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PRIVACY
Policy.
1. Policy Statement

1.1 We take your privacy seriously and this policy (Privacy Policy) sets out how we will handle your personal data securely and in accordance with your rights.

1.2 This website and online platform is operated by Oodle Financial Services Limited trading as Oodle Car Finance (“Oodle Car Finance” “we”, “us” or “our”). Details of Oodle Car Finance’s notification to the data protection regulator may be found in the Information Commissioner’s Office Public Register of Data Controllers at www.ico.org.uk.

1.3 To the extent that we determine the manner and the purpose of processing, we acknowledge that we are Data Controllers of your Personal Data (as such terms are defined in the Data Protection Act 1998 but which, on and from 25 May 2018, shall have the respective meanings given under the General Data Protection Regulation (EU) 2016/679) (the “Regulation”)). We undertake to act in accordance with the Data Protection Act 1998 (and, on and from 25 May 2018, the Regulation) at all times (including having in place adequate levels of security in respect of such Personal Data). As noted above this Privacy Policy sets out the basis on which we will collect and process your Personal Data and that of any third party whose Personal Data you supply to us.

1.4 We will regularly review the purposes for which we hold your Personal Data and will not hold it for longer than is necessary. We will also seek to minimise the Personal Data which we hold about you wherever possible. If we intend to make use of your Personal Data for any new purposes which would be considered incompatible with the purposes for which it was originally collected, as set out in this Privacy Policy, we will notify you of such intended uses and seek your consent to such activities, prior to the commencement of any such processing.

1.5 Our Data Protection Officer is: Oodle Car Finance General Counsel who can be contacted by writing to Oodle Car Finance, 1st Floor, Fletcher House, Oxford Science Park, Oxford, OX4 4GE or by emailing legal@oodlecarfinance.com .

2. General Information

2.1 This Privacy Policy explains what Personal Data we collect about you when you register to use our sites and/or use our services and how we handle your Personal Data to ensure that we protect your rights. Please read this Privacy Policy carefully to understand how we will treat your Personal Data. In this Privacy Policy, references to “you” or “your” shall mean you as a user of our website (our “site(s)“) and /or as an applicant or recipient of our financing services (“our “Services“).

2.2 This Privacy Policy (together with our terms of use and any other documents referred to on it) sets out the basis on which any Personal Data we collect from you, or that you provide to us, will be processed by us.

2.3 Where you enter into a credit or finance agreement with us, we may provide some additional privacy terms in the form of a Use of Information Statement (our “Use of Information Statement“). If there is any inconsistency between any of the provisions of this Privacy Policy and the provisions of the Use of Information Statement, the provisions of the Use of Information Statement shall prevail to the extent the privacy terms in it apply to the credit or hire agreement we enter into with you.

2.4 We will seek your consent to the processing described in this Privacy Policy by asking you to tick relevant boxes situated on the page on which we collect your Personal Data, which will contain an explanation of what data we are collecting, what consent we are seeking and why we need such consent(s).

3. What information do we collect?

3.1 When you register an interest to use our Services and/or our sites we may ask you to provide certain information such as your name, address, email address, and a contact number. When you register or apply to use our Services we may ask you for additional information including your date of birth, marital status, driving licence type details regarding your income and your employment and address history. We may also collect information on an ongoing basis about what pages you access or visit, and information about your use of our sites, for example the pages viewed, the website from which you came to visit our sites, changes you make to information and/or Personal Data you supply to us, details of the quotes you request and your transactions, including by use of Cookies. If you contact us, we may keep a record of that correspondence.

Data that is sensitive or considered a special category of data

3.2 In order to provide you with our Services we may need to collect Personal Data which is defined as ‘sensitive’, or considered to be a special category of data as set out in the Regulations. such as your medical and/or criminal records, for example any relevant driving convictions. For example, we may require such information if we consider you have specific requirements, your needs change or experience vulnerabilities which we need to consider as part of the management of your agreement with us. We will ask you to signify your explicit consent to such sensitive or special categories of Personal Data being processed by us and our service providers for the purposes stated in this Privacy Policy and/or our Use of Information Statement.

4. What do we do with the information we collect?

4.1 The main reason we use the information that you provide is to consider whether Oodle Car Finance should enter into a finance agreement with you, either now or in the future and this information will be entered onto the Oodle Car Finance, finance proposal system. It is important that you provide accurate information on your application. When you register or apply to use our Services in addition to the information that you provide in your application for finance from Oodle Car Finance, we may also collect information about you to assess your creditworthiness. This information may be collected:

  • . from enquiries we may make about you (including from the searches we do with fraud prevention and credit reference agencies); and
  • . from information we hold in relation to your performance of any other agreement you have or have previously had with Oodle Car Finance.
This information will be collected in accordance with this Privacy Policy and with our Use of Information Statement. Please note that information held about you by the credit reference agencies may already be linked to records relating to anyone financially connected with you and for the purposes of this application, you may be treated as financially linked with such person and your application will be assessed on this basis.

