USE OF YOUR INFORMATION
We are MotoNovo Finance Limited, a subsidiary of Aldermore Group PLC and part of the FirstRand Banking Group. We are registered in Wales under number 11556144, and our Registered Office address is One Central Square, Cardiff, Wales, United Kingdom CF10 1FS. In this policy when we use terms such as “we”, “us” and “our”, we mean MotoNovo Finance Ltd.
We can be contacted by telephone on 0333 200 0030 or email email@example.com. Our Data Protection Officer can be contacted by post at our Registered Office address or by email at DPO@motonovofinance.com.
WHAT IS THE PURPOSE OF THIS DOCUMENT?
This policy applies to personal data processed by or collected on behalf of MotoNovo Finance Limited. We may collect information from you when you visit our website, apply for finance, contact us or receive a communication from us relating to your service.
MotoNovo Finance Ltd is a “Data Controller”. This means that we make decisions about how and why we use your personal data. We are responsible for making sure that your personal data is used in accordance with applicable data protection laws and are required by law to give you the information in this policy.
On occasions there may be other Data Controllers involved in processing your data as further explained in this policy, or as you may be advised at the time your information is to be processed.
You will see at the end of this policy that we mention the privacy notices of Fraud Prevention Agencies and Credit Reference Agencies. We do need to share these with you. Please read them carefully and contact those organisations if you have questions (their details are in their notices).
This policy was updated in May 2019. We reserve the right to change the policy at any time, so please check back regularly to keep informed of updates to this policy.
WHAT WE COLLECT AND PROCESS
We will collect and process the following personal data about you:
Information you give us, or provide to your Motor Dealer or Finance Broker when making an application (Submitted Information): The information comprises :
- Your name
- Date of birth, (so that we can, for example, make sure that you are eligible to apply for the product and it is suitable for you)
- Residential address and address history for the last three years,
- Contact details such as email address and telephone numbers
- Details about you that are stored in documents in different formats, or copies of them. This could include things like your passport, driving licence or banking documents, if these are necessary for us to comply with our legal and regulatory requirements
- Financial information
- Employment details, to include your salary, employer name, address and time period
- Some special categories of personal data such as information about your health.
Information we receive about you from third parties (Third Party Information) may include:
- Your personal and financial information (from your Motor Dealer, Finance Broker, your employer, your bank, or other person connected with your finance application)
- Information about the vehicle you are purchasing
- Credit information, such as previous applications, the conduct of accounts in your and your financial associate’s name (this is anyone linked to you for credit or finance purposes), any business accounts you may have
- Fraud prevention information, and
- Public information including County Court Judgments, bankruptcies and the Electoral Register.
Information we collect about you and your device (Device Information): Each time you use our website we will automatically collect technical information about your computer or other internet connected device including your internet protocol (IP) address browser type, domain names, access times and referring web site addresses. You may be able to disable the collection of some of this data through amending the web settings of your device or browser but doing so may impact the functionality of our website. Full details of our Cookies Policy can be found below this policy.
When you phone us or we phone you: (Call Information): We may monitor and record calls made to us, or we make to you, for monitoring and training purposes and to improve the services we offer. We will also use your personal data to verify your identity if you get in touch with us.
We may combine the above categories of information and may use these categories of information and the combined information for the purposes set out below.
 If you are an individual this will be your personal data. For a corporate entity, this “Use of your Information” notice will only apply to the directors or officers’ personal data.
HOW WE USE THE INFORMATION WE COLLECT ABOUT YOU
Processing necessary to perform our contract with you, or for taking steps prior to entering into it during the application stage:
- Administering and managing your account and associated services, updating your records, tracing your whereabouts to contact you about your account and doing this for the recovery of debt
- Sharing your personal data with certain third-party service suppliers such as payment service providers
- All stages and activities relevant to managing your account including enquiry, application, administration and management of accounts
- To manage how we work with other companies that provide services to us and our customers.
- To manage fees, charges and interest due on customer accounts
- To exercise our rights set out in agreements and contracts.
