Data Privacy Policy

The information we collect includes some or all of the following:

1. Full name (including title);
2. Address;
3. Phone number;
4. Date of birth;
5. Email address;
6. Vehicle information (including registration number, VIN, service reminders, mileage and warranty repair information);
7. The date and time you used our services;
8. The pages you visited on our website and how long you visited us for;
9. Device identifiers such as your IP address;
10. Your GPS location (where you have permitted access to this);
11. The internet browser and devices you are using;
12. Cookie, Pixels or Beacon information (for more information please see our Cookie Policy);
13. The website address from which you accessed our website;
14. Details of any transactions between you and us or any franchised retailer;
15. Where you engage with us in a business context, we may collect your job title, company contact details (including email addresses), fleet size and company details (some of which we may obtain from an online or public business directories);
16. Voice recordings of calls you make to our customer service centre;
17. “Live chat” records;
18. Any information within correspondence you send to us;
19. Credit Reference Data;
20. Financial and employment details;
21. Banking and credit card details;
22. Documentation relating to your identification; and
23. CCTV.

We only collect information which is necessary, relevant and adequate for the purpose you are providing it for.

We may collect information about you (and/or your vehicle) from:

• You, including if you contact us (including any email address, Internet Protocol (IP) address or telephone number supplied by your electronic service provider) or if you use our products or services, or engage with our website or other online applications;
• Third parties, such as credit reference agencies (we will supply your personal information to credit reference agencies (“CRAs”) and they will give us information about you, such as your financial history);
• Our franchised retailers or repairers (some of this information does not identify you personally, but provides us with information about how you use our services and engage with us and we use this information to improve our services and make them more useful to you); and/or
• Other companies who provide services to us, such as insurance companies.

We may also collect information about you (and/or your vehicle) when you use:

• VWFS’s websites and applications. This online information includes some or all of the following:
  • Information you provide when you register to use the sites, browse content on the sites or use other functionality;
  • Details of your visits to the sites including, but not limited to traffic data, location data and other communication data, and the resources that you access; and/or
  • Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform (please see further our Cookies Policy);
• VWFS’s customer services centre. In particular, we may record telephone calls for training, monitoring, service delivery and internal compliance purposes. Similarly, all email, other electronic correspondence and any postal mail between us will also be stored for the same purposes.

Some of the information that we may obtain about you or your vehicle from our franchised retailers, insurance companies and repairers does not identify you personally, but provides us with information about how you use our services and engage with us (we use this information to improve our services and make them more useful to you).

If you are a fleet customer, we may also obtain additional information required in order for you or your employer to receive or use services on our sites, including but not limited to polls, live chat and personalised services, as well as data required for VWFS to provide products and services to you or your employer or to help us identify you when you contact us.

VWFS will only process information that is necessary for the purpose for which it has been collected. You will always have the option to opt out of receiving marketing communications from us and you can withdraw your consent or object at any time. We will never send you unsolicited ‘junk’ email or communications, or share your personal information with anyone else who might.

There are various ways in which we may use or process your personal information. We list these below:

Where you have provided your consent, we may use and process your information (including cookie data) to contact you from time to time about promotions, events, products, services or information which we think may be of interest to you. For further information on our use of cookie data, please see our Cookie policy

You can withdraw your consent at any time by contacting us on the details stated in the section below titled How can you manage the information we hold about you? or, in relation to any marketing messages you receive, by using the unsubscribe option included in those messages.

We may use and process your personal information where this is necessary to perform and manage a contract with you, for example, if you are a finance customer, to enable us to manage your account, including responding to your enquiries and complaints and to recover debts.

We may use and process your personal information as set out below where it is necessary for us to carry out activities for which it is in our legitimate interests as a business to do so.

We may also contact you from time to time about promotions, events, products, services or information which we think may be of interest to you and (where you are a finance customer) to communicate your end of contract or contract renewal option(s), where applicable.

