Privacy Policy

Last Updated: 20th June 2022

This Privacy Policy applies to information that Holmesdale Finance, and any parents, subsidiaries and affiliate entities worldwide (individually and collectively referred to herein as the “Holmesdale Finance”, "we," "us" or “our”) collects about you on or via www.holmesdalefinance.co.uk (or any subdomain), or one of our other websites, applications or other services from which you are accessing this Privacy Policy (each referred to herein as a “Site,” and collectively, the “Sites”). This Privacy Policy describes how we collect such information, how we use it and to whom and under what circumstances we may disclose it.

 

HOW WE COLLECT INFORMATION

Information You Provide to Us

We (or our service providers) may collect information from you when you:

• purchase products from us,
• create an account with us, or otherwise sign up for a service or feature;
• participate in a survey, poll, sweepstakes, contest or other promotion;
• communicate with us via third-party social media sites;
• submit a rating or review;
• or contact us, or otherwise communicate with us or provide information to us.

The “personal information” we collect may include, for example, your name, postal address, postal code, email address, telephone number, date of birth, payment information, details on items purchased, and other information you choose to provide to us. In some cases, you may provide information to us about someone else, such as when you request that we deliver an e-commerce order to that person or when you share website content. In these type of cases, you agree that you have the authority to provide us with such information.

How long will we store your personal information?

We will store your personal information for up to 12 months, we will store your personal information for six years from the point of last engagement with you. This is to enable us to refer to our records in the unlikely event that you want to lodge a complaint against us within six years.

If you do not exercise your right to object to marketing or unsubscribe to our marketing emails we will store your personal information for marketing purposes until you exercise your right to object or unsubscribe.

 

What are your rights in relation to your personal information?

Right to access

You have the right to request copies of the personal information we hold about you at any time.

Right to rectification

You have the right to request that we correct any inaccurate personal information we hold about you.

Right to erasure

You have the right to request that we delete your personal information from our records.

Please note that we will not be able to delete your personal information whilst we are still providing our services to you. We will be able to delete your personal information once you cancel the service or once the service is completed.

Right to restrict processing

You have the right to request that we restrict how we use your personal information.

Right to object

You have the right to object to the collection and use of your personal information at any time.

Right to data portability

You have the right to obtain a copy of your personal information in a legible and compatible format such as PDF, Excel or Word.

If you fail to provide Personal Data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

How can I exercise my rights in relation to my personal information? You can exercise all your rights by contacting us on any of the above contact details. How do I lodge a complaint about the use of my personal information?

You can lodge a complaint with us directly by contacting us on one of the above contact details.

You also have the right to lodge a complaint directly with the Information Commissioner’s Office (ICO). The ICO are the regulator who makes sure that we use your personal information in a lawful way.

You can lodge a complaint with the ICO by following this link https://ico.org.uk/make-a-complaint/ or calling the ICO on 0303 123 1113.

How long will we store your personal information?

We will store your personal information for up to six years on our CRM systems. We are committed to ensuring your data is kept secure so review our security systems on a regular basis.

This is to enable us to refer to our records should we be required to for the purpose of regulatory or lawful reasons.

If you do not object to receiving marketing communications from us, we will store your personal information for marketing purposes until you unsubscribe from receiving marketing communications from us.

Please note that some of your information may be included in information used for accounting purposes. Where this is the case this information is kept for 7 years as per our legal requirements.

How we might share your information

The third parties with whom we may need to share personal information to help us provide services and products to you are detailed within this section.

Our partners, including brokers, introducers, lenders and motor dealers we work with depend upon your individual credit profile and the specific criteria determined by the lender.

• Close Motor Finance - https://www.closemotorfinance.co.uk/privacy-policy
• PCF Bank - https://pcf.bank/privacy
• V12 - https://www.v12retailfinance.com/privacy-policy
• JBR Capital - https://jbrcapital.com/customer-policies/privacy-policy/
• Moneyway - https://www.moneyway.co.uk/privacy-statement
• Automoney – www.automoneymotorfinance.co.uk/privacy-policy/
• Blue Motor Finance - https://bluemotorfinance.co.uk/PrivacyPolicy
• Marsh Finance – www.marshfinance.com/privacy/
• Moneybarn – www.moneybarn.com/privacy-policy/
• Oodle Car Finance - www.oodlecarfinance.com/privacy-notice
• Paragon Bank - https://www.paragonbank.co.uk/data-protection
• Our subsidiaries or affiliates, for the purpose of managing our customer relationships, administering our business and to provide you with information about other products and services which might be of interest to you;
Service providers who need to know the information in order to provide us or you with a product or service (including our third party service providers who process information on our behalf to help run some of our internal business operations including email distribution, electronic signature processing, storage of customer documentation, our HR careers portal, IT services, customer services and for data analytics (using anonymised data));
• Third party credit providers at your request where you have been unsuccessful in applying for personal lending services and/or product(s); in which case third party credit providers will become the relevant data controller;
• Credit and fraud agencies (including Call Credit, Equifax, Experian and Cifas) to help make decisions.
• Law enforcement bodies in order to comply with any legal obligation or court order.
• Third parties for the purpose of validating and assessing fitness and propriety in connection with any application for employment.
• Entities who may or do acquire any rights in us for the purpose of a business sale or reorganisation;
• Occasionally, we may make your details available to reputable suppliers of credit and insurance related services that we feel may be of interest to you where you have agreed to receive such marketing.
• Debt recovery agencies or service providers, tracing agents or investigators, solicitors or other agents for the purpose of collecting monies or assets due or outstanding on your account;
• We reserve the right to sell performing and non performing accounts. We will inform you if we do this.

