No Credit Scoring* Car Finance

We respect your privacy and are committed to protecting your personal data.

The information set out in this privacy policy aims to inform you as to how we collect and look after your personal data when you visit our website, [ www.thecarloancentre.co.uk ]. It will also tell you about your privacy rights and how the law protects you.

References to "you" or "your" are to you as an individual using our website or otherwise contacting us (either on behalf of yourself, your business or another individual or organisation).

THE CONTENT

WHO WE ARE
THE DATA WE COLLECT ABOUT YOU
IF YOU FAIL TO PROVIDE PERSONAL DATA
HOW WE COLLECT YOUR PERSONAL DATA
HOW WE USE YOUR PERSONAL DATA
DISCLOSURES OF YOUR PERSONAL DATA
CREDIT REFERENCE AGENCIES AND OTHER AGENCIES
OPEN BANKING
AUTOMATED DECISION-MAKING
DATA SECURITY
DATA RETENTION
YOUR LEGAL RIGHTS
CONTACT DETAILS AND COMPLAINTS

IMPORTANT INFORMATION

It is important that you read this privacy policy together with our Cookie Policy our Terms of Use and any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them.

Please note that we may update and amend this privacy policy from time to time and any changes will be posted on our website. This version was last updated on 11-APRIL-2022.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Our website may include links to third-party website, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

By accessing and continuing to use our website, you accept the terms of this privacy policy.

WHO WE ARE

The Asset Exchange Ltd (trading as ["The Car Loan Centre"] is a company incorporated in England and Wales with company number 08679485. Our registered office is 77 Wollaston Way, Burnt Mills Industrial Estate, Basildon, Essex, SS13 1DJ and is referred to as " we", "us" or "our" in this privacy policy.

We source and make available used vehicles and provide finance to our customers. We lend money to customers who may have been declined elsewhere, or would usually be declined due to issues such as poor credit histories. We sell vehicles on hire purchase finance, as well as lending money secured on vehicles ('Logbook Loans') ("Finance Package(s)"). In deciding whether to offer Finance Packages to our customers, we consider each applicant individually according to their current circumstances and ability to repay rather than just automated credit scores. We are a controller in respect of the personal information we process about you.

We also receive introductions to customers from other lenders and traders ("Introducers") via our Cash4Declines business model where the customer has been unable to secure finance from more mainstream lenders. Please note that our Introducers will be initially responsible for your personal data in connection with your original application/purchase as well as the decision to submit your details to us. The Introducer's privacy policy will apply to all such processing up to and including the introduction to us. This privacy policy will apply to any application for our Finance Packages and any vehicle purchase following such introduction.

We are bound by applicable data protection laws in respect of the handling and collection of your personal data and are registered as a data controller in England and Wales, with the Information Commissioner's Office (ICO) under the ICO number ZA020916.

If you have any questions about this privacy policy, including any requests to exercise your legal rights as set out in the 'YOUR LEGAL RIGHTS' section, please contact us using the contact details in the 'CONTACT DETAILS AND COMPLAINTS' section.

THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data) or data relating to a corporate entity.

If you visit our website, apply for an Agreement in Principle, complete our 'Request a Callback' form, or otherwise contact us to enquire about our vehicles and/or Finance Packages, of if you apply for or receive our Finance Packages, we may collect, use, store and transfer different kinds of personal data about you. Those calls are recorded for training and monitoring purposes. We have grouped together the types of personal data we may process as follows:

• Identity Data includes first name, last name, title, company position, date of birth, gender, nationality, marital status, occupation, social media profile information and voice recordings.
• Contact Data includes business or home address, billing and delivery address(es), email address(es), telephone number(s) and fax number(s).
• Financial Data includes card holder details (CHD), bank account details (account name, number and sort code).
• Identification Data includes a copy of your driving license and/or passport.
• Vehicle/Driving Data includes your vehicle registration and mileage, logbook loans, driving license information including any penalty points, details of accidents and claims (including history and those occurring whilst you are using our products/services) and, where vehicle tracking is used, your driving speed, distance travelled and current and past location tracking.
• Credit Check Data includes information necessary for us to undertake credit and other financial checks on you and assess what Finance Packages and terms would be suitable for you based upon what you can reasonably afford to pay. This may include the time you have spent at your address, occupational details, details from your income and expenditure from the bank statements you provide or that we obtain direct from your bank via Open Banking, number of dependents and adults you live with and details of your credit file received from Credit Reference Agencies such as your credit history. If you are a spouse or financial associate of someone applying for one of our Finance Packages, this may include your Credit Check Data.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, use of cookies or other devices to store and sometimes track information about you (more details on our use of cookies is set out in our Cookie Policy and other technology on the devices you use to access our website.
• Profile Data includes your username and password, purchases and orders made by you and feedback and survey responses.
• Usage Data includes information about how you use our website.
• Marketing and Communications Data includes your preferences in receiving marketing from us, or from our Introducers or other third parties and your communication preferences.

