privacy

Scott Motor Finance Privacy Policy  

Introduction

This notice explains who we are and why and how we use your information.


Scott Motor Finance Limited (we, us, our, Scott Motor Finance) is the data controller. We are registered with the Information Commissioner's Office with registration number: ZA673866 (which can be viewed here)


This Privacy Notice explains in detail the types of personal data we may collect about you. It also explains how we’ll store and handle that data, and keep it safe.


We know that there’s a lot of information here but we want you to be fully informed about your rights, and how Scott Motor Finance uses your data. For example, we will explain things such as our credit checking procedure and how we combine data to build a picture of you.


We hope the following sections will answer any questions you have but if not, please do get in touch with us.

It’s likely that we’ll need to update this Privacy Notice from time to time and will publish updates on our website. 

1. How we use your information

We use information about you (both provided by you and collected from third parties) to provide our services to you and in the normal administration and operation of our business. 


We will use your information to: (i) process your loan application; (ii) perform our contract with you and manage your account(s) with us and to send you statements; (iii) provide our services to you; (iv) where your preferences permit, contact you in relation to our other products and services; (v) check your identity and undertake vetting of you and your circumstances in relation to your application (as described in more detail in section 4); (vi) register your repayments with credit reference agencies (as described in more detail in section 4); and (vii) where justified in the pursuit of our legitimate interest, undertake research, assessment and analysis (including credit and/or behaviour scoring, market research etc) to enable us to develop and improve our services to you and other customers and to protect our interests.


We will store and process your information on our secure servers and in any other way we need to so that we can carry out the activities described in this Privacy Notice.

2. What information we use

We use information about you, including financial information, to help us decide whether to offer you a loan, and if so, to provide you with our services. We use other information collected about you, including your use of our website, for a range of business purposes. 


By “your information” we mean personal and financial information about you that we obtain: (i) from you directly as part of your application for a loan and in the creation of your account; (ii) from third parties, such as credit reference agencies (who may search the Electoral Register), fraud prevention agencies or other organisations; and/or (iii) information we gather during our contract with you, for example about the way you use and manage your account(s) with us (including from the transactions and payments made to your account with us).


The types of information we normally use include:


  • your name, address, date of birth and contact details (which may include your email address and telephone number);
  • information about your employment, residential status and financial position;
  • information about your existing credit commitments, previous borrowing and credit rating and how you manage your repayment history;
  • information collected about your visits to and use of our website (see our Cookies Notice for further details); and
  • information you provide us during the course of our relationship with you about your needs, requirements or changes in your circumstances.


We do not routinely collect special categories of information (which may include information about your mental and physical health). However, sometimes this may be necessary to adapt our services to your needs or in order to ensure that we treat you fairly. We will only record this information where it is necessary and where you (or someone you have appointed to act on your behalf) provide express consent for us doing so.


Failure to provide information when requested by us may impact on our ability to provide our services to you (such as our ability to offer you a loan, or to ensure our collections activity is adapted to your needs).


We will monitor and/or record telephone calls from and to you in the interests of customer service and for training purposes.


Automated processing and decision taking


We may perform automated processing (i.e. processing that is carried out without human intervention) on your personal information, to evaluate certain things about you. In particular, we may do this to analyse or predict (amongst other things) your economic situation, credit history, age, personal preferences, interests or behaviour. This could mean that automated decisions (i.e. decisions that are made without human intervention) are made about you using your personal information. For example, if you do not meet an element of our lending criteria (such as being over 18 or being a resident in the UK) any application for credit will be automatically declined. If you do meet our lending criteria, the amount we lend, the term of your loan and the interest we charge on your loan will be determined by your credit status.

3. Third parties with whom your information may be shared

We may share your information with people who provide us with services and help us run our business. We may also share it with Credit Reference Agencies and our regulators. 


We may share information about you with: (i) credit reference and fraud prevention agencies; (ii) people who provide a service to us or act on our behalf (which will include third parties engaged to provide customer, technical, or operational support, handle payments, host our services, or provide us with legal advice and accountancy services) on the understanding that (and subject to contractual terms which require that) they will keep the information confidential and handle your personal information solely in accordance with our instructions; (iii)any third party who introduced you to us so that they can contact you and for their own accounting and administration purposes; and (iv) anyone to whom we transfer or may transfer all or part of our business and its assets, including our rights and duties under your credit agreement(s) with us.


We may also give out information about you if we have a duty to do so or if the law requires or allows us to do so.

4. Our use of credit reference agencies and fraud prevention agencies

We collect information about you and may share information with Credit Reference Agencies to assess your application and during the course of any loan you have with us. 