 

Credit checking and automated decision making

Whenever you apply for any of our products and/or services we and/or our lenders will carry out checks with credit reference agencies ("CRAs"), including-

• Checks against publicly available information such as the Electoral Register, County Court Judgments (CCJs), bankruptcy or repossession information. These checks may be referred to as "soft searches" or "quotation searches" and are visible to only you;
• Checks against data relating to your financial situation and financial history. These checks may be referred to as "hard searches" or "credit application searches" and may be visible to other third parties, such as potential lenders

 

We will use this information to:

• Assess your creditworthiness and whether you can afford to take 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 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 your partner successfully files for a disassociation with the CRAs to break that link.

Whenever fraud prevention agencies transfer your personal data outside of the European Economic Area, they impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the European Economic Area. They may also require the recipient to subscribe to "international frameworks" intended to enable secure data sharing.

Retention of your personal information

The personal information that you provide will be retained by us in accordance with applicable laws. However, in accordance with our lawful basis, data will only be retained in line with our stated policy approach and only be used for the purposes detailed, any marketing activity will only be undertaken where we have your consent, following the conclusion of your relationship or employment with Holmesdale Finance LTD or its subsidiaries and trading styles.

Our retention policies are aligned to individual rights and freedom and any request under those rights will be met in accordance with our stated lawful bases or obligations.

Sensitive personal data

Sensitive personal data includes information about an individual's health and other categories of personal information which are closely protected (e.g. criminal convictions). We do not generally process such information, unless you have voluntarily provided that information to us (for example, where you have notified us of a health issue).

You agree that, to the extent that you have provided us with sensitive personal data, you provided it voluntarily and agree that we can use any sensitive personal data that you provide us to deliver products or services to you and/or determine your fitness to avail yourself of our products or services. Where possible we shall seek to minimise the collection and use of such sensitive personal data.

 

Marketing

Where you tell us you are happy to receive information from us we may send you communications products that we perceive may be of interest to you (including in relation to products and/or services of our partners where we have your agreement).

Depending on the contact preferences you select, we will communicate with you by letter, telephone, SMS, email or other electronic means such as via social and digital media.

 

Keeping your information secure

We invest appropriate resources to protect your personal information, from loss, misuse, unauthorised access, modification or disclosure, in particular:

We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorised access to systems.

We restrict access to personal information to Holmesdale Finance employees, contractors and agents who need to know that information in order to process it for us and who are subject to strict contractual confidentiality obligations. They may be disciplined or their contract terminated if they fail to meet these obligations.

We and the other companies processing your data for the purposes mentioned in Section 4 may from time to time need to undertake some of the processing in countries outside of the European Economic Area. Different privacy laws may apply in these countries and you understand and unambiguously agree to the transfer of personal information to these countries and parties. We only make these arrangements or transfers where we are satisfied that adequate levels of protection are in place to protect any information held in that country or that the service provider acts at all times in compliance with applicable privacy laws.

If, at any time, you prefer not to receive further communications from us in any or all forms (except in connection with information, products or services that you specifically request), you will have the ability to unsubscribe from such communications by means of a link provided in every email that is sent to you by us or by contacting us.

AUTOMATICALLY COLLECTED SITE USAGE DATA

To facilitate the operation of a website, certain information is collected automatically from or about you in connection with your visit to the website or the device you are using to access the website. Servers may automatically gather site usage information (for example your IP address, information about your web browser, your device, your location (subject to consent), shopping, browsing and other such activities).

COOKIES AND SIMILAR TECHNOLOGIES

Like many companies, we (and our service providers) use cookies and other similar technologies to collect, store and track information about your Site usage. This information helps us to provide, operate, improve and personalise our Sites.

WHAT ARE COOKIES

Cookies are small files of letters and numbers. These files are stored on the hard drive of the device you are using, be it a PC, mobile phone, or tablet. These letters and numbers are used to allow a website to remember certain bits of information, so that the user experience can be improved next time you visit.By using our website you agree that we may store and access cookies on your device in accordance with this Privacy Policy.

