How we use your information
We are findandfundmycar.com, part of 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.
We can be contacted by telephone on 0333 200 0030 or email email@example.com. Our Data Protection Officer can be contacted at our Registered Office address or by email at DPO@motonovofinance.com.
What is the purpose of this document?
This policy explains what personal data we collect from you, how it will be used by us and why.
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.
How we use the information we collect about you
What we will do when you search for a car using findandandfundmycar.com
When you register an account on findandandfundmycar.com
What we will do when you apply for a decision in principle
Where you have applied for a decision in principle and you have visited the individual web page for a car where the motor dealer is named, we will make certain information you have provided to us available to that motor dealer. We do this because we have a legitimate interest in alerting motor dealers that you may be contacting them and so that they know that you have viewed their vehicles advertised on the findandfundmycar.com website.
We will use your information to carry out a credit search as a necessary part of the decision in principle process. This will be a "soft search", which will leave a quote record on your file but this will only be visible to you and us and will not affect your credit profile.
When you phone, or we phone you: call recording and customer identification
We will also use your personal data to check your identity if you get in touch with us.
We may monitor and record calls made to us, or calls that we make to you. We use your information in this way in our legitimate interest, in order to prevent fraud, to improve the services we provide to you and for monitoring and training purposes.
Calls made to the phone numbers displayed on our website are tracked and your telephone number will be matched to Submitted Information (please see below) if you later take out a finance agreement with MotoNovo Finance. We use your information in this way in our legitimate interest to monitor the service being provided by motor dealers and to monitor performance.
What we will do when you apply for finance
Before we provide services, goods or financing to you, we will need to collect certain details from you for the purpose of entering into an agreement with you for services, goods or financing; administering any agreement with you; and in order to undertake checks for the purposes of preventing fraud, money laundering, to verify your identity; to assess your creditworthiness; and if you access our website we collect information about your browsing experience, for the purposes of understanding and improving our website, customer experience and our products and services.
What we will do when you book a test drive or request a quote or brochure
If you book a test drive of a new vehicle, or request a quote or brochure, through the Website you will need to provide your name, email address, postal address and telephone number which will be passed to the relevant dealer or other third party. Each request form clearly indicates that you are giving authorisation for your details to be passed to the relevant dealer or other party for them to contact you and action your request.
What we collect and process
We will collect and process the following personal data about you (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.):
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. Please see our Cookies Policy section below.
When calling the numbers displayed on our website we will collect
- telephone number
- Call details: duration, time, recipient, whether the call was answered or not.
Information you give us and/or provide to a motor dealer when making an application for finance (Submitted Information):
- Your name,
- date of birth,
- residential address and address history for the last three years,
- contact details such as email address and telephone numbers,
- financial information, and employment details, to include your salary, employer name, address and time you have worked there.
If, for any reason, you do not provide this information we will not be able to proceed with credit reference and fraud prevention checks and, subsequently will not be able to fulfil your application and we will not be able to enter into the agreement with you. Further details about these checks are provided below.
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, 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 have,
- fraud prevention information and
- public information such as County Court Judgments, bankruptcies and the Electoral Register.
We may combine Submitted Information with Third Party Information and may use both these categories of information and the combined information for the purposes set out below.
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 including credit, market, regulatory and operational risk management; systems testing; network monitoring
- Commercial Activities which will mean assigning our rights or obligations to a third party and obtaining funding for our business
- For market research ,analysis and developing statistics, such as for scorecard development purposes and matching of website users to MotoNovo Finance customers
- 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:
- Where consent is required for us to process certain types of your personal data, it must be clearly given. You may give us your consent to receive our marketing communications and/or when you use the Website to request services provided by motor dealers.
- Where you have given consent for Findandfundmycar.com to process your personal data for direct marketing purposes you may withdraw consent at any time by emailing firstname.lastname@example.org We will cease processing your data based on that consent but this does not affect any processing we have undertaken at any time before withdrawal.
- 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
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 a credit check 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.
People and organisations with whom we share your data
In addition to the sharing of data with credit reference agencies and fraud prevention agencies outlined above, we may share your personal data with the following other third parties.