When you apply for a product from us you confirm that all the information you have given to us is true and complete. We will make checks with credit reference agencies and fraud prevention agencies in order to assess your application for credit. Where your application is approved and you enter into a credit agreement with us we may also make periodic searches at credit reference agencies and fraud prevention agencies to enable us to manage your account with us. Although these further searches will be added to your credit record, they will not be shared with others. Law enforcement agencies may also access and use this information. When credit reference agencies receive a search from us they will add details of our search and your application to your credit records that may be seen by other lenders. A large number of applications within a short period of time could impact your ability to obtain credit. We will use a credit scoring or other automated decision making system when assessing your application (in particular in relation to assessing your creditworthiness and the affordability of your proposed loan). Credit reference agencies supply to us public information (including the Electoral Register), shared credit information and fraud prevention information. The identities of the credit rating agencies, and the ways in which they use and share personal information, are explained in more detail at the following links:


TransUnion: www.transunion.co.uk/crain

Equifax: www.equifax.co.uk/crain

Experian: www.experian.co.uk/crain


Once you have an account with us, we will give details of your accounts and how you manage it/them to credit reference agencies. If you borrow from us and do not repay in full and on time, or otherwise break the terms of your agreement with us, we will register such information with credit reference agencies who will record the outstanding debt. This information may be supplied to other organisations by credit reference agencies and fraud prevention agencies to perform similar checks and to trace your whereabouts and recover debt that you owe.


The personal information we have collected from you will 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. Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights are set out in this Notice and are available on request. You can also find out more about how Fraud Prevention Agencies handle your information at www.cifas.org.uk. If false or inaccurate information is provided and fraud is identified, details will be passed to fraud prevention agencies. Law enforcement agencies may access and use this information.


We and other organisations may also access and use this information to check your identity and to prevent fraud and money laundering, for example, when: checking details on applications for credit and credit related or other facilities; managing credit and credit related accounts or facilities; tracing debtors and recovering debt; checking details on proposals and claims for all types of insurance, checking details of job applicants and employees and for any other purpose for which you give your agreement. We and other organisations may access and use from other countries the information recorded by fraud prevention agencies.


5. International transfers of your information

We do not normally transfer information outside of Europe. Where we work with a service provider who does, we will always endeavour to ensure there are proper protections in place. 


We will not normally transfer your data outside of the EEA.


If any of the third parties described above are located in, or may otherwise transfer your information to, another country (which may be outside the European Economic Area (the "EEA")) we will make sure that they agree to apply the same levels of protection as we are required to apply to information held in the UK, and to use your information only for the purpose of providing the service to us. We will always take steps to ensure that any international transfer of information is carefully managed to protect your rights and interests and we will (i) only transfer your personal data to countries which are recognised as providing an adequate level of legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights; and/or (ii) endeavour to ensure that such transfers by third parties are protected by appropriate contractual commitments. You have the right to ask us for more information about the safeguards we have put in place as mentioned above. Contact us as set out in paragraph 11 if you would like further information.



6. How long we may retain your information for

We only keep your information for as long as is necessary for the purpose that it is being used. Where you have a loan with us we may keep some information about you for six years after the end of your agreement (plus a further one year to review the data). 


We endeavour to ensure that personal information is kept as current as possible and that irrelevant or excessive personal information deleted as soon as reasonably practicable. However, some personal information may be retained for varying time periods in order to comply with legal and regulatory obligations and for other legitimate business reasons. We will generally retain your personal information only so long as it is required for purposes for which it was collected. This will usually be the period for which we provide you with our services plus the length of any applicable statutory limitation period following that time (normally six years from the end of our agreement with you plus a further one year for review). We may keep some specific types of data, for example, tax records, for different periods of time, as required by applicable law or where it is necessary for the purpose of managing our legal risks. You can contact us (using the details set out below) for more information.



7. The legal basis on which we use your information: paragraph

We only use your information in a way that is lawful. Normally we are using it because we need to so that we can perform a contract with you, to comply with the law, for a legitimate business need or, if none of those reasons applies, where you have given your consent. 


We only use your personal information for the purposes described above where we are satisfied that:


7.1 our use of your personal information is necessary to perform a contract or take steps to enter into a contract with you (e.g. to provide you with your loan, our customer assistance and/or our technical support), or;


7.2 our use of your personal information is necessary to comply with a relevant legal or regulatory obligation that we have (e.g. we can pass on details of people involved in fraud or other criminal activity affecting Scott Motor Finance to the appropriate law enforcement/government agency); or


7.3 our use of your personal information is necessary to support legitimate interests that we have as a business (for example, to maintain and improve our services by identifying user trends and the effectiveness of our services and identifying technical issues with our services, such as our website), provided it is conducted at all times in a way that is proportionate, and that respects your privacy rights.


7.4 you have provided your consent to us using your personal information for that purpose (e.g. to provide you with promotional or marketing content)



8. Your rights in relation to your information

You have a number of legal rights in relation to your information, including to opt out of direct marketing, ask for a copy of your information or ask for it to be corrected. 