Aggregated Data. We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

Special Categories of Personal Data. This includes details about your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, health, sex life or sexual orientation.

We may process certain special categories of personal data when:

• you include such information in your CV which you send to us when you make contact with us about employment opportunities with us;
• we request medical information if you are unable to meet your repayments and we are considering forbearance (an agreement to provide you with temporary repayment relief instead of taking possession of the financed car); or
• via the operation of CCTV at our sites - for example if you have an accident in or near one of our sites which is captured by our CCTV and/or then logged in our accident book or if you are involved in criminal activity which is captured on one of our CCTV systems.

The legal basis on which we process such data will usually be your explicit consent, save for in respect of CCTV where our legal basis is legal claims and/or employment, social security and social protection law and/or vital interests.

Children. Our website is not intended for children and in this respect we do not knowingly collect data relating to children.

We do not actively collect any information about criminal convictions and offences.

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 (for example in connection with a vehicle purchase or a Finance Package) 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. In this case, we may have to suspend or cancel the purchase and/or Finance Package but we will notify you if this is the case at the time.

HOW WE COLLECT YOUR PERSONAL DATA

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact, Financial, Identification, Vehicle/Driving, Credit Check, Profile, Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email, social media or otherwise. This includes personal data you provide when you:
• complete the form on our website when applying for an 'Agreement in Principle' for a Finance Package;
• fill in our 'Request A Callback' form on our website and subsequently speak to us on the telephone;
• provide us with information when contacting us on our automated chat function (through our website);
• provide us with contact details for the purpose of finding out information on our vehicles and/or Finance Packages or request to be contacted by a member of our team;
• get in touch to request information on our vehicles and/or Finance Packages or otherwise contact us;
• apply to purchase a vehicle from us and/or take out a Finance Package;
• set up a client account with us (as a sole trader or on behalf of a corporate entity as an Introducer);
• make contact with our support team;
• contact us about your interest in a job with us; or
• give us some feedback.
• Automated technologies or interactions. As you interact with our website we may automatically collect Technical or Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy. If you agree to use a tracking device in your vehicle, we may collect Profile Data associated with that device and your vehicle use.
• CCTV. We operate CCTV in and around our sites which capture images of you. We may be able to identify you from the CCTV data. We will only use this data to prevent, detect, deter and report on crime, to protect buildings and assets from crime, to protect the health and safety of customers, prospective customers, staff and other visitors and/or to assist with criminal investigations and support law enforcement bodies.
  We use CCTV systems in this way for our legitimate interests (to prevent and detect crime), to comply with legal or regulatory obligations (to law enforcement bodies) and/or to protect the vital interests of you or another individual.
• Third parties or publicly available sources. When you apply for a Finance Package, we receive information about you from third parties and public sources as set out below:
• Identity and Financial/Credit Check Data from credit reference agencies and other credit information services to check that, where you have applied to obtain a vehicle or Finance Package from us, all the details submitted by you on your application are true and that the application has been genuinely made by you (please see the sections on 'CREDIT REFERENCE AGENCIES AND OTHER AGENCIES' and 'OPEN BANKING' for more information on this);
• Identity, Identification Data, Profile Data and Vehicle/Driving Data from the DVLA to check that all details submitted by you in your application are true, in particular in relation to your driving history;
• Identity and Vehicle/Driving Data from insurance companies, including details of accidents or claims, where we need this to deal with and manage any accidents or claims occurring whilst you are using our vehicles/Finance Packages and to receive insurance pay-outs where we are within our right to do so;
• Identity and Contact Data from Introducers and other vehicle dealers and introducers that provide us with your details in order for us to make contact to introduce you to our vehicles and/or Finance Packages (where you have provided them with consent to do so);
• Identity and Contact Data from individuals recommending, in a business-to-business context, that we make contact with you to introduce our Finance Packages to you;
• Identity, Contact (and possibly Special Categories of Personal) Data from recruitment professionals who send us your CV;
• Identity, Contact, Financial, Identification, Credit Check, Technical, Profile, Usage and Marketing & Communication Data from our Introducers based on the information they obtain from you when you access finance or our vehicles through them; and
• Technical and Usage Data from analytics providers, such as Google, Zuko and Hotjar, based in and outside the UK.

