Davenham Asset Finance Privacy Notice
At Davenham Asset Finance we take your privacy very seriously and this policy means that we will hold your personal information under the Data Protection Act 2018 ("DPA"). This policy contains important information about what to expect when Davenham Asset Finance collects personal information about you when you visit our website, or when you subscribe to our marketing communications. It also explains the specific ways we use and disclose that information, and lays out what you can do should you have any queries or concerns.
Who we are:
This website is owned and operated by Davenham Asset Finance Limited (Davenham), a company registered in England and Wales (Company number 08356079). Its Registered Office is 55 King Street Manchester M2 4LQ. The terms “Davenham”, “we”, “us”, “our” and “Davenham Asset Finance” shall be construed as Davenham Asset Finance Limited.
Davenham understands and respects how important your privacy is and we have implemented measures which will ensure any personal data that is obtained from you will be processed and maintained in line with accepted principles of good information handling and in accordance with the DPA.
Contained within this Privacy Notice, and set out below, are details of the type of information that we may hold about you, our customer, how we obtain and process any information we may have and, most importantly, how we will protect your privacy. Please read them carefully.
We may change this Privacy Notice from time to time. The collection of personal information through our website and storage, use, transfer and disclosure of personal information relating to individuals is subject to the Privacy Notice in effect at the time of that information being provided to us. We recommend that you review this Privacy Notice regularly for changes, and in any event, before submitting any personal information to us through our website.
Who is the Data Controller?
Any information that you provide on our website is controlled by Davenham. Davenham is registered as a data controller with the Information Commissioner’s Office in the United Kingdom under reference ZA002958.
If you have any queries about the information we hold about you, please use the following email address firstname.lastname@example.org or call us on 0161 832 8484.
What information we will collect:
You are free to access and browse our website at your convenience, and you do not have to provide any personal information / data. However, in certain circumstances, where you request information from us or send it to us through our site (for example, through online forms), you will be asked for personal information (such as your name, address, organisation/company name, telephone number and e-mail address). Certain information that we may request in online forms will be optional. Where personal information that we ask to be submitted is mandatory, to help us fulfil your request, this is identified in the online form. By sending personal information to us through our website, you confirm that it is current, accurate and complete, and that it does not include the unauthorised disclosure of any personal information (for example, relating to someone other than you). We will only collect personal information through our website that you knowingly provide (for example, when you submit an online form.
However, certain information – other than personal information about you – may be collected using various sources, technologies and methods without you actively providing it. Such information that we collect about you is derived from documents that are available to the public, such as the electoral register, Companies House or from third parties such as credit reference agencies and fraud prevention agencies.
Details of your visits to www.davenhamassetfinance.co.uk, including, but not limited to, traffic data, location data, web logs and other communication data are collected, along with details of the resources that you access whether this is required for our own purposes or otherwise.
Any information/data obtained from third parties is checked for accuracy and we will endeavor to check any information relating to you with you. The DPA requires Davenham and all organisations to maintain records of processing activities and the legal bases for processing such data. Davenham constantly reviews the data it holds about you, where this came from, how long we hold it and the legal basis for processing.
How we use your Personal Information:
When you provide us with your personal information it may be stored (by electronic and other means) and used by us for certain legitimate business purposes in some or all of the following ways:
- to enable us to provide services to you (and/or your organisation);
- to contact you and any person referred to by you in connection with your application or enquiry;
- to respond to requests for information from you;
- to follow up with you after you request information to see if we can provide any further assistance, including complaints;
- for statistical purposes - to analyse trends and profiles and carry out assessment and analysis (including credit, market and product analysis);
- to develop and improve the products and services we provide and/or may provide to you (and/or to your organisation);
- for our own administrative purposes (including, but not only), maintaining our records and compliance purposes;
- for crime prevention and detection including fraud (see section below);
- to ensure that our website's content is presented in the most effective manner for you and for your computer;
- for audit purposes;
- to carry out customer satisfaction research;
- to meet our regulatory compliance and reporting obligations;
- to contact you with marketing communications about our products and services available from us or our associated companies.
You have the right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted by us for marketing purposes you can unsubscribe from any of the emails we send to you or by contacting us by post at Davenham Asset Finance Limited, 55 King Street, Manchester, M2 4LQ or by calling us on 0161 832 8484.
Please note that we may monitor telephone calls made to us for fraud, security, legal compliance, and for training purposes.
WHAT IS OUR LEGAL BASIS FOR USING YOUR PERSONAL INFORMATION?