Depending on the lawful basis for which we use your personal information (as described above), you have various rights in relation to your information and the way in which we use it. Those rights may include the following:-


8.1 Right to access your information - You have a right to request that we provide you with a copy of your personal information that we hold and you have the right to be informed of; (a) the source of your personal information; (b) the purposes, legal basis and methods of processing; and (c) the entities or categories of entity to whom your personal information may be transferred


8.2 Right to rectify or erase - You have a right to request that we rectify inaccurate personal information and we may seek to verify the accuracy of the personal information before rectifying it. You can also request that we erase your personal information in limited circumstances where (i) it is no longer needed for the purposes for which it was collected; or (ii) you have withdrawn your consent (where the data processing was based on consent); or (iii) following a successful right to object; or (iv) it has been processed unlawfully.


8.3 Data portability - where we are relying upon your consent or the fact that the processing is necessary for the performance of a contract to which you are party as the legal basis for processing, and that personal information is processed by automatic means, you have the right to receive all such personal information which you have provided to us in a structured, commonly used and machine-readable format, and also to require us to transmit it to another controller where this is technically feasible.


8.4 Right to restriction of processing - you have the right to restrict our processing of your personal information where: (i) you contest the accuracy of the personal information until we have taken sufficient steps to correct or verify its accuracy;(ii) where the processing is unlawful but you do not want us to erase the data;(iii) where we no longer need the personal information for the purposes of the processing, but you require them for the establishment, exercise or defence of legal claims; or (iv) where you have objected to processing justified on legitimate interest grounds (see below) pending verification as to whether we have compelling legitimate grounds to continue processing. Where personal information is subjected to restriction in this way we will only process it with your consent or for the establishment, exercise or defence of legal claims.


8.5 Right to withdraw consent - where you have provided us with your consent to process data, you have the right to withdraw such consent at any time. In the case of email marketing communications, by following the unsubscribe link. Please note that when you withdraw your consent this will not affect any use of your data based on your consent which occurred prior to the point your consent was withdrawn.


8.6 Right to object to processing justified on legitimate interest grounds - where we are relying upon legitimate interest to process data, then you have the right to object to that processing. If you object, we must stop that processing unless we can either demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or where we need to process the data for the establishment, exercise or defence of legal claims. Where we rely upon legitimate interest as a basis for processing we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.


8.7 Rights to object to profiling and automated decisions - you have a right not to be subject to automated decisions which have a legal effect and to be protected by safeguards in respect of any profiling.


8.8 You can exercise your rights described above by writing to us, by sending an email to customerservices@scottfmotorfinance.co.uk or by telephone by calling 03330 144 562. You can also request details of the credit reference and fraud prevention agencies we use by contacting us using the details above or writing to Head of Customer Services, Scott Motor Finance Ltd., Suite 3/1, Skypark 3, 14 Elliot Place, Glasgow, G3 8EP or by emailing customerservices@scottmotorfinance.co.uk .


We will always respond to requests promptly and usually within one month. Normally no fee will be payable. However, if your request is excessive, repetitive or manifestly unjustified we may (i) refuse your request or (ii) ask you to pay a fee which reflects our reasonable administrative costs. If your request is particularly complex we may take up to 3 months to respond (but will always let you know if this is going to be the case).


9. How we protect your personal data:

We do our best to make sure that your data is kept safe and implement appropriate technical and organisational measures to prevent loss or unauthorised access or disclosure. 


We know how much data security matters to all of our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.


We secure access to all transactional areas of our websites using leading encryption technology like HTTPS and Transport Layer Security.


Access to your personal data is password-protected, and sensitive data (such as payment card information) is secured using leading encryption technology like HTTPS and Transport Layer Security.


We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.



10. Contacting the Regulator

You have a right to complain to the Information Commissioner's Office if you are unhappy about how we are using your data.


- If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.


You can contact them by calling 0303 123 1113 or go online to www.ico.org.uk/concerns (opens in a new window; please note we can't be responsible for the content of external websites).

11. Cookies

We and our trusted partners use cookies and other technologies in our related services, including when you visit our Site or access our services. 

A "cookie" is a small piece of information that a website assigns to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier. Cookies are also used to help make sure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our Services. 

The Site uses the following types of cookies:

a. 'session cookies' , which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed; 

b. 'persistent cookies', which are read only by the Site, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in; 

c. 'third-party cookies' , which are set by other online services who run content on the page you are viewing, for example by third-party analytics companies who monitor and analyse our web access.

Cookies do not contain any information that personally identifies you, but Personal Information that we store about you may be linked, by us, to the information stored in and obtained from cookies. You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our Site may not operate properly and your online experience may be limited.

We use a tool which is based on the Snowplow Analytics technology to collect information about your use of the Site. The tool collects information such as how often users access the Site, which pages they visit when they do so, etc. The tool does not collect any Personal Information and is only used by our Site hosting and operating service provider to improve the Site and services.

12. How to contact us

If you would like to contact us, you can find our contact details below.


We hope this Privacy Notice has been helpful in explaining how we handle your personal data and your rights to control it.


If you have any questions that haven’t been covered, please contact our Compliance team at compliance@scottmotorfinance.co.uk , or by post addressed to Compliance, Scott Motor Finance Ltd, Suite 3/1 Skypark 3, Elliot Place, Glasgow G3 8EP or by telephone on 03330 144 562.


Last Modified 01/08/2022


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