HOW WE USE YOUR PERSONAL DATA

Please note this section only summarises the purposes for which we use personal data where we are acting as a controller of personal data. Our Introducers and other introducers, credit reference agencies and your bank are responsible for determining the purposes for which they collect your personal data and will be responsible for providing you information in that respect.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Performance of Contract means processing your personal data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

• Legitimate Interest means the interest of our business in conducting and managing our business , including training and monitoring of our customer services experience, to enable us to offer you the best product and/or service and the best and most secure experience we can. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can contact us for further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities (please see the 'CONTACT DETAILS AND COMPLAINTS' section).

• Consent means where we have obtained your agreement to process your personal data. Consent must be freely given, specific, informed and be an unambiguous indication of your wishes for us to process your personal data (this may be collected by you ticking a box). Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending our newsletters and/or marketing material to you via email, post, phone, text message and social media. You have the right to withdraw consent to newsletters and/or marketing at any time by contacting us (please see the 'Opting Out / Unsubscribing', the 'Withdraw consent at any time' under 'YOUR LEGAL RIGHTS' and the 'CONTACT DETAILS AND COMPLAINTS' sections).

• Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

• Prospecting. In a business-to-business context we may make contact with individuals at other businesses (including Introducers or potential Introducers) to provide or seek information in connection with our vehicles and/or Finance Packages. The legal basis we rely on for using personal data to make such contact is our shared legitimate interests in doing business together. When we make contact with an individual, they can exercise your right to object to such contact from us (please see the 'Object to processing' section under 'YOUR LEGAL RIGHTS')

• Marketing. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established personal data control mechanisms for our business including an unsubscribe link displayed on every email newsletter and marketing communication.

  Marketing from Us

  If you provide your express, opt-in consent, we may use your Identity, Contact, Technical, Usage and/or Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which vehicles, Finance Packages and offers may be relevant for you (we call this marketing).

  You may receive marketing communications from us after you have requested information from us, purchased a vehicle, applied for or obtained a Finance Package from us, or opened a client account and, in each case, you have opted-in to receiving that marketing.

  You can withdraw your consent at any time.

  You can ask us to stop sending you marketing communications at any time (please see the 'Opting Out / Unsubscribing' section).

  Third-Party Marketing

  We will get your express opt-in consent before we share your personal data with any third party company for marketing purposes

  Opting Out / Unsubscribing

  You can ask us to stop sending you marketing messages at any time by following the unsubscribe links on any marketing message sent to you or by contacting us at any time.

  Where you opt out of receiving these marketing messages, you may still receive messages for other purposes (such as providing the services to you).

• Cookies. Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website. By continuing to browse the website, users are agreeing to our use of cookies.

  A cookie is a small file of letters and numbers that we store on your browser or the hard drive of their computer. We only use (and store) non-essential cookies on your computer's browser or hard drive if you provide your consent. For more information about the cookies we use, please see our Cookie Policy.

• Change of Purpose. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, you can contact us (please the 'CONTACT DETAILS AND COMPLAINTS' section).

  If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

  Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

DISCLOSURES OF YOUR PERSONAL DATA

For the purposes set out in the 'HOW WE USE YOUR PERSONAL DATA' section we may have to share your personal data with the following third parties:

