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Sensible Privacy Policy Car Finance 

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint about how we have dealt with your data.

When we use your personal data, we are regulated by the Information Commissioners Office (ICO) under the Data Protection Act 2018 (DPA 2018).  UK GDPR now applies across the United Kingdom, and we are responsible as ‘controller’ of that personal data for the purposes of the UK GDPR. Our use of your personal data is subject to your instructions, the GDPR, other relevant UK U legislation and our professional duty of confidentiality.

Key terms

We, us, ourEqualiti Limited T/A Sensible Car Finance
Personal dataAny information relating to an identified or identifiable individual
Special category personal data

Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership

 

Genetic and biometric data

 

Data concerning health, sex life or sexual orientation

Personal data we collect about you

The table below sets out the personal data we will or may collect in the course of advising and/or acting for you.

Personal data we will collectPersonal data we may collect depending on why you have come to us as a Customer.

Your name, address, and telephone number

 

Information to enable us to check and verify your identity, for example your date of birth or passport details

 

Electronic contact details, for example your email address and mobile phone number

 

Information relating to the finance product in which you are seeking a quotation or finance for

 

Information to enable us to undertake a credit or other financial checks on you

 

Your financial details so far as relevant to your instructions. Information about your use of our IT, communication and other systems, and other monitoring information, for example if using our or other third party secure online Customer portals

Your National Insurance and tax details

 

Your bank and/or building society details

 

Details of your online presence, for example your Facebook or LinkedIn profile

 

Details of your spouse/partner and dependants or other family members, for example if you instruct us on a family matter or a will

 

Your employment status and details including salary and benefits, if you instruct us on matter where these details are relevant

 

Personal identifying information, such as your eye colour or your parents’ names, for example if you instruct us to incorporate a company for you

This personal data is required to enable us to provide our service to you. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you.

How your personal data is collected

We collect most of this information from you, direct or via our secure online client portal. However, we may also collect information:

  • from publicly accessible sources, for example Companies House or HM Land Registry;
  • directly from a third party, including:
  • your bank or building society, other financial institutions or advisors;
  • your employer and/or trade union, professional body;
  • consultants and other professionals we may engage in relation to your credit application;
  • sanctions screening providers;
  • credit reference agencies;
  • Customer due diligence providers;
  • via our website based upon our use of cookies (for more information on cookies, please see our cookies policy)
  • via our information technology (IT) systems, including:
  • case management, document management;
  • automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems;

How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason:

  • to comply with our legal and regulatory obligations;
  • for the performance of our contract with you or to take steps at your request before entering into a contract;
  • for our legitimate interests or those of a third party; or
  • where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal data for and our reasons for doing so:

What we use your personal data forOur reasons
To provide Financial services to youFor the performance of our contract with you or to take steps at your request before entering into a contract

Conducting checks to identify our clients and verify their identity

 

Screening for financial and other sanctions or embargoes

 

Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, for example under health and safety regulation or rules issued by our professional regulator

 

Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies and our lender panel of financial products

To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, for example policies covering security and internet useFor our legitimate interests or those of a third party, to ensure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training, and quality controlFor our legitimate interests or those of a third party, to be as efficient as possible so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information

For our legitimate interests or those of a third party, to protect our intellectual property and other commercially valuable information

 

To comply with our legal and regulatory obligations

Statistical analysis to help us manage our practice and to assess our financial performance, client base, work type or other efficiency measuresFor our legitimate interests or those of a third party, to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorised access and modifications to systems

For our legitimate interests or those of a third party, for example to prevent and detect criminal activity that could be damaging for us and for you

 

To comply with our legal and regulatory obligations

Updating and enhancing Customer records

For the performance of our contract with you or to take steps at your request before and after entering into a contract

 

To comply with our legal and regulatory obligations

 

For our legitimate interests or those of a third party, for example making sure that we can keep in touch with our Customers

Statutory returnsTo comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments

To comply with our legal and regulatory obligations

 

For our legitimate interests or those of a third party, to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you