We only use your personal information where that is permitted by laws that protect your privacy rights.
We will only use your personal information where:
- we have your consent (if consent is needed);
- we need to use your personal information to perform a contract with you;
- we need to use the personal information for legal purposes;
- it is fair to use the personal information either in our interests or someone else's interests, where there is no disadvantage to you (what is known as a 'legitimate interest').
We may disclose your personal information as follows:
For the purposes we have set out above, we will share your personal information with:
- other organisations that we may engage to perform our functions or to advise us, provided that they will only be given access to your personal information to perform such functions or advise us and not for other purposes. Any such organisation will be engaged under a written contract in which it undertakes to adopt appropriate security measures in respect of yours and others’ personal data. For example, we may use third parties to maintain our IT systems.
- those third parties to whom you have consented to us sharing your personal information with (for example, but not only, where you ask us to pass on your details to a 3rd party finance company for the purposes of that company contacting you).
- credit reference, fraud prevention, law enforcement agencies and identity and address verification agencies whom may record and use your information and disclose it to other organisations for credit reference, debt tracing, fraud and money laundering prevention purposes. Please see below for further information.
- purchasers or prospective purchasers and their advisers in connection with and for the purpose of the sale, assignment or other transfer of our business or part of it or any contracts entered into between you (and/or your organisation) and us.
- Davenham's panel of funders and their advisers in connection with, and for the purpose of security, sale and assignment of it's funding contracts to procure debt finance.
- third parties who shall assist us with verifying your identity and we may also carry out credit assessments on you.
- regulatory bodies, law enforcement agencies or governmental authorities, where we are required to do so or such disclosure is authorised by law or a court order.
Transferring your personal data outside the European Economic Area ('EEA')
We may sometimes transfer your personal information to countries that do not provide the same level of data protection as the United Kingdom. If we intend to do this, then (other than in the circumstances described above, where practical and appropriate, before doing so) we will put contractual arrangements in place to ensure the adequate protection of your information and we shall endeavor to ensure that any such contractual arrangements comply with the those standards required by the Information Commissioner. If you would like more information or the details of the safeguards we have in place to protect your personal information please contact our Compliance Manager at Compliance@davenhamassetfinance.co.uk.
Fraud prevention agencies & credit referencing:
To help make relevant decisions on any application we will engage fraud prevention agencies and credit reference agencies as follows.
- Fraud Prevention Agencies ("FPA")
When we assess an application we may share your personal information with FPAs to check your identity. We do this to prevent fraud and crime; this includes money laundering / Proceeds of Crime etc. This results of this check will then be used to consider whether to offer credit. We have regulatory obligations to comply with responsible lending, FPAs and CRAs (as defined below) assist us in doing so.
Further information on fraud prevention agencies can be obtained from our Compliance Manager by emailing Compliance@davenhamassetfinance.co.uk.
- Credit Reference Agencies ("CRA")
When we assess an application we may share your personal information with CRAs to assess your credit worthiness. When this type of check is made a footprint will appear on your credit file, this can be seen by other lenders. CRAs provide us with shared credit information, fraud prevention information and public information (which shall include information held in the electoral register).
You may contact any or all the CRA’s directly. If you choose to contact a CRA, please bear in mind that the information held may not be the same so it may be useful to contact all CRAs. We have provided below contact details for the CRAs:
· Equifax Plc, Credit File Advice Centre, PO Box 3001, Bradford, BD1 5US, Tel number 0870 010 0583, www.equifax.co.uk
· Experian, Consumer Help Service, PO Box 8000, Nottingham, NG80 7WF, 0844 4818000, www.experian.co.uk
· CallCredit, Consumer Services Team, PO Box 491, Leeds, LS3 1WZ, 0870 060141]
Information received by CRAs will be recorded by them. If after making an application for finance to us, you enter into a finance agreement, the activity and details of management of your account will be passed onto CRAs. In the event that you take out a finance agreement and fail to repay back the full funds this will also be recorded with the CRA. In this case information may be passed onto other companies by CRAs in order to locate and trace you to seek recovery of any outstanding debts. If this does occur then this will remain on your credit reference file for 6 years following the closure of an outstanding debt.
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 period and your data protection rights with the CRAs are explained in more detail by the three main CRAs (Callcredit, Equifax and Experian). You can find a copy of their Credit Reference Agency Information Notice ("CRAIN") at [Link Here] or by emailing our Compliance Manager at Compliance@davenhamassetfinance.co.uk.