• Third party service providers such as Perfect Data Solutions Ltd, trading as Lending Metrics (Lending Metrics) who collect and process your information in connection with such credit checks via credit reference agencies such as Equifax (see the sections on CREDIT REFERENCE AGENCIES AND OTHER AGENCIES and OPEN BANKING for more information).
• Service providers and suppliers based in (and outside) the UK who provide IT and system administration services including for example FLG 360, Bronto (Oracle Net suite) and Constant Contact, who provide Customer Relationship Management (CRM) software.
• Analytics service providers such as Google, Zuko, Hotjar and Qlik Sense, which use anonymised data from our website for analytical user behaviour purposes.
• Reputable companies such as Feefo and Trustpilot that provide consumer survey and review services to us and our customers.
• Insurance companies where we are obliged to provide Vehicle/Driving Data to them, for example if you have an accident in one of our vehicles/whilst using our Finance Packages;
• Third parties we use to help deliver our vehicles to you, such as payment service providers and delivery companies.
• Professional advisers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, legal, banking, accounting insurance and services.
• HM Revenue & Customs, regulators, law enforcement bodies, police and other authorities based in the UK who require reporting of processing activities in certain circumstances (such as criminal activity, suspected or actual fraud or tax evasion).
• Marketing and PR providers where you have agreed to a publication or article with us.
• Third party advisors for example insurance brokers where you have agreed for us to pass on your details.
• Approved and vetted asset recovery or debt collection companies, if necessary to exercise our rights.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

If you require further information on specific third party integrations in relation to your personal data, please get in contact (please see the 'CONTACT DETAILS AND COMPLAINTS' section).

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

INTERNATIONAL TRANSFERS

Where we transfer personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

If further information on the specific mechanism used by us when transferring your personal data out of the UK is required, please contact us directly (please see the CONTACT DETAILS AND COMPLAINTS section).

CREDIT REFERENCE AGENCIES AND OTHER AGENCIES

As a responsible lender, we have a legal obligation to take steps to ensure that our customers are creditworthy. We must ensure that our customers are able to afford the Finance Packages we offer them.

We use a variety of methods to try to make sure that we do not lend money to people who are in financial difficulty. One of these is to perform credit reference and identity checks on you with a credit reference agency (CRA). In order to do this, we will pass the personal data that you provide to us in your Finance Package application to a CRA called Perfect Data Solutions Limited which trades as "Lending Metrics" (Lending Metrics). Lending Metrics provide us with data about a customer's credit history and borrowing habits.

This data will include information from your credit application and about your financial situation and financial history. Lending Metrics will supply to us both public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information.

You can contact Lending Metrics at Lancaster Court, 8 Barnes Wallis Road, Fareham, Hampshire, PO15 5TU in writing to request the information that they hold about you (please note, a small statutory fee may be payable).

A condensed guide to the use of your personal information by ourselves and at Credit Reference and Fraud Prevention Agencies

1. When you apply to us take out a Finance Package, we will check the following records about you and others (see 2 below):

1.1 Our own database;

1.2 Those at 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. They supply to us both public (including the electoral register) and shared credit and fraud prevention information.

1.3 Those at fraud prevention agencies (FPAs).

We will use this information to:

• Assess your creditworthiness and whether you can afford to take out the Finance Package;
• 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.

CRAs:

2. 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 must be sure that you have their agreement to disclose information about them. CRAs 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.

3. Information on applications will be sent to CRAs and will be recorded by them. Where you borrow from us (such as where you take out a Finance Package with us), we will give details of your accounts and how you manage it/them to CRAs. 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 and FPAs to perform similar checks and to trace your whereabouts and recover debts that you owe. Records remain on file for six (6) years after they are closed, whether settled by you or defaulted.

4. Please ensure the information you provide about yourself is true as it will be checked. If you give us false or inaccurate information and we suspect or identify fraud we will record this and may also pass this information to FPAs and other organisations involved in crime and fraud prevention.

5. If you have borrowed from us and do not make payments that you owe us, we will trace your whereabouts and recover debts or the asset.

6. Your data may also be used for other purposes for which you give your specific permission or, in very limited circumstances, when required by law or where permitted under the terms of Data Protection Laws.

How to find out more

This is a condensed version and if you would like to read the full details of how your data may be used please contact us on the details in the 'CONTACT DETAILS AND COMPLAINTS' section.

You can contact Lending Metrics at the address above in writing to request the information that they hold about you (please note, a small statutory fee may be payable).

The details in this policy relating to the third parties in this section are for your information only. Further information about the CRAs, their role as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with them are explained in more detail within the Credit Reference Agency Information Notice (CRAIN) accessible from the credit reference agency's websites (see above for link).