Processing necessary to comply with our legal obligations:
- To carry out identity checks, anti-money laundering checks and checks with Fraud Prevention Agencies pre-application, at the application stage and periodically after that. Where you have been introduced to us by a broker or other intermediary they may do these searches on our behalf
- For compliance with laws that apply to us
- For establishment, defence and enforcement of our legal rights
- For activities relating to the prevention, detection and investigation of crime
- To carry out monitoring and to keep records
- To deal with requests from you to exercise your rights under data protection laws
- To process information about a crime or offence and proceedings related to that (in practice this will be relevant if we know or suspect fraud).
Where we consider that, on balance, it is appropriate for us to do so, processing necessary for the following legitimate interests which apply to us and in some cases other organisations are:
- Administering and managing your account and services relating to that, updating your records, tracing your whereabouts to contact you about your account, and doing this for recovering debt
- To test the performance of our products, services and internal processes
- For management and audit of our business operations including accounting
- Recovery and sale of debt
- To carry out searches at Credit Reference Agencies pre-application, at the application stage, and periodically after that. Where you have been introduced to us by a broker or other intermediary they may do these searches on our behalf
- To carry out monitoring and to keep records
- To administer our good governance requirements and those of other members of our Group
- For market research ,analysis and developing statistics
- Marketing activities including customer service surveys; profiling of your data for marketing purposes (where we use profiling for marketing purposes this would be to contact you about similar products that may be of interest to you); analysis of our customer database to understand our customer’s activities and preferences, and to improve our services to you
- Sharing your personal data with third-parties including Motor Dealers where a legitimate interest is considered to be present
- For some of our profiling and other automated decision making, in particular where this does not have a legal effect or otherwise significantly affect you.
Processing with your consent:
We may also from time to time ask you for your consent for other purposes, which we will explain to you at the time. For example, when you request that we share your personal data with someone else and consent to that
For some of our processing of special categories of personal data such as about your health (and it will be explained to you when we ask for that explicit consent what purposes, sharing and use it is for.)
Processing for a substantial public interest under laws that apply to us where this helps us to meet our broader social obligations such as:
- Processing of your special categories of personal data such as about your health or if you are a vulnerable customer
- Processing that we need to do to fulfil our legal obligations and regulatory requirements
- When we share your personal data with other people and organisations such as members of our Group if they need to know that you are a vulnerable customer and your relatives, social services your carer or the person who has power of attorney over your affairs.
WHO MIGHT WE SHARE YOUR DATA WITH
In order to provide our services, there will be times when we will share your data. We may share your personal information with these organisations:
- Members of the FirstRand Group, including Aldermore Bank PLC
- Contracted third-party suppliers acting on our behalf, including without limitation, Sterling Client Services Ltd, Covea Insurance, Red Sands Insurance (Europe) Ltd and our service, system, support and outsourcing providers including without limitation ,i-Vendi Ltd, Core, Performance Bonus and Flexys.
- Collection and Debt Recovery Agents
- Motor Dealers
- Retailers and Manufacturers of Goods relating to your agreement
- Regulatory bodies, fraud prevention and law enforcement agencies
- Agents and advisers who we use to help run your accounts and services, collect what you owe, and explore new ways of doing business
- Any party linked with you or your business’s product or service
- Companies we have a joint venture or agreement to co-operate with
- Companies that we introduce you to
- Market researchers
- Companies you ask us to share your data with
- If you use direct debits, we will share your data with the Direct Debit scheme.
Sharing where we are obliged under a legal obligation
We will disclose your personal data in order to comply with any legal regulations or good governance obligations, or to enforce or to protect our rights, property, or safety, or that of our customers or other persons with whom we have a business relationship. This includes exchanging information (which may include information relating to debts which are owed to you and the related debtors) with other companies and organisations for the purposes of fraud protection, credit insurance and credit risk reduction.