HOW WE USE COOKIES

When you visit our website it is likely we will create cookies which are stored on your device. For the duration of your 'session' on our website these cookies help us to deliver the correct information and ensure you only have to enter required information once, thereby improving your browsing experience.

We also use web analytics to understand how many people have visited our website, what they have looked at and how they found us etc. This gives us a better understanding of how our website is working. All data accrued cannot be used to identify personal information and merely gives us a general idea of how our website performs.

This overview of the type of cookies we use is based on categories outlined by the International Chamber of Commerce, in the ICC UK Cookie Guide. Some cookies may appear in multiple categories.

Category 1: strictly necessary cookiesThese cookies are necessary for the website to function. By disabling these cookies, some aspects of a website will either not work, or not work properly, such as secure logins, location services, and e-commerce functionality.

Category 2: performance cookiesThese cookies gather information to help improve the day to day performance of a website. By analysing data collected we can enhance popular pages, fix bugs and error messages etc. All data is based on totals and averages and is strictly anonymous. For example we use Google Analytics, which creates several first-party cookies. The data that Google collects is kept strictly private and confidential and won't be shared with anyone else. We don't feel that Google Analytics is a breach of privacy as we are merely aggregating the data survey. The information that is collected is used to understand website trends and performance.

Category 3: functionality cookiesThese are cookies which provide a 'memory' for the website, this enables the website to remember any personal choices you make (for example, your username, language or geographic location). A website may provide local weather reports, traffic updates and other similar localised information. These cookies are also used to remember changes you may make to text sizes, fonts and other customisable elements of the website. The information these cookies collect may be made anonymous and can't track activity on other websites.

Category 4: targeting cookies or advertising cookiesWe nurture the use of social media websites and believe sharing is a key part of how people access new information. Social media networks are a popular way of doing this. To enable people to share information via popular social media, our website may have functionality allowing this type of activity.

The owners of social media websites may place cookies on users' devices and they will have their own cookie policies. We have no control over these companies' cookies policies.

HOW TO TURN OFF COOKIES

Most web browsers enable you to decline or block cookies (check the “Help” or “Settings” menus of your browser to learn more). It is your right to decline cookies however doing so may disable certain features within our website(s) and compromise your experience.

 

HOW YOUR INFORMATION IS USED

• The information we collect may be used in a number of ways, including:
• improving your browsing and functional experience;
• to fulfill orders and requests submitted by you;
• to contact you (via post, email, and any other method you may have chosen) with relevant information to promote our products or services or educate our users on applicable changes therein;
• to contact you if appropriate in regards to a rating or review submitted;
• where appropriate, for market research;
• to better understand you in order to provide relevant, more tailored communications on our products and services;
• protecting the security, legality or integrity of our business;
• And otherwise, with your permission or as permitted by law.

 

Any information you provide about another person will be used to fulfil your requests and treat such information in accordance with this Privacy Policy. Please refrain from providing other persons information if you do not have consent to provide and use their data for this purpose. We analyse and use information collected by our website automatically, and through cookies, beacons and other technologies, potentially in combination with personal information, to assess the activities of our users and measure the effectiveness of our website and digital marketing materials. We do this on both an individual basis and as aggregated results.

With your consent to this Policy, we may combine the information we collect online from or about you with the information we collect offline from or about you. We will not store your personal data for any purpose for longer than is necessary to fulfil our service to you or as required by law.

SECURITY

Technical and organisational security measures have been put in place to ensure any personal data in our control is suitably safeguarded. We have limited access to direct employees and authorised service providers who require such information to deliver our services and for the purposes outlined in this policy.

While we have endeavored to protect our systems, it is impossible to guarantee that any information, during transmission or while stored on our systems, will be absolutely safe from intrusion by others, such as hackers.

CHILDREN'S PRIVACY

The Site is not directed to children under the age of thirteen (13). If you are under thirteen, do not provide your personal information on or to the Site. Users who are below the age of eighteen (18) should not use the Site without permission from their parent or legal guardian.

PHISHING / SPOOFING SCHEMES

If you receive a request to provide sensitive information (including your Account password, or any payment information) via email or to a website or individual claiming to be us, that does not appear legitimate, please do not respond or disclose your information. Please immediately report any such communication or request to us at: info@holmesdalefinance.co.uk

CHANGES TO THIS PRIVACY POLICY

We reserve the right to and may change this Privacy Policy on occasion where required. In some circumstances we may instruct users of updates to our policy via a notification. Our latest Privacy Policy will be available on our website(s) and should be reviewed for the avoidance of doubt.

CONTACT US

If your require additional information about our Data Protection Officer, the specific roles of any data controllers or processors and/or you have any questions about this Privacy Policy, please email us at info@holmesdalefinance.co.uk, or in writing to:

The Data Protection Officer
Holmesdale Finance.The Byre, Pury Hill Business Park, Near Alderton, Towcester,
Northamptonshire, NN12 7LS