CRAs have a legal duty to explain the purposes and legal basis for processing your personal data. Please always refer to the CRAs' privacy policies on their websites (see above) for such information. We are not responsible for the privacy policies or practices of these third party recipients of your personal data.

Other agencies:

We may provide your personal data to other agencies (including FPAs), this will be in order to help lenders such as us trace debtors, recover debt, prevent fraud and to check your identity to prevent money laundering. If you have taken out a Finance Package from us and failed to make repayments, we may trace your whereabouts and recover debts. Agencies are not permitted to keep "blacklists" nor should they give any opinion about whether or not credit finance should be granted to you - this for us to decide.

Each agency has a legal duty to explain the purposes and legal basis for processing your personal data. Please always refer to the agency's privacy policy on their website for such information. We are not responsible for the privacy policies or practices of these third party recipients of your personal data.

Accessing your file:

If you wish to see the information contained on an agency file you can do so by writing to the relevant agency. If your file contains information about you which is incorrect (or contains information about other people with whom you have no financial connection) you can request for the applicable information to be corrected, removed or have a note put on the file explaining why you think the information is wrong. The agency will not remove correct information.

OPEN BANKING

Open Banking is the secure way of providing access to your bank or building society account to providers who are registered for this purpose.

Registered providers and participating banks and building societies are listed under the Open Banking Directory.

We use Open Banking as it allows us to process loan applications efficiently, securely and in our customers' best interests. By permitting access to your bank or building society account information in this way, we are able to make a better lending decision as we shall be able to verify your income, outgoings and other matters in order to assess what loan terms would be suitable for you based upon what you can reasonably afford to repay.

Further information about Open Banking is available from www.openbanking.org.uk.

How your personal data will be processed for the purposes of Open Banking:

By proceeding with your loan application via our website you expressly consent to us sharing the details you have provided in your application for a Finance Package, which will include your personal data ("the Shared Personal Data"), with our registered Open Banking partner, Lending Metrics. Lending Metrics is also a credit reference agency. Further information about Lending Metrics including their registered provider and regulatory status is available from www.lendingmetrics.com.

Whilst completing your Finance Package application, we will ask you to choose whether you would like to provide us with copies of your bank statements or allow us to use Open Banking. You are free to choose either of these options and we will not use Open Banking unless we have obtained your consent.

If you consent to Open Banking, during your loan application we will safely and securely direct you to Lending Metrics’ secure portal ("the Portal") for the purposes of granting Lending Metrics access to your bank or building society account information ("Transaction Information").

If your bank or building society is registered to provide access under the Open Banking Directory, Lending Metrics will obtain your Transaction Information and report it back to us in the form of a completed search for us to process your loan application ("the Permitted Purpose").

Where your bank or building society have already permitted access to your Transaction Information you shall need to contact them directly in order to withdraw your consent under their particular Open Banking terms and conditions.

Data security:

Lending Metrics are registered under the Open Banking Directory as an account information service provider and are also regulated by the Financial Conduct Authority as a payment services firm under number 802599. Any data you submit via the Portal will be encrypted and its usage tracked as part of set Open Banking data security standards.

We are responsible for the secure transmission of any Shared Personal Data to Lending Metrics, for safely directing you to the Portal and for the safe receipt and usage of your Transaction Information.

You will not be required to share your banking password or log in details with either us or Lending Metrics. Once you have given your consent to proceed with Open Banking you will be directed to your own bank or building society’s login page where you will enter in your own login details directly.

Save as set out above or elsewhere in this Privacy Policy, we are not responsible for your direct data transmissions with Lending Metrics or with your own bank or building society.

How your Shared Personal Data and Transaction Information will be used

Lending Metrics shall, subject to their own terms and conditions and privacy policy, and, if your bank or building society is registered to provide access under the Open Banking Directory, obtain your Transaction Information and submit this back to us for the Permitted Purpose. By way of example, the Transaction Information that we shall receive from Lending Metrics is likely to include information relating to your income, outgoings and credit worthiness.

Lending Metrics will be entitled to re-access your Transaction Information for up to 90 days from the date of your original search result in order to refresh the search results, obtain a snapshot of your data or gather additional data.

Lending Metrics will hold the Shared Personal Data and the Transaction Information they receive and retain according to their own terms and conditions and privacy policy, available on the Portal and its website, which you will be required to read and consent to once directed their via our website.

