We are committed to collecting and using data fairly and in accordance with the requirements of the General Data Protection Regulation (GDPR).
Your information will be held by First European Finance (Scotland) Limited.
Our Privacy Promise
- To keep your data safe and private.
- Not to sell your data.
- To give you ways to manage and review your marketing choices at anytime.
Who we are
First European Finance (Scotland) Limited. You can find out about us at www.first-european.co.uk
If you have any questions, or want more details about how we use your personal information, you can get in touch with us at email@example.com.
Or you can call us on 0330 0947 350.
How the law protects you
As well as our Privacy Promise, your privacy is protected by law.
Data protection law says that we are allowed to use personal information only if we have a proper reason to do so. The law says we must have one or more of these reasons:
- To fulfil a contract we have with you
- When it is our legal duty
- When it is in our legitimate interest
- When you consent to it
A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you.
You have the right to object to how we process your personal information. You also have the right to access, correct, sometimes delete and restrict the personal information we use.
You can contact us at firstname.lastname@example.org to exercise any of the following privacy rights:
Right to object
You can object to our processing of your personal information. Please contact us as noted above, providing details of your objection.
Access to your personal information
You can request access to a copy of your personal information that we hold, along with information on what personal information we use, why we use it, who we share it with, how long we keep it for and whether it has been used for any automated decision making.
Right to withdraw consent
If you have given us your consent to use personal information, you can withdraw your consent at any time and, update your marketing preferences by emailing us directly or by using the unsubscribe options on any email marketing.
You can ask us to change or complete any inaccurate or incomplete personal information held about you.
You can ask us to delete your personal information where it is no longer necessary for us to use it, you have withdrawn consent, or where we have no lawful basis for keeping it.
You can ask us to provide you or a third party with some of the personal information that we hold about you in a structured, commonly used, electronic form, so it can be easily transferred.
You can ask us to restrict the personal information we use about you where you have asked for it to be erased or where you have objected to our use of it.
Make a complaint
You can make a complaint about how we have used your personal information to us, by emailing us directly at email@example.com
Where we collect personal information from
In addition to the information you provide to us directly, we collect personal information in a number of ways, for example from third party credit reference agencies and from looking at how you have used other products and services that we offer.
Sometimes for your safety and for legal reasons we collect personal information by recording and monitoring calls. We also record calls for training purposes.
We obtain personal information:
- Directly from you, for example when you fill in any web based forms or online applications.
- By observing how you use our products and services.
- From other organisations such as credit reference and fraud prevention agencies.
- From other people who know you, including joint account holders and people linked to you financially.
Credit Reference Agencies (CRAs)
We carry out credit and identity checks when you apply for a product or services for you or your business. We may use Credit Reference Agencies to help us with this.
If you use our services, from time to time we may also search information that the CRAs have, to help us manage those accounts.
We will share your personal information with CRAs and they will give us information about you. The data we exchange can include:
- Name, address and date of birth
- Credit applications
- Details of any shared credit
- Financial situation and history
- Public information, from sources such as the electoral register and Companies House.
We’ll use this data to:
- Assess whether you or your business is able to afford to make repayments
- Make sure what you’ve told us is true and correct
- Help detect and prevent financial crime
- Manage accounts with us
- Trace and recover debts
- Make sure that we tell you about relevant offers.
We will go on sharing your personal information with CRAs for as long as you are a customer. This will include details about your settled accounts and any debts not fully repaid on time. It will also include details of funds going into the account, and the account balance. We will also tell the CRAs when you settle your accounts with us.
When we ask CRAs about you or your business, they will note it on your credit file. This is called a credit search. Other lenders may see this and we may see credit searches from other lenders.
You should tell them about this before you apply for a product or service. It is important that they know your records will be linked together, and that credit searches may be made on them.
CRAs will also link your records together. These links will stay on your files unless one of you asks the CRAs to break the link. You will normally need to give proof that you no longer have a financial link with each other.
You can find out more about the CRAs on their websites, in the Credit Reference Agency Information Notice. This includes details about:
- Who they are
- Their role as fraud prevention agencies
- The data they hold and how they use it
- How they share personal information
- How long they can keep data
- Your data protection rights.
Fraud Prevention Agencies (FPAs)
We may need to confirm your identity before we provide products or services to you or your business. Once you have become a customer of ours, we will also share your personal information as needed to help detect fraud and money-laundering risks. We use Fraud Prevention Agencies to help us with this.
Both we and fraud prevention agencies can only use your personal information if we have a proper reason to do so. It must be needed either for us to obey the law, or for a legitimate interest’.
A legitimate interest is when we have a business or commercial reason to use your information. This must not unfairly go against what is right and best for you.
We will use the information to:
- Confirm identities
- Help prevent fraud and money-laundering
- Fulfil any contracts you or your business has with us.
We or an FPA may allow law enforcement agencies to access your personal information. This is to support their duty to detect, investigate, prevent and prosecute crime.