4.2 We may also use your information:

  • . in the normal course of our business, to allow us to register you to receive our Services and to provide you with our Services;
  • . to allow us to manage your account;
  • . to allow us to analyse your personal preferences and personalise our Services to you so that we can provide a more tailored experience to you;
  • . to store your Personal Data and other information which you provide to us to pre-populate fields to make it easier for you to provide information when you return to our sites;
  • . to ask you to complete surveys that we use for research purposes, although you do not have to respond to them;
  • . to record details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data and the resources that you access on the basis that processing is necessary in order to perform our contract with you to provide our Services;
  • . to communicate with you, including sending you information about products and Services which we think may be of interest to you (details of how to manage your marketing preferences are covered below under Marketing);
  • . to validate your Personal Data (and, in some cases, match it against information that has been collected by a third party) to check that the Personal Data we hold about our customers/users is accurate, consistent and up to date on the basis that you have consented to such processing by agreeing to share your Personal Data with us for such purposes;
  • . to provide customer service, including answering questions and responding to feedback and complaints;
  • . to comply with any legal obligations to which we are subject on the basis that processing is necessary to comply with our legal obligations;
  • . in pursuit of our legitimate interests, such as developing and/or consolidating our business, defending our legal rights and/or seeking advice from our professional advisors;
  • . to make automated decisions, including profiling (further details regarding automated decision making are set out below under What are your rights?);
  • . to respond to requests from law enforcement agencies.

4.3 Your Personal Data may be converted into anonymised form in a way which means you cannot be identified from it and then used for the purposes of information security testing, statistical analysis and to enhance our provision of products and services. Our use of all such data will be in line with our responsibilities under data protection law (as relevant) and we would anonymise it before using it for these additional purposes.

4.4 We will endeavour periodically to check that the Personal Data we store for you is accurate. If you would like to update the Personal Data we hold about you, please contact us via customerservices@oodlecarfinance.com with your request.

4.5 The provision of your contact information is mandatory if you are to receive our Services.

4.6 The provision of Personal Data for the purposes of direct marketing is voluntary and you do not need to provide such Personal Data in order to receive our Services. Information relating to your marketing preferences is detailed below under Marketing.

5. Who do we share this information with?

When you register an interest to use our Services you consent to us sharing your data with the following parties:

  • . service providers and other third parties who process and store data on our behalf;
  • . car dealers and brokers, including their business partners

As part of using our Services, you consent to us sharing your Personal Data with the following parties:

  • . service providers and other third parties who process and store data on our behalf;
  • . third parties who provide maintenance and servicing of any vehicles you hire as part of the Services;
  • . professional advisors;
  • . individuals who you nominate as referees to verify certain information;
  • . in the event that our business, either in whole or in part, is acquired by a third party (in which case Personal Data about customers will be one of the transferred assets);
  • . if we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or in order to enforce any contract with you; or to protect our rights, property, or the safety of our employees, customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud prevention and credit risk reduction.
  • . companies and consultants providing services to us (for example, marketing agencies, mail outsourcing service provider, Information Technology service providers who provide and maintain our systems and our website host). Those companies and consultants providing services to us will only use your information to provide those services.
  • . a third-party company that may take over your contract, so that you can continue with your contract.
  • . car dealers and brokers, including their business partners.
  • . third party insurance providers.
  • . debt collection agencies.
  • . the courts in connection with court proceedings.
6. Credit Reference and Fraud Prevention Agencies

When you register or apply to use our Services:

6.1 We share Information with fraud prevention agencies about both active and prospective borrowers.

6.2 We will exchange your Personal Data (provided to us as set out in this Privacy Policy and any Use of Information Statement which is provided to you) with credit reference agencies and fraud prevention agencies. This is not limited to such agencies based in the United Kingdom and includes such agencies overseas. We will only share such details with such organisations in accordance with this Privacy Policy and the Use of Information Statement which is provided to you in the course of entering into an agreement with us. For further details as to our Use of Information Statement(s) please read section 2.3 above, under General Information).

6.3 We will seek your consent to such processing by asking you to tick relevant boxes situated on the page on which we collect your Personal Data.

6.4 Further details explaining which fraud prevention agencies we use and how the information held by fraud prevention agencies may be used can be obtained by contacting us at Oodle Car Finance, 1st Floor, Fletcher House, Oxford Science Park, Oxford, OX4 4GE.

7. How long do we store your personal data for?

7.1 We only store your Personal Data for as long as necessary for the purposes described in this Privacy Policy and or Use of Information Statement.

7.2 In the event that you make an application to use our Services or use our Services, we will only store your Personal Data whilst you continue to use our Services and for a period of 6 years thereafter (or such longer period as is necessary for the proper performance of our regulatory obligations to you).