1. To respond to correspondence you send to us and fulfil the requests you make to us (for example, with regards to your finance agreement or account with us);

2. To provide vehicle support and services (for example, with regards to maintenance or insurance);

1. To analyse, evaluate and improve our products and services so that your visit and use of our website, applications, customer service centre and dealer network are more useful and enjoyable (we will generally use data gathered from many people so that it doesn’t identify you personally);
2. To undertake market analysis and research (including contacting you with customer surveys) so that we can better understand you as a customer and provide tailored offers, products and services that we think you will be interested in. We will only send marketing communications to you if you have provided your consent for us to do so or which we have obtained in the ways mentioned in the paragraphs below;
3. For product development purposes (for example to improve vehicle quality, performance and safety);

1. To send you marketing information from time to time after you have purchased a product or service from us or made a purchasing enquiry, closed your browser with items in your shopping basket or requested a test drive, brochure or other information of interest. We will only contact you with information about our own products and services (and in ways the law allows). You have the right to object to us sending you this information at any time;
2. To contact you from time to time with marketing information (unless you object) if you have expressly indicated to us that you are acting on behalf of a business or where we have obtained your business contact details from our authorised dealer network or an online or public business directory. In relation to any such information we send by email or SMS, we will include an option allowing you to object to receiving future messages by unsubscribing;
3. To contact you with targeted advertising delivered online through social media and other platforms operated by other companies, unless you object. You may receive advertising based on information about you that we have provided to the platform or because, at our request, the platform has identified you as having similar attributes to the individuals whose details it has received from us. To find out more, please refer to the information provided in the help pages of the platforms on which you receive advertising from us;
4. To identify and record when you have received, opened or engaged with our website or electronic communications (please see our Cookie policy for more information);
5. To administer competitions and promotions that you enter with us from time to time and to distribute prizes;
6. To contact you when your local franchised retailer opens, closes or moves premises;
7. To obtain analytics including those received from search engine providers that assist us in the improvement and optimisation of the site;

1. To respond to queries, complaints or claims and to manage legal and regulatory requests and requirements;
2. To enforce or protect our legal rights or to establish, bring or defend legal claims;
3. To verify the accuracy of information that we hold about you and create a better understanding of you as a customer;
4. For network and information security purposes i.e. in order for us to take steps to protect your information against loss, damage, theft or unauthorised access;
5. To comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);
6. To inform you of updates to our terms and conditions and policies, where possible;

1. To verify the accuracy of information that we hold about you and create a better understanding of you as a customer;
2. For network and information security purposes i.e. in order for us to take steps to protect your information against loss, damage, theft or unauthorised access;
3. To comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);
4. To inform you of updates to our terms and conditions and policies, where possible;

1. To comply with our obligations before we provide finance, goods or services to you as both a responsible lender and FCA authorised firm, such as assessing creditworthiness and product suitability, verifying your identity, managing your account, tracing and recovering debts and preventing criminal activity. We will also continue to exchange information about you with CRAs on an ongoing basis, including about your settled accounts and any debts not fully repaid on time. CRAs will share your information with other organisations. If you have made a joint finance application to us, or tell us that you have a spouse or financial associate, we will link your records together, so you should make sure that you have discussed this with them, and share with them this information, before lodging the application. CRAs will also link your records together and these links will remain on your and their files until such time as you or your partner successfully files for a disassociation with the CRAs to break that link;
2. To prevent fraud and money laundering, and to verify identity before we provide services, goods or financing to you;
3. To ensure that we continue to fulfil our ongoing obligations with regards to preventing fraud and money laundering and to verify identity, in order to protect our business and to comply with laws that apply to us. If we, or a fraud prevention agency, consider you to pose a fraud or money laundering risk, we may refuse to provide the services and financing you have requested, or we may stop providing existing services to you. A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and 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 below;
4. To enable us to assess fraud or money laundering risk by automated means, which may indicate that you pose a risk or 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. You have rights in relation to automated decision making: if you want to know more please contact the Data Protection Officer using the details below; and/or
5. To comply with other legal or regulatory requirements (for example, to register your car with the DVLA), to assist, or respond to a request for information from, an authorised authority, regulatory body or court, or to respond to a court order.