FPAs can keep personal information for different lengths of time. They can keep your data for up to six years if they find a risk of fraud or money-laundering.
How we use your personal information
We use your personal information to provide you with products and services (including credit checks), to comply with the law and enforce our legal rights (including debt recovery), and to improve and market our products and services.
We sometimes need to gather, use and share additional personal information for specific purposes, which are:
- To operate and administer our products and services, including dealing with your complaints and fixing our mistakes
- To administer payments to and from you
- To make credit decisions about you (including new applications for credit or requests to increase credit limits)
- To advise on the suitability of our products and services.
- To comply with our legal obligations, to prevent financial crime including fraud and money laundering
- For financial management and debt recovery purposes
- To enable payments to third parties
- To carry out market research and analysis to develop and improve our products and services
- To market products and services to you from us or our partners
How we use your information to make automated decisions
We sometimes use systems to make automated decisions based on personal information we have – or are allowed to collect from others – about you or your business. This helps us to make sure our decisions are quick, fair, efficient and correct, based on what we know. These automated decisions can affect the products, services or features we may offer you now or in the future, or the price that we charge you for them.
As a person you have rights over automated decisions.
- You can ask that we do not make our decision based on the automated score alone.
- You can object to an automated decision, and ask that a person reviews it.
If you want to know more about these rights, please contact us on firstname.lastname@example.org
Who we share your personal information with
We will share personal information with our suppliers and other third parties where we need to do that to make products and services available to you, market products and services to you, meet or enforce a legal obligation or where it is fair and reasonable for us to do so. It may be necessary for us to approach more than one lender or finance house from our panel of providers to have credit facilities agreed and this may result in several credit searches being registered on your credit file. If you are a company or partnership, these searches will also be made in respect of any of your directors and partners.
Most of the time the personal information we have about you is information you have given to us, or gathered by us in the course of providing products and services to you. We also sometimes gather personal information from and send personal information to third parties where necessary for credit checking and fraud prevention or marketing purposes, for example so you can receive the best offers from us and our partners.
We will only share your personal information to the extent needed for those purposes
Sending data outside of the EEA
We will only send your data outside of the European Economic Area (EEA) to:
- Follow your instructions.
- Comply with a legal duty.
- Work with our agents and advisers who we use to help run your accounts and services.
If we do transfer information outside of the EEA, we will make sure that it is protected in the same way as if it was being used in the EEA.
Any information that we hold about you will be used to supply our goods and services to your business. We will only use or share your information to the extent needed for those purposes.
We may use your personal information to tell you about relevant products and offers. This is what we mean when we talk about ‘marketing’.
The personal information we have for you is made up of what you tell us, and data we collect when you use our services, or from third parties we work with.
We study this to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
We can only use your personal information to send you marketing messages if we have either your consent or a ‘legitimate interest’. That is when we have a business or commercial reason to use your information. It must not unfairly go against what is right and best for you.
You can ask us to stop sending you marketing messages by contacting us at any time or by using the unsubscribe option on any email marketing.
Whatever you choose, you may still receive other important information such as changes to your existing products and services.
We may ask you to confirm or update your choices, if you take out any new products or services with us in future. We will also ask you to do this if there are changes in the law, regulation, or the structure of our business.
If you change your mind you can update your choices at any time by contacting us.
If you choose not to give personal information
We may need to collect personal information by law, or under the terms of a contract we have with you.
If you choose not to give us this personal information, it may delay or prevent us from meeting our obligations. It may also mean that we cannot perform services needed to run your accounts or policies. It could mean that we cancel a product or service you have with us.
Any data collection that is optional would be made clear at the point of collection.
How long we keep your personal information for
We will keep your personal information securely for as long as we need to and this will depend on the products and services we deliver to you
We will not retain your personal information for any longer than is necessary for the purposes we need to use it for.
What Are Cookies And Why Do We Use Them?
Types of Cookies We Use And The Information They Store
The cookies we use are for analytical purposes and don’t store any personal information apart from the information you choose to input on our site. As well as for web traffic analysis, our cookies are used to automatically pre-populate fields in forms for the sole reason of saving you the effort of filling them out multiple times!
We use both session and persistent cookies on our site which improve your experience and allow us to see how many new and returning visitors have been on our site. This information is obtained by tracing a device’s IP address, and includes which pages were visited, how many pages were visited, the length of time spent on each page and rough location etc.
Because we use Google and Adobe analytical technology, cookies may be left on your device from these organisations. These are the only “third party” cookies you may receive from our site.
Importantly, we will never attempt to personally identify you from your IP address unless required to as a matter of law or regulation or in order to protect our, or our other customers’ rights.
If you don’t want to accept cookies from our site that’s fine, but your experience of using the site will be compromised and certain aspects may not function properly or at all. Most modern browsers have an option that allows you to surf the web without accepting cookies, or to only accept cookies from the sites that you choose to. If you wish to delete cookies from your computer this is possible in your browser settings.