Credit checking, verifying your identity and preventing fraud and money laundering
We will use certain personal data you have provided to us in order to confirm your identity and to prevent fraud and money laundering, and to carry out credit checks on you by searching at credit reference agencies who will supply us with credit information about you. More details about these checks are set out below.
When we use your personal data for these purposes we do so on the basis that we have a legitimate interest in assessing your application, making decisions about whether you can afford to take the product or if the product is appropriate to your circumstances, preventing fraud and money laundering, to trace and recover debts, and to verify identity, in order to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the services or financing you have requested, and we will not be able to process your application without undertaking these checks.
Credit Reference Agencies
We will supply certain of your personal information to credit reference agencies and they will give us information about you. This will include information from your credit application and about your financial situation and financial history. Credit reference agencies will supply to us both public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information.
We may also, where another person is acting as a guarantor, check the record of that person, and, if you are a director or partner in a small business, we may also check on your business. so you should make sure you discuss this with them, and share with them this information, before lodging the application.
If you are financially linked to another person (for example if you have a joint mortgage or loan) your credit reference agency records will be linked until such time as you or your partner successfully files for a disassociation with the credit reference agencies to break that link. If you are financially linked to another person, this application may impact on their credit record (and their record could impact your application) so you should make sure you discuss this with them, and share with them this information, before lodging the application.
Whether or not this application proceeds, the credit reference agency will place a record of our searches on your credit file (commonly referred to as a "footprint"). These records (but not our name) will be seen by other organisations when you apply for credit in the future. A large number of applications within a short period of time could affect your ability to obtain credit.
In the event that your application is successful, we will record information about you with the credit reference agencies concerning your agreement with us, including the details of your agreement with us, the payments you make under it, any default or failure to keep its terms and any change of name or address. The information that we provide shall remain on the credit reference agencies' file for six (6) years after your account with us is closed, whether settled by you or upon default. This information may be supplied to other organisations by the credit reference agencies.
Fraud Prevention Agencies
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. For further details of the fraud prevention agencies we use please contact us on the details at the top of this policy.
We, and fraud prevention agencies, may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime. Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six (6) years.
Other third parties
Should your application with MotoNovo Finance Ltd be unsuccessful we may pass your application details to another finance company, we will let you know who that is prior to passing your information to that company or credit broker, to help fulfil your lending requirement. That company will obtain their own credit reference and fraud prevention searches.
We provide the Motor Dealer supplying the vehicle with access to your information up to the point that your finance agreement is executed with us, to facilitate your application for finance. Motor Dealers may also be provided with further information during the life of your agreement including the results of customer surveys, to aid with customer experience improvement and information regarding your finance agreement for the purpose of account management.
We may also transfer our rights under your agreement to third parties (who will be chosen by us based upon carefully selected business criteria, including their treatment of personal data) which may mean that they become your creditor under our agreement with you. If we do this, to enable them to exercise their rights and/or administer the agreement with you we will need to transfer to them your personal data but we will only transfer such data as is necessary for those purposes, and you will be informed of their identity at the time of the transfer. We will ensure that any such third parties safeguard the security of your data in accordance with the Data Protection Act 2018 (the “Act”) and may replace the Act.
We may disclose your details and/or transfer your data to third parties to whom we propose to transfer our rights under this agreement and/or sell the vehicle/equipment, who may use your details for the purposes set out in this statement. We may also disclose the settlement figure, in relation to your agreement, to a supporting Dealer of ours who is not the Dealer who introduced the agreement to you, but is a Dealer whom you have approached in connection with a new finance deal.
We may also share your personal data with any person (and their or our professional advisors for this purpose) with whom we are negotiating any sale, transfer or re-organisation of our business or where we are organising our commercial funding. If this proceeds, the acquiring party or part of it may use your personal details in the same ways and for the same purposes as set out in this policy. We will give you their details once the business change has been completed.
Pursuant to the above, personal data may be transferred to recipients located in countries outside the European Economic Area (including the USA) which do not provide the same standard of data protection laws as the UK. Any party who receives personal data is required by us to have appropriate technical, organisational and security measures in place to keep such personal data confidential and secure. 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.