We may transfer your personal data to other companies in our group or to third parties acting on our behalf, including without limitation, Sterling Client Services Ltd, Covea Insurance, Red Sands Insurance (Europe) Ltd (for related insurance policy services), iVendi Ltd (findandfundmycar.com system supplier); Core Internet Solutions Ltd (who co-host the findandfundmycar.com website) and our service, system, support and outsourcing providers; our collection agents; our motor dealers; retailers and manufacturers of Goods relating to your agreement; regulatory bodies, and law enforcement and fraud prevention agencies, for administrative purposes, processing or for the operation and maintenance of your business with us.
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 the EU General Data Protection Regulation and any other applicable legislation relating to the protection of personal data and privacy from time to time that 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 motor dealer of ours who is not the motor dealer who introduced the agreement to you, but is a motor 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.
Companies in our group
FirstRand Bank Ltd and Aldermore Groups its establishments and trading divisions as follows:
- FirstRand Bank Ltd (London Branch)
- RandMerchant Bank (RMB)
- First National Bank
- FirstRand International (Guernsey) Ltd
- RMB International UK Ltd
- Ashburton Investments Holdings Ltd
- Aldermore Group plc
- Aldermore Bank plc
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 search on your credit file (commonly referred to as a "footprint"). This record (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
If you have provided inaccurate information or we suspect fraud, we will share some of the personal data we have collected from you 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.
If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services, goods or financing you have requested, or to employ you, or we may stop providing existing services to you. Records held by fraud prevention agencies 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.
Other third parties
Should your application with MotoNovo Finance 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, 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.
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.
Where we have a legitimate interest to provide marketing information to you, and where appropriate, if you provide your consent for us to contact you by electronic means; 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). At any point in your journey through our site where we ask for information about you which we may use for direct marketing purposes, we will either ask you to allow us to contact you or we will provide you with an opportunity to say no to this type of processing You can also change your preferences at any time by contacting us at email@example.com or in the account area.
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. Where you register an account area, we will retain your data for as long as your account is active and for five years after your account is closed to enable us to satisfy our legal, accounting and reporting requirements
Information relating to phone calls made to numbers displayed on our website will be retained for a period of 6 months.
We will keep information about any financial agreement you hold with us for at least the duration of your agreement and the period of 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 5 years in accordance with Anti Money Laundering legislation requirements (Credit Reference Agencies may keep your data for longer).
At the end of the relevant retention period your personal data may be anonymised to remove any information from which you may be identified. Anonymous data will be used by MotoNovo Finance for the purposes of statistical analysis, business improvement and research.
You have the following 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
- to be informed about the processing of your personal data (this is what this statement sets out to do)
- to have your personal data corrected if it's inaccurate and to have incomplete personal data completed
- to object to processing of your personal data
- to withdraw your consent to processing your personal data;
- to restrict processing of your personal data;
- to have your personal data erased;
- to request access to your personal data and information about how we process it;
- to specify which credit reference agencies we have shared your personal data with;
- to move, copy or transfer your personal data ("data portability"); and
- 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, 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 using the contact details set out at the top of this notice.
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 or www.transunion.co.uk/crain.
Cookies and similar technologies
What are cookies?
A cookie is a small text file that is placed on a computer or other device and is used to identify the user or device and to collect information. Cookies are typically assigned to one of four categories, depending on their function and intended purpose: strictly necessary cookies, performance cookies, functional cookies, and cookies for marketing purposes.
Types of cookies and why we use them
- Strictly necessary cookies: These cookies are essential to enable you to move around a website and use its features. Without these cookies, services you have asked for, like adding items to an online shopping cart, cannot be provided.
- Performance cookies: These cookies collect information about how you use our websites. Information collected includes, for example, the Internet browsers and operating systems used, the domain name of the website previously visited, the number of visits, average duration of visit, and pages viewed. These cookies don't collect information that personally identifies you and only collect aggregated and anonymous information. Performance cookies are used to improve the user-friendliness of a website and enhance your experience.
- Functionality cookies: These cookies allow the website to remember choices you make (such as your username or ID, language preference, or the area or region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts, and other customisable parts of web pages. They may also be used to provide services you have asked for, such as watching a video or commenting on a blog. The information these cookies collect may be anonymised, and they cannot track your browsing activity on other websites.