Sometimes we will need to process your personal information to contact you if there is an urgent safety or product recall notice and we need to tell you about it.

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We do not sell your information to third parties but we do work closely with our franchised retailers and third party service providers who fulfil business activities for us (like roadside assistance, marketing, events and market research etc.) In addition, we may have a legal or other obligation to share your personal information.

From time to time, we may disclose your information to companies or organisations:

• Where the law says we may or must do so;
• Where we have ongoing reporting obligations to credit reference agencies;
• To comply with our ongoing obligations to prevent fraud and money laundering by allowing law enforcement and fraud prevention agencies to access and use your personal information to detect, investigate and prevent crime;
• To companies that provide services to us so we can perform activities relating to your contract and/or to enforce any contract we have with you and/or to protect our rights and/or property;
• To our franchised retailers to provide you with information about your application and our products and services or to manage any request or complaint you have made to us; or
• To our advisors, and investors and their advisors for corporate finance purposes, for example, in the event that we sell or buy any business or assets, or if VWFS or substantially all of its assets are acquired by a third party

There are circumstances where we share your information with our parent company (or other companies within our Group), where necessary, in order to:

• Fulfil orders;
• Facilitate transactions;
• Handle complaints;
• Provide you with service(s) or information that you have requested;
• Facilitate audit, statistical analysis, risk management and product and service development purposes;
• Co-ordinate and manage customer contract renewals (see ‘customer contract renewals’ section below); and
• Comply with legal requirements

For example, we will share information with branded trading divisions of Volkswagen Group United Kingdom Limited (“VWG”) where you enquire about their services through us, or where you make a complaint to us and later make the same or similar complaint to them.

Customer contract renewals:

In connection with customer contract renewals, VWFS and VWG work together to ensure that follow up activities relating to the renewal of your finance contract(s) are performed as effectively and efficiently as possible. This is achieved, in part, by the sharing of your personal information between VWFS and VWG (and subsequently, with our franchised, authorised retailer network) to co-ordinate and manage the renewals process. For the purposes of data protection laws, VWFS and VWG are “joint data controllers” of this processing of your personal information. This means that both businesses work together to decide why and how your personal information is processed and are jointly responsible to you under the law for that processing. As such, VWFS and VWG have prepared a ‘Joint Privacy Statement’ which describes the relationship between VWFS and VWG, our data protection responsibilities and the personal information that is shared between the parties in respect of finance contract renewals.

Other purposes:

In addition, both VWFS and VWG utilise a Customer Engagement Platform (CEP) for the purposes of:

• personalising marketing material, including offers and information regarding products and services which may be of interest to you;
• enhancing your online journeys.

For CEP to operate effectively, VWFS and VWG share certain personal data and cookie data relating to customers and/or websites users. The information shared between VWFS and VWG is the minimum required to fulfil the purpose. Both VWFS and VWG are committed to protecting and respecting any personal data and cookie data shared in accordance with data protection laws. For data protection purposes, VWFS and VWG are independent and separate data controllers of the personal and cookie data utilised by CEP.

For more information regarding VWG’s data protection policy or to object to VWG’s use of your information, please visit the brand’s website and/or the VWG Privacy Statement

We will also share your personal information with third parties and/or other companies within our Group if we have a duty to do so, e.g. to register your car with the DVLA, to assist an authorised authority, regulatory body or court, or to enforce or protect our legal rights or to establish, bring or defend legal claims.

We take steps to ensure that any third party partners who handle your information comply with data protection legislation and protect your information just as we do. We only disclose personal information that is necessary for them to provide the service that they are undertaking on our behalf. We will aim to anonymise your information or use aggregated none specific data sets wherever possible.

Due to the international nature of our business, there may be some instances where your information is processed or stored outside of the EU. In those instances, we will ensure that appropriate safeguards are in place for that transfer and storage as required by applicable law.

