The following data privacy notice explains the circumstances in which “V2L Ltd” will collect personal data from you, why it is being collected, how we will use it and to whom we might disclose it to if necessary. This policy was updated on 25th May 2018 in line with the General Data Protection Act (GDPR). This reform sets out more rights for individuals and greater transparency in how personal data is processed by Data Controllers, such as consent, distribution, marketing and deletion. As we are a credit intermediary, we undertake a number of financial tasks that relate to customer credit. Our firm’s lawful basis for processing your personal data is done so under a Legitimate Interest-Article 6 (1)(f) – “the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.’
The data controller
“V2L Ltd” is committed to complying with the UK’s Data Protection law and the EU General Data Protection Regulation (GDPR) for the protection of personal data, as well as the principles of data security in the configuration of our services. If you have any questions about this privacy notice or how we use your personal data, please contact our Data Protection Officer, Lisa Ratcliffe: In Writing:
Todd Street Bury
By Phone: 0161 764 0409
By Email: firstname.lastname@example.org
Personal data we may collect
We will obtain personal data about you (including your name, address, date of birth, contact information, interests, payment details, financial information and opinions) and those whose personal data you have with express authority disclosed to us (‘others’) whenever you complete an online form or make a telephone enquiry with us to receive our services. If you submit an online enquiry you will be required to agree to the terms of this Policy which include permitting us to contact you for the purposes of the finance related enquiry via the contact means of which you provide us with the details of. i.e. email address, telephone number, etc.
For example, we will obtain personal data when you (e.g. contact us for any reason, or purchase services). In certain circumstances, we may hold sensitive personal data if you provide us with such information if you feel that it is relevant for the purpose of your enquiry, but we will not ask for such information. Any sensitive personal data obtained and recorded will only be done so with your explicit consent.
How we use personal data
We will use the personal data you disclose to us for the purposes described in Our Terms. These purposes include:
• To assist us in processing your enquiries and obtaining the services which you require
• To help us identify you and any accounts that you hold with us
• Undertaking credit checks
• Research, statistical analysis and behavioural analysis
• Customer profiling and analysing your preferences
• Marketing (providing you have opted-in) [for further information see ‘Marketing and opting-in’ below]
• Fraud prevention and detection
• Billing and order fulfillment
• Customising our website and its content to your particular preferences
• To notify you of any changes to our website or to our services which may affect you
• Security vetting
• Improving our services.
Marketing and opting-in
We may share your personal data with organisations as set out in the ‘Disclosure of personal data’ section below. If you have opted-in to receive our marketing material, we will ensure that it is to your requirements and granular. We or they may contact you or others (unless you have asked us or them not to do so) by mail, telephone, text message, email, (each contact method requires its own consent via an opt-in selection) The nature of these marketing communications relate to information on products, services, promotions and special offers which we believe may be of interest to you or others. If you or others would prefer not to receive any further direct marketing communications from us or our business partners, it is possible to opt out at any time. See further ‘Your rights’ below.
Disclosure of personal data
We may disclose personal data that you provide to us to:
• Our agents and service providers (e.g. providers of web hosting, maintenance services or potential funders)
• Law enforcement agencies in connection with any investigation to help prevent unlawful activity
• Our business partners in accordance with the ‘Marketing and opting out’ section above, specifically being:
• Finance companies with whom we deal for the purposes of providing our services to you
• Insurance companies with whom we deal for the purposes of providing our services to you and to verify information provided to us by you
• Other third parties with whom we deal with in the course of providing our services to you
• Any regulators within whose jurisdiction we operate within from time to time.
Please be aware that we will not sell or otherwise disclose any personal data provided to us to any other party.
A cookie is a small file that asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, like and dislikes by gathering and remembering information about your preferences.
We use traffic log cookies to identify which pages are being used. This helps us analyse data about our website traffic and improve our website in order to tailor it to meet customer needs. We only use information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose 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. This may, however, prevent you from taking full advantage of the website.
Keeping data secure
We currently safeguard personal data by storing it on a Customer Management System protected by password and shall ensure that from time to time we use no lesser technical and organisational measures to safeguard personal data which is disclosed to us. Whilst we will use all reasonable efforts to safeguard such personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data which are transferred from you or to you via the internet.
We may monitor and record communications with you (such as telephone conversations and emails) for the purpose of quality assurance, training, fraud prevention or compliance purposes.
Information about other individuals
If you give us information about others, you confirm that the other third party person has appointed you to act on his/her behalf. This is also relevant where others are concerned if you indeed ask another person to act on your behalf as a third party. Under the third party authorisation, the other person can:
• Give consent on his/her behalf to the processing of his or her personal data for the purposes and reasons set out in this Policy
• Receive on his/her behalf any data protection notices.
Such authorisation will remain in place until this has been revoked, either by verbal or written communication.
You have the right to request access to your personal data that we process. This formal request is made under the DPA and is referred to as a Subject Access Request. If you wish to exercise this right and make a Subject Access Request, you should:
• Put your request in writing; either by Email or by letter.
• Include proof of your identity and address (e.g. a copy of your driving licence or passport, and a recent utility or credit card bill); • Specify the personal data you want access to, including any account or reference numbers where applicable.
You have the right to require us to correct any inaccuracies in your data free of charge. If you wish to exercise this right, you should:
• Either speak to us via telephone or put your request in writing;
• Provide us with enough information to identify you (e.g. account/order number, username, registration details)
• Specify the information that is incorrect and what it should be replaced with.
You also have the right to ask us to stop processing your personal data for direct marketing purposes. If you wish to exercise this right you should:
• Put your request in writing (an email sent to email@example.com with a header that says ‘unsubscribe’ is acceptable)
• If your objection is not to direct marketing in general, but to direct marketing by a particular channel (e.g. email or telephone) please specify the channel you are objecting to.
We will only process your personal data providing you have given your consent for us to do so. Under the provisions of the Data Protection Act, our firm’s lawful basis for processing personal data is based on a Legitimate Interest.
The legitimate interest relates to a legal requirement for the firm to hold your personal data and financial information on record for up to a total of six years. This six-year period satisfies the requirement of our regulator, The Financial Conduct Authority and is also in line with other financial industry retention periods.
You have the right to withdraw your consent for us to collect, process and store your data at any time. If you wish to withdraw your consent, please confirm this in writing to our Data Protection Officer: By Post: V2L Ltd Fernhill Depot Todd Street Bury BL9 5BJ By Email: firstname.lastname@example.org
Right to complain
If you have a complaint about any aspect of data protection or if you feel we have breached your privacy, we would like to hear from you. To help us investigate and resolve your concerns as quickly as possible, please contact our Data Protection Officer: V2L Ltd
By Email: email@example.com.
If you are unhappy with the final response you have received from V2L Ltd, you have the right to complain to the supervisory authority, the Information Commissioner’s Office (ICO) within three months of your last meaningful contact with us. You can call the ICO on 0303 123 1113 or by visiting their website: https://ico.org.uk/
Due to the further development of our website, government regulations or the implementations of new technologies, this policy will be reviewed, and may change, from time to time. V2L Ltd reserves the right to change this data protection information at any time with effect for the future. The revised policy will be posted to this page so that you are always aware of the information we collect, how we use it and under what circumstances we disclose it. We therefore recommend you read the current data protection information again from time to time.