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Who Are We And What Do We Do With Your Personal Data?

This document explains who we are and how we use any personal information we collect about you when you contact us.

Part A: Initial Disclosure Document

Initial disclosure document

The Financial Conduct Authority (FCA) is the UK regulator of financial services. The FCA requires us to provide you with a document called an 'Initial Disclosure Document'. This document provides you with information about us, the products we offer, the services we will provide, what we charge for our services, who regulates us, and what to do if you have a complaint.

What services do we provide?

We will provide you with either comparable details of firms most appropriate to your lending or purchase requirements or general information relating to finance products. In assessing your requirements we may seek such information about your personal circumstances and objectives as might be relevant in order to enable us to identify your needs. It is important that you provide us with accurate and relevant information. You will not receive advice, or a recommendation from us, but we may ask questions to narrow down the selection of firms offered, from which you can more easily make your own choice if you so wish.

Whose products do we use?

As an FCA regulated credit broker we can introduce you to a range of lenders who may be able to help you finance your vehicle and provide other products/services.

Do we charge for our services?

We charge a small fee for our broker related services at the time of order. As at 1st July 2017, that charge is £216 including VAT. We are a commission and fee based company which means that we may receive a payment(s) or other benefits from finance providers should you decide to enter into an agreement with us. These fees may be variable or fixed dependent upon the product and the volume of customers who we place with a chosen supplier.

Who regulates us?

We are members of the industry trade body, the BVRLA and Affinity Leasing Ltd is authorised and regulated by the Financial Conduct Authority. Our firms reference number (FRN) is 678775. You can check this on the FCA's Register by visiting the FCA's website: http://www.fca.org.uk/register/ or by contacting them on 0300 500 8082.

Some services we offer are not regulated by the FCA. Those services which are regulated by the FCA may also be regulated by the Financial Ombudsman Service.

The Financial Ombudsman Service
Exchange Tower
London E14 9SR
0800 023 4 567
complaint.info@financial-ombudsman.org.uk

If you have a complaint

Please visit our website or ask for details or ask us for our complaints policy and procedure.

Part B: Privacy Policy

What information do we collect?

We collect information when you call in to us, send an email enquiry, request a call back or email quotes through our website, in order to provide pricing to suit your motoring and financial needs. This includes phone numbers and email addresses. We also collect information when you progress through the sale process and give us your mileage, desired deposit level, ideal duration and contract type. If you make an application for a vehicle with us, on behalf of the proposed funder we also collect residential address history, work history, date of birth, bank account number and sort code. We need this information to create quotes for you and this is our “lawful basis” for obtaining, storing and processing your data as you progress through the process.

How will we use the information?

Initially we use it to store your quote and information requests on our Customer Relationship Management (CRM) system. If you then apply for credit, we pass the details to an FCA regulated funder, with your approval. They will have their own Privacy Policy and we will give you their contact details if you wish. We will store this information for the duration of our dealings with you: if you proceed to order stage this will be for the duration of your lease and for six years after. If you have enquired but have not proceeded to order, we will make contact with you at least once a month; you can opt out of these communications and/or ask for us to delete your contact data at any time if you wish by contacting any of our staff in writing with the request. If you don’t remember which member of the team you were dealing with you can email info@affinityvehicleleasing.com . We will remove your details from our CRM system and our email communication service.

Marketing

We never sell our data to anyone else, we know how annoying that can be. We may add your email address to our newsletter distribution list to keep you up to date with our special offers, but you are welcome to opt out of this at any time: you can do it yourself using the instructions on the bottom of the email or send a request to info@affinityvehicleleasing.com

General Data Protection Regulation

We will be the data controller of all personal data obtained by us from you. We don’t anticipate any member or employee personal data will be shared directly by partner organisations with us. For your protection we, and our partner organisations each warrant to the other, at all times, to comply with all applicable laws including without limitation the Data Protection Act 1998 (DPA), the EU General Data Protection Regulation 2016/679 (as amended and replaced from time to time) (GDPR) and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (as amended and replaced from time to time) ("Applicable Law").

Further, we, as data controller we will:

(a) Use the data you give us only for the purposes of processing applications directly from you for Credit Sale Agreements and administering Credit Sale Agreements, and will only disclose the data to the third parties involved in this process;

(b) Have in place, and maintain, appropriate technical and organisational measures against the accidental, unlawful or unauthorised processing, destruction, loss, damage or disclosure of your personal data held or processed by us;

(c) Not retain client data for longer than necessary (in accordance with Applicable Laws); if you lease a car through us we will retain the data we hold on you for 6 years after the end of your lease. If you make an enquiry with us, we will contact you no less than once a month: you can opt out of these at any time and can submit a “request to be forgotten” and we will remove your data from our systems.

(d) Not transfer the your data outside the European Economic Area or to any third party without prior written consent;

(e) Take all reasonable steps to ensure the reliability of any Affinity Leasing employee and/or consultants who have access to your personal data;

(f) at any time we become aware of any breach in security of personal data, we will advise you immediately of the nature and extent of the breach and shall use all reasonable efforts to prevent such breach continuing; and

(g) co-operate with partner organisations to fulfil their respective data protection compliance obligations in accordance with Applicable Laws.

The terms "personal data", "data controller", data processor" and "processing" as used in this Agreement have the meanings given in the GDPR and DPA, as applicable.

Lawful basis for processing personal data

We need to have a lawful basis for processing your data, and, in accordance with Article 6 of the GDPR the basis we have is:

“Contract” – in other words, we need to know specific personal information from you in order to produce quotes for you, and to store and send them to you. If you then decide to proceed with a deal from us, we will be entering into a contract to provide our services to you. Our service starts as soon as you get in touch with us and we can provide verbal quotes to you without needing to take personal data such as your name and email address if we are satisfied that you are a member of our scheme, but if you would like them in writing, or would like to proceed with a car, we need to take additional details in order to be able to process your application for credit.

Access to your information (subject access request) and correction

You have the right to request a copy of the information we hold about you, this can be referred to as a subject access request. If you would like a copy of some or all of the information it must be requested in writing: please write in or email info@affinityvehicleleasing.com citing “SAR” in the heading or subject line. In accordance with the Information Commissioners Office guidance and Data Protection rules, we will need to be sure of your identity before we release the information to you. We charge £10 for this service and we have one month to respond which starts as soon as you pay your fee. You may pay by card over the phone, make an online bank transfer or send a cheque.

We want to make sure that your personal information is as up to date as possible, you may ask to update or correct any incorrect information.

Cookies

Our website contains cookies to collect standard internet log information. This information is used to track visitor use and improve the service we offer. For further information visit www.aboutcookies.org You can set your browser not to accept cookies and the above website tells you how to remove cookies from your browser, however in a few cases some functionality on our website may not function as a result.

Other websites

This policy applies to affinityvehicleleasing.com and trackmyorder.co.uk

How to contact us

info@affinityvehicleleasing.com
0800 060 7070
Compliance Officer, Affinity Leasing Ltd, Cross Bank House, Cross Bank, Bewdley, DY12 2XB

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