As part of the application process we may use credit scoring or other automated decision making systems to assess your application. This will use data from credit reference agencies in relation to your existing credit agreements combined with our internal demographic rules to give a credit assessment score. The final score is then used to assess your financial circumstances and ability to repay your finance with us; and is necessary to assess your application to enter into the contract.
We may also automatically decide that you pose a fraud or money laundering risk if our processing reveals your behaviour to be consistent with that of known fraudsters or money launderers, or is inconsistent with your previous submissions, or you appear to have deliberately hidden your true identity. Currently, our fraud risk assessment process includes manual decision making, using automated processing as one of the tools assisting in such assessment.
You have rights in relation to automated decision making, including the right to ask us to make a manual assessment of your application: if you want to know more please contact us using the details above.
CONSEQUENCES OF PROCESSING
If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services or financing you have requested, or to employ you, or we may stop providing existing services to you.
A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you. If you have any questions about this, please contact us on the details above.
Where we have a legitimate interest to provide marketing information to you, and in compliance with the requirements of the Privacy and Electronic Communications Regulations (PECR) we will process your personal data for the purposes of providing marketing information about our goods and services to you via the media that you choose (if any). You can change your preferences at any time by contacting us at firstname.lastname@example.org
Before we send you marketing information in relation to other financial products and services during and after the term of your agreement (see below), we may complete ad hoc credit searches against your file; to ensure we only send you appropriate offers that will be of interest to you and would typically be available to you. This will leave a quote record on your credit file (commonly known as a "soft search"), only visible to you and us and does not affect your credit profile.
DATA RETENTION AND STORAGE
All personal data you provide to us, or which we obtain from third parties, will be stored on our secure servers (or those of third parties or contractors we engage to help us run our business). We will keep information no longer than we need to for the purpose for which we collected it. The period of time for which we keep personal data depends on the legal and regulatory requirements, the purpose for which the information was obtained, and our business needs.
We will keep information about any account you hold with us for [at least] the duration of your agreement and the period of six (6) years from the end of your agreement, in line with our data retention policy that stipulates the timescales in line with our lawful purpose for processing your data.
If your application is declined, we shall keep your personal data for five (5) years in accordance with Anti Money Laundering legislation requirements (Credit Reference Agencies may keep your data for longer).
You have the rights (subject to certain statutory exemptions) to:
- Opt-out of receiving marketing information, or withdraw your consent to receive marketing information if provided on a previous occasion
- Be informed about the processing of your personal data (this is what this statement sets out to do)
- Have your personal data corrected if it’s inaccurate and to have incomplete personal data completed
- Object to processing of your personal data
- Withdraw your consent to processing your personal data
- Restrict processing of your personal data
- Request to have your personal data erased under certain conditions
- Request access to your personal data and information about how we process it
- Specify which credit reference agencies we have shared your personal data with;
- Move, copy or transfer your personal data (“data portability”), and
- Enact rights relating to automated decision making.
If you are unhappy about how your personal data has been used you can contact us using the details above. You also have a right to complain to the Information Commissioner's Office (https://ico.org.uk), which regulates the processing of personal data.
- Would like more information about how we process personal data
- Are unable to access of any of the links or further information referred to in this document , or
- Would like to exercise any of your data protection rights.
Please contact us at DPO@motonovofinance.com.
CREDIT REFERENCE AGENCY INFORMATION NOTICE
The Credit Reference Agencies we use have produced a Credit Reference Agency Information Notice ("CRAIN") which details how they will use your data after we provide them with your Agreement information. The CRAIN is available at www.experian.co.uk/crain; www.equifax.co.uk/crain.html or www.callcredit.co.uk/crain.
The MotoNovo Finance Web site use "cookies" to help you personalise your online experience. A cookie is a text file that is placed on your hard disk by a Web page server. Once set, it can be accessed by that website, and potentially some other computers from time to time. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.