In addition, fraud prevention agencies may allow the transfer of your personal data outside of the UK. This may be to a country where the UK Government has decided that your data will be protected to UK standards, but if the transfer is to another type of country, then the fraud prevention agencies will ensure your data continues to be protected by ensuring appropriate safeguards are in place.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and/or other third parties who have a business need to know it. They will only process your personal information on our instructions and are subject to a duty of confidentiality. Details of these measures may be obtained from the Data Protection Officer (please see contact details below).

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

Finally, we have established procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We do not retain personal information in an identifiable format for longer than is necessary.

If we have a relationship with you (e.g. you are a customer), we hold your personal information for 6 years from the date our relationship ends. We hold your personal information for this period to establish, bring or defend legal claims. Our relationship may end for a number of reasons including where the vehicle lease expires, or we have been made aware that you no longer own or drive that vehicle.

Where we have obtained your personal information following a request for information, such as a quotation for finance or any other information on any of our products or services, we hold your personal information for 1 year and 6 months from the date we collect that information, unless during that period we form a relationship with you e.g. you lease a vehicle. We hold your personal information for this period to give us an opportunity to form a relationship with you.

The only exceptions to the periods mentioned above are where:

• The law requires us to hold your personal information for a longer period, or delete it sooner;
• You have raised a complaint or concern regarding a product or service offered by us, in which case we will retain your information for a period of 6 years following the date of that complaint or query; or
• You exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law (see further information below on how can you manage the information we hold about you section

In addition, fraud prevention agencies can hold your personal information 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 years.

You have the right as an individual to access the personal information that we hold about you and make corrections if necessary. You also have the right to withdraw any consent you have previously given us and ask us to erase information we hold about you. You can also object to our use of your personal information (where we rely on our business interests to process and use your personal information).

You have a number of rights in relation to your personal information under data protection law. In relation to most rights, we will ask you for information to confirm your identity and, where applicable, to help us search for your personal information. We will respond to you within 30 days (unless there are exceptional circumstances) after we have received any request (including any identification documents requested).

You have the right to:

1. Ask for a copy of the information that we hold about you;
2. Correct and update your information;
3. Withdraw your consent (where we rely on it). Please see further information on how we use your information below
4. Object to our use of your information (where we rely on our legitimate interests to use your personal information) provided we do not have any continuing lawful reason to continue to use and process the information. When we do rely on our legitimate interests to use your personal information for direct marketing, we will always comply with your right to object;
5. Erase your information (or restrict the use of it), provided we do not have any continuing lawful reason to continue to use and process that information; and/or
6. Transfer your information in a structured data file (in a commonly used and machine readable format), where we rely on your consent to use and process your personal information or need to process it in connection with your contract.

You can exercise the above rights and/or manage your information by contacting us using the details below:

Post: Volkswagen Financial Services (UK) Limited, One Delaware Drive, Tongwell, Milton Keynes MK15 8HG

Email: DPO@vwfs.co.uk

If you have any specific data protection concerns or a complaint, you can address it to our Data Protection Team at DPO@vwfs.co.uk

You also have the right to lodge a complaint with a data protection regulator in Europe, in particular in a country you work or live or where your legal rights have been infringed. The contact details for the Information Commissioner’s Office, the data protection regulator in the UK, are below:

Post:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Call: 0303 123 1113

If you wish to raise a complaint to the ICO, you can do so via their website under ‘Make a complaint’ on the attached link: https://ico.org.uk/make-a-complaint/.

If you would like further information about the identities of the CRAs, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRAs, this is explained in more detail and is accessible from each of the three CRAs – clicking on any of these three links will also take you to the same CRAIN document:

Call Credit:
www.callcredit.co.uk/crain

Equifax
www.equifax.co.uk/crain

Experian:
www.experian.co.uk/crain

If you would like further information regarding how the fraud prevention agencies process your personal data, you can view their privacy policies on their websites, as below:

CIFAS:

• https://www.cifas.org.uk/

Hunter:

• https://www.nhunter.co.uk/