Marketing our services and those of selected third parties to:

  • existing and former Customers;

 

  • third parties who have previously expressed an interest in our services;

 

  • third parties with whom we have had no previous dealings
For our legitimate interests or those of a third party, for example to promote our business to existing and former Customers
Credit reference checks via external credit reference agenciesFor our legitimate interests or a those of a third party, including for credit control and to ensure our Customers are likely to be able to meet financial obligations of lenders / providers of finance
External audits and quality checks, for example ISO, our providers of  finance / Customer lenders or Investors in People accreditation and the audit of our accounts

For our legitimate interests or a those of a third party, to maintain our accreditations so we can demonstrate we operate at the highest standards

 

To comply with our legal, financial, and regulatory obligations

The above table does not apply to special category personal data, which we will only process with your explicit consent.

Where and when we need your consentThere 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.

Promotional communications

We may use your personal data to send you updates (by email, text message, telephone, or post) about product developments that might be of interest to you and/or information about our services, including exclusive offers, promotions or new services or products.

We have a legitimate interest in processing your personal data for promotional purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal data with the utmost respect and never share it with other organisations for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

Credit Searches

By submitting an application with Sensible Car Finance, you agree to allowing us to submit your details to third party credit reference agencies.

We will send your information to our lending panel to complete a soft search – this is so our lenders can establish creditworthiness. This will not leave a footprint on your credit profile.

If you decide to proceed with the finance agreement, the lender will record a footprint on your credit profile – if you do not consent to Sensible Car Finance submitting your details to credit reference agencies, please do not submit your application.

Who we share your personal data with

We routinely share personal data with:

We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers relating to our instruction to them to ensure they can only use your personal data to provide services to us and to you.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal data with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually information will be anonymised, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

Where your personal data is held

Information may be held at our offices, third party agencies, service providers, representatives and agents as described above (see ‘Who we share your personal data with’)

Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal data when this occurs, see below: ‘Transferring your personal data out of the EEA’.

How long your personal data will be kept

We will keep your personal data after we have finished advising or acting for you. We will do so for one of these reasons:

  • to respond to any questions, complaints or claims made by you or on your behalf;
  • to show that we treated you fairly;
  • to keep records required by law

We will not retain your data for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of data.

When it is no longer necessary to retain your personal data, we will delete or anonymise it.

Transferring your personal data out of the EEA

To deliver services to you, it is sometimes necessary for us to share your personal data outside the European Economic Area (EEA), for example:

  • with your and our service providers located outside the EEA;
  • if you are based outside the EEA;
  • where there is an international dimension to the matter in which we are advising you.

These transfers are subject to special rules under European and UK data protection law.

These non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal data will be secure. Our standard practice is to use standard data protection contract clauses which have been approved by the European Commission.

Your rights

You have the following rights, which you can exercise free of charge:

AccessThe right to be provided with a copy of your personal data
RectificationThe right to require us to correct any mistakes in your personal data
To be forgottenThe right to require us to delete your personal data (in certain situations)
Restriction of processingThe right to require us to restrict processing of your personal data in certain circumstances, for example if you contest the accuracy of the data
Data portabilityThe right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party (in certain situations)
To object

The right to object:

  • at any time to your personal data being processed for direct marketing (including profiling);
  • in certain other situations to our continued processing of your personal data, for example processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision-makingThe right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guide to the General Data Protection Regulations (GDPR) from the Information Commissioner’s Office (ICO).

If you would like to exercise any of those rights, please:

  • complete a data subject request form; or
  • email, call or write to us; and
  • let us have enough information to identify you (including your full name, address and client or matter reference number);
  • let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
  • let us know what right you want to exercise and the information to which your request relates.

Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

How to complain

We hope that we can resolve any query or concern you may raise about our use of your information.

The GDPR also gives you right to lodge a complaint with a supervisory authority in the European Union (or EEA) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/make-a-complaint/ or telephone: 0303 123 1113.

Changes to this privacy policy

This privacy policy was updated on 23rd January 2023