One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalise MotoNovo Finance pages, or register with MotoNovo Finance site or services, a cookie helps MotoNovo Finance to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and soon. When you return to the same MotoNovo Finance Web site, the information you previously provided can be retrieved, so you can easily use the MotoNovo Finance features that you customised.
Cookies have a lifetime. Those that only last until you close your browser are known as "session cookies". Cookies that last longer (for example, so that a website can recognise you when you return) are known as "persistent cookies" Cookies set directly by a website owner (like us) are generally known as "first party cookies". However, many websites nowadays also use bits of hidden technology provided by other people (for instance, in online advertising). These other people may also set cookies when you use a website and such cookies are generally known as "third party cookies". If you want to know more, we suggest you read this site (however please note that we are not responsible for other people's sites).
To find out what cookies we use on each of our websites and why please see the table below.
We use slightly different cookie combinations depending on which of our websites you are using. The tables set out which cookies we use for which websites together with an overview of why we use them.
|Cookie||Name||First or third party cookie||Session or persistent (+ expiry date)||Purpose||More information|
|Google Analytics||_utma_utmc_utmz||Third party - Google||Persistent (_utma expires after 2 years; _utmc expires when the browser is closed; _utmz expires after 6 months||These cookies are used to collect information about how visitors use our site. ||Click here for an overview of privacy at Google|
|Motonovo site preference||Motonovo||First party||Persistent (this cookie expires after 7 days)||This cookie is used to record the user's designation; either Customer or Dealer. |
|Motonovo Website Secure Session||ASP.NET_SessionId||First party||Session (this cookie is deleted when you close your browser).||This cookie is essential for the operation and navigation of the website.||Visit the Microsoft website|
|MotoNovo Website Secure Session||MotoNovoSession||First party||Session(this cookie is deleted when you close your browser).||This cookie is essential for the operation and navigation of the website.|
|Motonovo Website Session||PHPSESSID||First party||Session (this cookie is deleted when you close your browser).||This cookie is essential for the operation and navigation of the website.|
|MyCarLocator site search data||MyCarLocator||First party||Persistent (this cookie expires after 1 month)||This cookie is used to record the user's postcode and distance data.|
|MyCarLocator Website Session||ASP.NET_SessionId||First party||Session (this cookie is deleted when you close your browser).||Visit the Microsoft website|
|Canddi Prospect Analytics||_CAN_SId_CAN_BId||Third party||Persistent (expires after 10 years)||These cookies are used to collect information about how visitors use our site, so we can compile reports and to help us improve the site.||Visit the Canddi website|
|Canddi Prospect Analytics||_CAN_SId_CAN_BId||Third party||Persistent (_CAN_Bld expires after 10 years; _CAN_Sld expires after 30 minutes)||These cookies are used to collect information about how visitors use our site, so we can compile reports and to help us improve the site.||Visit the Canddi website|
You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the MotoNovo Finance services or Web sites you visit. In particular, you will not be able to navigate effectively between pages, search for cars or access secure areas.
Google Analytics - These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. To opt out of being tracked by Google Analytics across all websites visit Google Analytics Opt-out Browser Add-on.
Some of the data that Google Analytics collects will be transferred and stored outside the European Economic Area where data and privacy protection may be lower
Security of your Personal Information
MotoNovo Finance secures your personal information from unauthorised access, use or disclosure. MotoNovo
Finance secures the personally identifiable information you provide on computer servers in a controlled, secure environment, protected from unauthorised
access, use or disclosure. When personal information (such as a credit card number) is transmitted to other Web sites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol.
MotoNovo Finance welcomes your comments regarding this Statement of Privacy. If you believe that MotoNovo Finance has not adhered to this Statement, please contact MotoNovo Finance at info@MotoNovofinance.com, or write to us at The Data Protection Officer, MotoNovo Finance, One Central Square, Cardiff, CF10 1FS. We will use commercially reasonable efforts to promptly determine and remedy the problem.
If you have any comments or questions about this website or any aspect of our products and/or services, please contact us as specified on the "contact us" page.