As Lending Metrics is also a credit reference agency they may also share and keep a record of your Shared Personal Data and Transaction Information.

Will you use my Transaction Information data for any other purpose?

The Transaction Information we receive about you will only be used for the Permitted Purpose. We do not sell or share Transaction Information with any third party.

Save as set out above the information contained in the rest of this Privacy Policy deals with how we collate, use, transfer, store, delete and other terms applicable to your personal data including Shared Personal Data and Transaction Information.

Do I have to provide you with my consent to proceed?

You will be given the choice during your application for a Finance Package as to whether you wish to proceed using Open Banking or whether you wish to obtain the relevant Transaction Information yourself and provide it to us.

Where your bank or building society have already permitted access to your Transaction Information you shall need to contact them directly in order to withdraw your consent under their particular Open Banking terms and conditions.

Your legal rights:

Your individual data protection and privacy rights set out in the section, 'YOUR LEGAL RIGHTS', below continue to apply for the personal data we process via Open Banking.

Lending Metrics has a legal duty to explain the purposes and legal basis for processing your personal data, as does your bank or building society. Please refer to your bank and building society and Lending Metrics' privacy policy on their website for such information. We are not responsible for the privacy policies or practices of these third party recipients of your personal data.

AUTOMATED DECISION-MAKING

When assessing your suitability for a Finance Package, we may use automated decision-making facilities. For this purpose, we use a software called 'Automated Decision Platform' (ADP) licensed to us by Lending Metrics. We may submit your personal data to the ADP and Lending Metrics may process it on our behalf in accordance with our instructions. Such data may include Identity Data, Contact Data, Identification Data, Financial Data, Credit Check Data, Transaction Information obtained via Open Banking, and any other information or documents you have submitted as part of your Finance Package application. We do not make a decision solely by automated means without any human involvement in the decision-making process. We personally evaluate the decision-making undertaken by the ADP and make the final decision as to whether a Finance Package is suitable for you.

DATA SECURITY

We are SOC 2 certified, and we have put in place appropriate security measures (including SSL and SMB technology and dual-factor authentication) to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

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

Please contact our IT security team using the email securityops@thecarloancentre.co.uk if you require further information on our Security Policy and for the specific security measures we have in place.

DATA RETENTION

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

• Where we have entered into an agreement with you, we will generally retain your data for a period of 6 (six) years after a contract has ended, to ensure that we are able to assist you should you have any questions or feedback in relation to our vehicles and/or Finance Packages or to protect, or defend our legal rights, or for tax purposes.
• Where we have processed your personal data to provide you with marketing communications with consent, you will be regularly given the option to opt out of such marketing. If you tell us that you no longer wish to receive such communications, your personal data will be removed from our marketing lists (but will be added to a "do not contact" list).
• Where you have applied for a Finance Package with us but your application does not proceed, we will hold the data you have provided as part of that application for three (3) years from the date of the application withdrawal.
• Where you exercise your right to withdraw from an agreement with us within the first 14 (fourteen) days, we will hold your data for three (3) years from the date of withdrawal.
• Where we have processed your data for any other reason (such as where you have contacted us with a question in connection with services or in relation to recruitment), subject to the remainder of this section we will retain your data for 12 (twelve) months.

Data from CCTV cameras will not be retained indefinitely but will be permanently deleted once there is no reason to retain the recorded information. Exactly how long images will be retained for will vary according to the purpose for which they are being recorded. For example, where images are being recorded for crime prevention purposes or requested by a law enforcement body, data will be kept by them for as long as they need it. In all other cases, recorded images will be kept for no longer than 30 (thirty) days. We will maintain a comprehensive log of when data is deleted.

In some circumstances you can ask us to delete your data; please see section 'Request erasure of your personal data ' under ' YOUR LEGAL RIGHTS' for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are detailed below:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above and you are the customer of our Introducers you should direct your request to that Introducer. If you wish to exercise any of the above rights in respect of the personal data we are responsible for, please contact us directly (please see the 'CONTACT DETAILS AND COMPLAINTS' section).

• No fee usually required. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
• What we may need from you. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
• Time limit to respond. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

CONTACT DETAILS AND COMPLAINTS

Our full details are:

You have the right to make a complaint at any time to the ICO, the UK supervisory authority for data protection issues (ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.