Whitewater Finance Ltd understands that your privacy is important to you and that you care about how your personal data is used. [We] respect and value the privacy of everyone who visits this website, www.whitewaterfinance.com (“[Our] Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with [our] obligations and your rights under the law.
Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Account” means an account required to access and/or use certain areas and features of [Our] Site;
“Cookie” means a small text file placed on your computer or device by [Our] Site when you visit certain parts of [Our] Site and/or when you use certain features of [Our] Site. Details of the Cookies used by [Our] Site are set out in Part 14, below;
“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;]
Our Site is owned and operated by Whitewater Finance, a Limited Company [registered in England under company number 04921447.
12 Frouds Close
Data Protection Officer: Luke Allison
Email address: email@example.com
Telephone number: 01256 761444.
We are regulated by The Financial Conduct Authority, Licence Number 668744.
What Does This Policy Cover?
What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
- The right to access the personal data we hold about you. Part 13 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 15 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling. some parties we work with do use automated systems to make their decisions, you do have the right to contest this decision and can do so by using the contact details below
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided below.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau. If you have any cause for complaint about [our] OR [my] use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
What Data Do We Collect?
[Date of birth;]
[Address and residential status;]
[Job title and employment information;]
[Information about your preferences and interests;]
[Web browser type and version;]
[A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;]
How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for the following purposes:
[Providing and managing your Account;]
[Providing and managing your access to Our Site;]
[Personalising and tailoring your experience on Our Site;]
[Supplying our products and services to you. Your personal details are required in order for us to enter into a contract with you.]
[Personalising and tailoring our products and services for you.]
[Communicating with you. This may include responding to emails or calls from you.]
[Supplying you with information by email, SMS, and post that you have opted-in to (you may unsubscribe or opt-out at any time by contacting us via any of the means above).]
[Analysing your use of Our Site and gathering feedback to enable us to continually improve Our Site and your user experience.]
[Carrying out a credit check via a third parties in order to access your likelihood of being approved for credit with one of the lenders we work with]
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and telephone and text message and post with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.] Third Parties (including BlueOwl Network Ltd T/A Autoconvert.co.uk) whose content appears on [Our] Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that [we] do not control the activities of such third parties, nor the data that they collect and use themselves, and [we] advise you to check the privacy policies of any such third parties. [We] use the following automated system[s] for carrying out certain kinds of [decision-making] AND/OR [profiling]. If at any point you wish to query any action that [we] take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the GDPR gives you the right to do so. Please contact us to find out more using the details in Part 15.
The following automated decision-making method(s) may be used:
Checking the criteria of our lending panel against information you have supplied to determine the likelihood of an application for car finance being accepted by one of the lenders we work with. Sending information to a 3rd party credit reference agency or company to determine a soft search credit score. This is to further determine the likelihood of being accepted with one of our lender panel before a full application is propped to them.
Submitting an application through to a lender via an API (Application Programming Interface) for a fast decision.
The following automated profiling may take place:
Using you’re the data provided on your application we may look to market specific products or services to you. We want to make marketing relevant and data you provide can help us choose which products and services may be most suitable. (Example: If you have dependants and are looking for a family vehicle we could send you details of family vehicles as they come into stock).
How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept): Full application details will be kept until it is determined that you are no longer interested in our products and services.
How and Where Do You Store or Transfer My Personal Data?
We will only store or transfer your personal data in the UK. This means that it will be fully protected under the GDPR. Please note third parties we work with may keep data outside of an approved EEA state, whilst we carry out thorough due diligence on firms, we recommend reading their privacy policies.
Please contact us using the details below in Part 15 for further information about the particular data protection mechanism used by us when transferring your personal data to a third country.] The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
- SSL secure site
- Dedicated encrypted storage server
Do You Share My Personal Data?
[We] may share your personal data with other companies in [our] group for them to contact you regarding specific products or services you have expressed an interest in. This includes [subsidiaries] AND/OR [[our] holding company and its subsidiaries. [We] may sometimes contract with the following third parties to supply certain [products] AND/OR [services]. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that [we] hold. By making this application and agreeing to our Terms and conditions you are happy to be contacted by Whitewater Vehicle Solutions T/A Whitewater Finance Ltd by phone, email and SMS.
- BlueOwl Network Ltd T/A Autoconvert
- Equifax ltd
If any of your personal data is required by a third party, as described above, [we] will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, [our] obligations, and the third party’s obligations under the law, as described above in Part 9.]
If any personal data is transferred outside of the EEA, [we] will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 9.] In some limited circumstances, [we] may be legally required to share certain personal data, which might include yours, if [we are] involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
How Can I Control My Personal Data?