8. Security and data storage

8.1 In order to ensure fair and transparent processing, we will, taking into account our processing activities, adopt appropriate procedures for the processing of Personal Data, which shall include implementing technical and organisational measures which take into account the harm that may be suffered, and correct inaccuracies identified in Personal Data processed, so that risk of errors are minimised and your Personal Data is processed in a fair and secure manner.

8.2 All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share the password with anyone.

8.3 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

8.4 From time to time, service providers and organisations with whom we work to provide Services to you or credit reference agencies with which we work, may be located outside the European Economic Area in countries that do not have the same standards of protection for Personal Data as the UK. We will, however, always use every reasonable effort to ensure sufficient protections are in place to safeguard your Personal Data. We will also ensure that our service providers enter into compliant processing agreements with us to ensure that your Personal Data is processed in accordance with applicable data protection legislation.

9. Marketing

9.1 From time to time we would like to send you details of products and services, which may be of interest to you, for example, where you have consented, we may:

  • . use your personal information to send you information about our own products and services and those of our group companies and other carefully selected third parties which may be of interest to you; and
  • . pass your details to our group companies and other carefully selected third parties including anyone who introduced you to us, so that they may send you information about their products and services via e-mail, SMS text message, post and / or telephone

9.2 You can change your contact preferences at any time by Contacting Us or unsubscribing from the relevant communication (email customerservices@oodlecarfinance.com). To do this in relation to marketing from our group companies and third parties please write to them. Their contact details should be specified in the marketing communication itself which you have received from them.

10. What are your rights?
  • . Access to your Personal Data (Subject Access Requests): You may request access to a copy of your Personal Data that we hold on you.
  • . Right to withdraw consent: You may withdraw your consent at any time. Upon a review of the request, in accordance with the relevant legislation, we will update our records accordingly (including where appropriate by deleting your data in line with your right to erasure set out below).
  • . Rectification: You may ask us to rectify inaccurate Personal Data held about you. If you would like to rectify any incorrect Personal Data we hold about you, please contact us using the details below to rectify your information.
  • . Erasure: You may ask us to delete your Personal Data. If you would like us to delete the Personal Data we hold about you, please contact us using the details below, specifying why you would like us to delete your Personal Data. Upon a review of the request, in accordance with the relevant legislation, we will update our records accordingly
  • . Portability: You may ask us to provide you with the Personal Data that we hold about you in a structured, commonly used, machine readable form, or ask for us to send such Personal Data to another data controller.
  • . Right to object: You may object to our processing of your Personal Data pursuant to this Privacy Policy. Please contact us using the details below, providing details of your objection.
  • . Make a complaint: You may make a complaint about our data processing activities to a supervisory authority. For the UK, this is the Information Commissioner’s Office, at ico.org.uk.
  • . Automated Decisions: Oodle Car Finance may use a credit-scoring system, i.e. an automated system to assess your credit worthiness and decide whether to enter into a finance agreement with you. You may ask us to ensure that, when we are evaluating your application for finance, we don’t base any decisions solely on an automated process. You must notify us of this request by contacting us using the details below. If you make such a request, you will then have the right to be notified where such a decision is or will be based on an automated process. If we notify you that we have taken such a decision, you may request us to review that decision other than by automatic means by contacting us within 21 days of receiving the notification. These rights will not apply in all circumstances, for example where the decision is authorised or required by law and steps have been taken to safeguard your interests.

Please contact us using the details located under “Contact Us” below, if you would like to exercise any of the above rights. Please note that we may ask you to provide a form of identification verification before we can give effect to any such request made by you.

11. Cookies policy

Our Cookies Policy can be located via the following link.

12. IP addresses

We may collect information about your computer, including where available your IP address, operating system and browser type and for system administration e.g. we may collect anonymised statistics relating to users’ journeys to understand the popularity of particular vehicles or special offers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual. Further information regarding our use of analytics tools is set out in our Cookies Policy.

13. Links to Other Websites

Our site may, from time to time, contain links to and from the websites of our partner networks and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any Personal Data to these websites.

14. Changes to our Privacy Policy

14.1 We may modify this Privacy Policy from time to time, so please review it regularly.

14.2 If we change this Privacy Policy in a way that may substantially alter the purposes for which we process your Personal Data we shall notify you by means of notice on our site homepage and where a material change to such terms by email to the email address you have provided to us. You will not be able to continue to use our service unless you have acknowledged the changes.

14.3 This Privacy Policy was last amended on 25 September 2017

15. Contact Us
Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to The Data Protection Officer, at 1st Floor, Fletcher House, Oxford Science Park, Oxford, OX4 4GE or by emailing legal@oodlecarfinance.com . Please provide a summary of your enquiry in your correspondence with us so that we can process it as expediently as possible.