Inaccurate information provided by you:
Any false or inaccurate information given to us by you and/or any suspicion by us of fraud will be brought to the attention of FPAs or other relevant companies who deal in fraud/crime prevention. Any reported instances may also be accessed by law enforcement agencies i.e. HMRC, regulatory bodies or the police, for use to prevent any possible fraud and money laundering in respect of:
- managing credit and credit related accounts or facilities;
- recovering debt;
- checking details on proposals and claims for all types of insurance;
- checking details of job applicants and employees; and
- information recorded outside the UK:
Are Children Allowed to Use Davenham Asset Finance?
Davenham doesn’t sell or discuss finance agreements with children. If you’re under 18, you may not use www.davenhamassetfinance.co.uk for the purpose of making a finance application. Davenham has processes and mechanisms in place to verify the age of users.
Where we store your Personal Information and Security:
Davenham are committed to protecting the security of your personal information.
We have security procedures covering the storage and disclosure of your personal information to prevent unauthorised access and to comply with our legal obligations. All information you provide to us is stored on secure servers.
Please be aware that the internet is not secure and we cannot make any assurances about the security of your personal information during transmission to our server(s). For example, when you send information to us through our online forms, your details are not transmitted using encryption technology. In deciding whether to send information to us through online forms or e-mail, you should consider this.
We will do our best to protect your information. We cannot guarantee the security of your information transmitted to www.davenhamassetfinance.co.uk; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Cookie collection and usage:
To enable us to provide a better service and to assist our prevention of fraud, we may send “cookies” from this web site to your device.
Two types of cookies may be used on the web site, session cookies, which are temporary cookies that remain in the cookie file of your browser until you leave the web site, and persistent cookies, which remain in the cookie file of your browser for much longer (though how long will depend on the lifetime of the specific cookie). You may set up your browser to disallow cookies, but your experience of this web site may be compromised as a result. You may also set up your browser to inform you when cookies are sent.
Also, when you access our web site, our server records your IP address (which is the number assigned to your computer by your internet service provider). This alone does not enable us to identify you nor does it provide us with personal information about you. We may use your IP address for statistical and analytical purposes, crime prevention and detection, and may disclose it in the circumstances described above.
If you choose not to accept cookies on www.davenhamassetfinance.co.uk this may affect the quality of your visit to the Davenham website, and any potential future use of the Davenham website.
For more information on cookies (including how to switch them off) please visit www.allaboutcookies.org
You can contact us by post at Davenham Asset Finance Limited, 55 King Street, Manchester, M2 4LQ; by telephone on 0161 832 8484; or by email Compliance@davenhamassetfinance.co.uk to exercise any of the following rights;
- right of access – you may request access to a copy of your personal information that we use, 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 rectification - you may ask us to change or complete any inaccurate or incomplete personal information held about you;
- right to erasure - you may 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;
- right to restrict processing - you may 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;
- right to data portability - you may ask us to provide you or a third party with the personal information that we hold about you in a structured, commonly used, electronic form, so it can be easily transferred;
- right to object - you may object to our processing of your personal information pursuant to this Privacy Notice.
To protect your privacy and the security of your information, we are required to take reasonable steps to verify your identity before we act on any request which you may make in respect of Your Information.
You may make a complaint about how we have used your personal information to a supervisory authority - for the UK this is the Information Commissioner's Office, at https://ico.org.uk/
Notification of Breach
Davenham will inform you at the first sign of a data breach. In compliance with the DPA we want to make sure we are being completely transparent with you regarding your data and the security of your data. We will contact you via email or phone, to inform you of any suspicious activity.
How long do we keep your information for?
The amount of time we hold your information for depends on the basis it was provided by you to us.
If you request that we do not contact you for marketing reasons, then we will remove your details from our marketing database. We are still legally required to keep your information.
Information you may enter via our website will be kept for a minimum of 9 years which will commence at the end of the relationship. We are required to do this to ensure that if any disputes or complaints are raised, then we have your information to enable us to address the complaints or disputes.
In order to provide you with a service we will be required to keep your information whilst we continue to provide you with a service for however long this may take us.
Davenham may choose to amend the content of this privacy notice on occasion. If this occurs then we will update the notice and the revised notice will be posted on our website, please be aware that this Privacy Notice was last updated on the 25/05/2018. We may update this Privacy Notice from time to time. Please ensure that you check our Privacy Notice regularly for updates.
Davenham’s website may, from time to time, contain links to and from the websites of our affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we cannot accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.