In addition to your rights under the GDPR, set out in Part 5, when you submit personal data via [Our] Site, you may be given options to restrict [our] use of your personal data. In particular, [we] OR [I] aim to give you strong controls on [our] OR [my] use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from [us] which you may do by unsubscribing using the links provided in [our] emails [and] OR [SMS’s] at the point of providing your details [and by managing your Account].
You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
Can I Withhold Information?
You may access [certain areas of] [Our] Site without providing any personal data at all. However, to use all features and functions available on [Our] Site you may be required to submit or allow for the collection of certain data.
How Can I Access My Personal Data?
If you want to know what personal data [we] have about you, you can ask [us] for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”. All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell [us] everything [we] need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover [our] administrative costs in responding. [We] will respond to your subject access request within [20 days and, in any case, not more than] one month of receiving it. Normally, [we] aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date [we] receive your request. You will be kept fully informed of [our] progress.
How can I contact you and Preference Management?
Alternatively you can write to our Data Protection Officer at the following address:
12 Frouds Close
If you would like to opt-out of uses of your personal data please email us with your request to firstname.lastname@example.org
All Cookies used by and on [Our] Site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a pop up message requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling [us] to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of [Our] Site may not function fully or as intended. [You will be given the opportunity to allow only first-party Cookies and block third-party Cookies.]
Certain features of [Our] Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that [Our] Site may not work properly if you do so. [We] have taken great care to ensure that your privacy is not at risk by allowing them.
The following first-party Cookies may be placed on your computer or device:
|Name of Cookie||Purpose|
|Session Cookie||Make our website work as you'd expect.
Save you having to login every time you visit the site.
Remember your settings during and between visits.
Improve the speed/security of the site.
Personalise our site to you to help you get what you need faster.
Continuously improve our website for you.
Make our marketing more efficient.
Determining if you are logged in or not.
[Our] Site uses analytics services provided by Google. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling [us] to better understand how [Our] Site is used. This, in turn, enables [us] to improve [Our] Site and the [products] AND/OR [services] offered through it.
The analytics service(s) used by [Our] Site use(s) Cookies to gather the required information. You do not have to allow [us] to use these Cookies, however whilst [our] use of them does not pose any risk to your privacy or your safe use of [Our] Site, it does enable [us] to continually improve [Our] Site, making it a better and more useful experience for you.
In addition to the controls that [we] provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third- party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.]
To contact [us] about anything to do with your personal data and data protection, including to make a subject access request, please use the following details for the attention of Luke Allison:
Email address: email@example.com
Telephone number: 01256 761444
Postal Address: Whitewater Finance, ‘Tall Trees’ 12 Frouds Close, Hook, Hampshire, RG27 9NE
How Do I Contact Your Third Party Providers?
To contact third party providers please use the following details:
Equifax Ltd, Customer Services Centre, PO Box 10036, Leicester, LE3 4FS or call 0800 014 2955 or log on to www.equifax.co.uk
Autoconvert.co.uk, The Granary, 50 Barton Road, Worsley, Greater Manchester, M28 2EB. www.autoconvert.co.uk
[We] may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if [we] change [our] business in a way that affects personal data protection.
1. Any changes will be immediately posted on [Our] Site and you will be
of [Our] Site following the alterations. [We] recommend that you check this
page regularly to keep up-to-date.
17. A condensed guide to the use of your personal information by
ourselves, 3rd parties and at Credit Reference and Fraud Prevention
When you apply for finance with us Whitewater Finance, your details will be passed into a 3rd party company BlueOwl Network Ltd T/A Autoconvert.co.uk(contact details below), this organisation will check the following records about you and with their chosen Credit Reference Agency (CRA), Equifax Ltd(contact details below)
- a) Our own;
- b) Autoconvert.co.uk.
- c) Those at Equifax Ltd. When Equifax receives a search request from us via Autoconvert, they will place a soft quotation footprint that will be visible to you only, on your credit file, other parties including lenders will not see this. This quotation footprint will not be seen by other parties and will not affect your credit score/rating or ability to apply or finance from other lenders.
- d) Autoconvert.co.uk will access from Equifax Ltd both public (including the electoral register) and shared credit and fraud prevention information. This information will be used to check your eligibility against a select group of lenders.
- e) We will not see any information on your credit file, Autoconvert.co.uk will only provide a list of lenders that you are likely to be accepted for given the information supplied using there brokering technology that understands most the acceptance criteria of the lenders on their panel.
- f) Those at fraud prevention agencies (FPAs). We will make checks such as; assessing this application for credit and verifying identities to prevent and detect crime.
- Information on applications will be sent to CRAs and will be recorded by them.
- 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.
- 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 the Data Protection Act 1998.
How to find out more?
You can contact our chosen 3rd Party, BlueOwl Network Ltd T/A Autoconvert.co.uk or the Credit Reference Agency, Equifax; the information they hold may not be the same so it is worth contacting them all. All other third parties can be found on the information above.