which take place outside of the European Economic Area. If this is the case, we will ensure that appropriate safeguards are in place to protect your personal information. We may pass your information to the supplying dealer, any other franchised dealer, or the manufacturer and all companies within the manufacturer or dealer group to support their business and marketing activities.


Where we collect your personal information from

We will collect personal information about you from a number of sources, including:

• Information given to us on application forms submitted by you or by a supplying dealer on your behalf, when you talk to us over the phone or when new services are requested.

• From analysis of how you operate our products and services, including the frequency, nature, location, origin and recipients of any payments.

• From or through other organisations (for example card associations, credit reference agencies, insurance companies, dealers, retailers, comparison websites, social media, and fraud prevention agencies).

• In certain circumstances we may also use information about health or criminal convictions but we will only do this where allowed by law or if you give us your consent.


Do you have to give us your personal information?

We may be required by law, or as a consequence of any contractual relationship we have, to collect certain personal information. Failure to provide this information may prevent or delay us fulfilling these obligations or performing services.


Do we do any monitoring involving processing of your personal information?

Monitoring means any listening to, recording, viewing, intercepting, or taking and keeping records (as the case may be) of calls, email, text messages, social media messages, in-person meetings and other communications. We may monitor where permitted by law and we’ll do this where the law requires it, or to comply with regulatory rules, to prevent or detect crime, in the interests of protecting the security of our communications systems and procedures and for quality control and staff training purposes. This information may be shared for the purposes described above.


What about other automated decision making?

We sometimes make decisions about you using only technology, where none of our employees or any other individuals have been involved. For instance, we may do this to decide whether to offer you a product or service. We’ll do this where it is necessary for entering into or performing the relevant contract, is authorised by laws that apply to us, or is based on your explicit consent.


How long is your personal information retained by us?

Unless we explain otherwise to you, we’ll hold your personal information based on the following criteria:

• For as long as we have reasonable business needs, such as managing our relationship with you and managing our operations.

• For as long as we provide goods and/or services to you and then for as long as someone could bring a claim against us.

• Retention periods that are in line with legal and regulatory requirements or guidance.


What rights you have over your personal information

The law gives you a number of rights in relation to your personal information, including:

• The right to access the personal information we have about you. This includes information from application forms, statements, correspondence and call recordings.

• The right to get us to correct personal information that is wrong or incomplete. Please inform us as soon as possible if personal information we hold on you changes.

• In certain circumstances, the right to ask us to stop using or delete your personal information.

• From 25th May 2018 you will have the right to receive any personal information we have collected from you in an easily re-usable format when it’s processed on certain grounds, such as consent or for contractual reasons. You can also ask us to pass this information on to another organisation.


Other individuals you have financial links with

We may also collect personal information about other individuals who you have a financial link with. This may include people who you have joint accounts or policies with such as your partner/spouse, dependents, beneficiaries or people you have commercial links to, for example other directors or officers of your company. We will collect this information to assess any applications, provide the services requested and to carry out credit reference and fraud prevention checks.


How we use credit reference agencies

In order to process your application we may supply your personal information to credit reference agencies (CRAs), including how you use our products and services and they will give us information about you, such as about your financial history. We do this to assess creditworthiness and product suitability, check your identity, manage your account, trace and recover debts and prevent criminal activity. We may also continue to exchange information about you with CRAs on an ongoing basis, including about your settled accounts and any debts not fully repaid on time, information on funds going into the account, the balance on the account and, if you borrow, details of your repayments or whether you repay in full and on time. CRAs will share your information with other organisations, for example other organisations you ask to provide you with products and services. Your data will also be linked to the data of any joint applicants or other financial associates as explained above.


How we use fraud prevention agencies

The personal information we have collected from you and anyone you have a financial link with may be shared with fraud prevention agencies who will use it to prevent fraud and money laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance or employment.


Contact from us and your marketing choices

Personal contact is an important part of the service and we may contact you personally by mail, telephone, email or text message to inform you about products and services offered by the Allen Ford Group and others that they think are relevant to you, based on their understanding of your financial needs. You have the right at any time to ask us not to contact you or give your details to others for these marketing purposes. You can contact Customer Care at Allen Ford Group by mail, telephone or email and we will update your marketing preferences. The supplying dealer may also contact you with information and offers on vehicles and/or vehicle finance packages (which may refer to our products and services). If you would like the dealer to stop using your details for these marketing purposes, you should contact the dealer.


How you can contact us

If you have any questions or require more information about how we use your personal information, please contact us by e-mailing: datacontroller@allenford.com. If you feel we have not answered your question, Allen Ford Group has a Group Data Controller who you can contact on 01268 522744 and tell us you want to speak to our Data Controller.


Version Control

This notice was last updated on 22nd May 2018. We may update our privacy notice from time to time to reflect changes in the law and/or privacy practices. We encourage you to check this privacy notice for changes whenever you revisit our website.