- Targeting and advertising cookies: These cookies track browsing habits and are used to deliver targeted (interest-based) advertising. They are also used to limit the number of times you see an ad and to measure the effectiveness of advertising campaigns. They are usually placed by advertising networks with the website operator's permission. They remember that you have visited a website and this information is shared with other organisations, such as advertisers.
Cookies we set
Cookies: _utma, _utmz, _ga, _gat, _gid (Performance)
We use Google Analytics to carry out statistical analysis of page use, page interactions and paths through the website to evaluate and develop our website. This is known as 'digital analytics'. We may also record certain information that customers provide during online applications. To opt out of being tracked via Google Analytics, you can also use Google's opt-out browser add-on: https://tools.google.com/dlpage/gaoptout.
Google DoubleClick Remarketing
Cookies: IDE (Targeting and advertising)
We use Google remarketing to advertise online using text or image ads on the Google Display Network. Remarketing is a feature that lets us reach people who have previously visited our site, and show them relevant ads when they visit other sites on the Google Display Network. You can opt-out of Google's remarketing program at http://www.google.com/ads/preferences/.
Visual Website Optimizer
Cookies: _vis_opt_exp_EXPERIMENT_ID_goal_GOAL_ID, _vis_opt_test_cookie, _vis_opt_exp_EXPERIMENT_ID_combi, _vis_opt_exp_EXPERIMENT_ID_exclude, _vis_opt_exp_EXPERIMENT_ID_split, _vis_opt_s, _vis_opt_out, _vwo_uuid
Cookies: _distillery, muxData (Performance)
Cookies: Ivsp (Performance)
We use Snowplow Analytics to carry out statistical analysis of page use, page interactions and paths through the website to evaluate and develop our website. This is known as 'digital analytics'. We may also record certain information that customers provide during online applications. Please refer to snowplowanalytics.com.
You can manage website cookies in your browser settings, and you always have the choice to change these settings by accepting, rejecting, or deleting cookies. If you choose to change your settings, you may find that certain functions and features will not work as intended on the Services. All browser settings are slightly different, so to manage cookies, you should refer to the relevant settings within your browser.
We understand that you may want to know more about cookies. Here are some useful resources that provide detailed information about types of cookies, how they are used, and how you can manage your cookie preferences: www.aboutcookies.org or www.allaboutcookies.org. Please click below for detailed information on how to disable and delete cookies in some commonly used browsers:
Other tracking technologies
- Local shared objects/Flash cookies: Flash cookies, also known as local shared objects, are designed to support browser content supported by Adobe® Flash. They are usually used to enable ads and video content on websites. Like other cookies, they will store information on your device, some of which will be specific to the Flash-enabled content. Flash cookies can only be deleted within Adobe Flash rather than via your browser. Please refer to the following help page for information on how to manage your privacy settings and deletion of Flash cookies: www.macromedia.com/support.
- Web beacons: Our web pages may contain electronic images known as web beacons (also called single-pixel gifs and transparent graphic images) that we use to help deliver cookies on our sites, count users who have visited those sites, deliver services, and analyse the effectiveness of our promotional campaigns, for example. We may also include web beacons in our marketing email messages or newsletters to determine whether an email is opened or if links are clicked.
Web server & application logs: Our servers automatically collect certain information to help us administer and protect the Services, analyse usage, and improve users' experience. The information collected includes:
- IP address and browser type
- Device information including Unique Device Identifier (UDID), MAC address, Identifier For Advertisers (IFA), and similar identifiers we or others may assign
- Device operating system and other technical facts
- The city, state, and country from which you access our website
- Pages visited and content viewed, stored, and purchased
- Information or text entered
- Links and buttons clicked
- URLs visited before and after you use our Services
Third Party Cookies
Security of your Personal Information
findandfundmycar.com secures your personal information from unauthorised access, use or disclosure. findandfundmycar.com 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.
Changes to this Statement
findandfundmycar.com will occasionally update this Statement of Privacy to reflect company and customer feedback. findandfundmycar.com encourages you to periodically review this Statement to be informed of how findandfundmycar.com is protecting your information.
findandfundmycar.com welcomes your comments regarding this Statement of Privacy. If you believe that findandfundmycar.com has not adhered to this Statement, please contact findandfundmycar.com at firstname.lastname@example.org, or write to us at findandfundmycar.com, 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.