Who we are

1. We are Startline Motor Finance Ltd (known as Startline), a company registered in England & Wales (company number 08302453) whose registered office is at 6th Floor, 60 Gracechurch Street, London, EC3V 0HR. Our principal trading office is at Suite 6/1, Skypark 1, 8 Elliot Place, Glasgow, G3 8EP. We are a data controller for the purposes of the General Data Protection Regulation (Regulation (EU) 2016/679) and related data protection legislation. Our registration number at the Information Commissioner's Office is ZA006163.

How to contact us

1. If you have any questions about this privacy notice or our data protection policies generally, please contact us: By post: Startline Motor Finance Ltd, Suite 6/1, Skypark 1, 8 Elliot Place, Glasgow, G3 8EP By email: enquiries@startlinemotorfinance.com By phone: 02920 853 528

Privacy notice

1. We are committed to protecting your personal data and your privacy. This privacy notice aims to give you information on how we collect and process your personal data through your use of our website (including any data that you may provide through our website) and through your other communications with us.
2. Before we process your personal data, we are obliged to inform you of who we are, why we need to process your personal data, what we will do with your personal data and to whom we will pass your personal data.
3. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
4. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
5. This version of this privacy notice was last updated on 24 May 2018.

Visitors to the website

What information do we collect and process?

1. When you visit our website (as hosted on www.startlinemotorfinance.com or any other domain name registered in our name), we use Google Analytics to automatically collect information about your computer, including your IP address, information about your visit, your browsing history, and how you use our website. We use cookies within our website. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. If you contact us via our website, please see the "People who contact us" section below.

Children

1. Our website is not intended for children and we do not knowingly collect data relating to children.

How is your information used?

1. We use six cookies (in the table below) that provide tracking data to a third party application, namely Google Analytics, and will remain in the cookie file of yourbrowser even after it is closed. You can select to manually delete these from the cookie file in your browser after you have left our website if you prefer.

   COOKIE	TYPE	DURATION	DESCRIPTION
   _ga	persistant	2 years	Google Analytics, used to distinguish users.
   _gat	persistant	1 minute	Google Analytics, used to throttle request rate. If Google Analytics is deployed via Google Tag Manager, this cookie will be named _dc_gtm_
   _gid	persistant	24 hours	Google analytics used to distinguish users
   viewed_cookie_policy	session	session	Cookie policy viewer cookie
   woocommerce_cart_hash	session	session	Commerce cart hashing, so we can securely send cart details to payment gateway
   woocommerce_items_in_cart	session	session only	Cookie to remember what you have added to your cart

   Further information about the cookies provided by Google Analytics, including a privacy statement relating to such cookies, can be found at: https://support.google.com/analytics/answer/6004245. We also use one other cookie, called catAccCookies. This is also a third party cookie set by the UK cookie consent plugin to record that you accept the fact that the website uses cookies, and is set in your computer to prevent the cookie notification from coming up again. The cookie is set to expire 1 month after your visit. Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout. We do not use such information for any form of automatic decision-making, including profiling.

With whom do we share your information?

1. Google Analytics will have access to the website visitor information. We do not permit Google Analytics to access or process your data except in accordance with our instructions.

Lawful processing

1. When we process your personal data for the purposes of improving our website, we do so on the basis of our legitimate interests in maintaining a relevant and functioning website, in maintaining network security and improving customer experience by studying how visitors use our website and what pages interest them most.

How long do we retain your data?

1. Personal data contained within a cookie is retained until its expiry date, as set out in the cookie table below.

Third party links

1. Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. People who contact us by phone, e-mail, website contact forms or other means
   1. What information do we collect and process?
   2. Telephone - When you call us, we will collect your name and telephone number, and where relevant, we may collect other details including other contact details and information relating to any contract for products or services. Your telephone call may be recorded In writing – when you contact us either via email, by completing a contact form on our website, or through a postal method, we will collect any personal data contained in such correspondence. We may electronically store this correspondence and any attachments.
   3. How is your information used?
   4. We may use any information obtained by telephone, e-mail, website contact form or other media to handle customer and other enquiries, including addressing any complaints. This may include contacting you to discuss any such enquiries or complaints. We may monitor e-mails and other electronic messages for security reasons. We use e-mail monitoring or blocking software (spam filters). We may also use any personal information obtained by telephone, e-mail, website contact form or other media to improve our internal processes, including staff training and quality control.
   5. With whom do we share your information?
   6. Customers (including guarantors) - we may share your information with third parties, including fraud prevention agencies, third party service providers (including banks, software service providers, loan servicing providers, debt collection agents and vehicle valuation companies), our funders or our or your legal advisers and other professional advisors. For more information about how we process customer information, please see our fair processing notice here [http://startline/FPN].Non-customers - we do not share your information with third party controllers unless otherwise specified in this privacy notice or unless we have obtained your consent to any such processing. Your data may be added to an existing customer's records if relevant (e.g. you are a guarantor for an existing customer, you are making a complaint about a customer or you are making a payment on behalf of a customer). The third-party service provider managing our website will have short term access to personal data entered onto the website (e.g. in a contact form). We do not permit the third-party to access or process your data except in accordance with our instructions.
   7. Lawful basis of processing
   8. When we process your personal data in connection with telephone calls, e-mails, website contact forms or other media, we do so on the basis of our legitimate interests in responding to customer and other queries and in creating and retaining records of such communications for training purposes and for evidentiary purposes. Where you are an existing or prospective customer, we process your personal data arising from telephone calls, e-mails, website contact forms or media on the basis of performance of a contract with you (or steps necessary to enter into such a contract) where such communications are relevant to such a contract.
   9. How long do we retain your data?
   10. We retain recordings, transcripts, e-mails, letters and other copies of communications for a maximum period of six years following termination of the relevant contract.
3. Website Payment Form
   1. What information do we collect and process?
   2. We operate a website payment form on our website to permit existing customers to make one-off payments towards any amounts outstanding to us under a contract. When you complete a website payment form, we will collect your name, email address, residential address, and car registration number, as well as your credit or debit card details.
   3. How is your information used?
   4. We use the information obtained by a website payment form solely for the purpose of handling one-off payments from an existing customer.
   5. With whom do we share your information?
   6. We use SagePay to process your payments securely. The third party service provider managing our website will have short term access to personal data entered onto the website (e.g. in a website payment form). We do not permit the third-party to access or process your data except in accordance with our instructions.
   7. Lawful basis of processing
   8. When we process your personal data in connection with a website payment form, where such payment is made by an existing customer, we do so on the basis of performance of a contract with you. Payments made on behalf of an existing customer by a third party are at the discretion and agreement of the two parties. We process such personal data on the basis of our legitimate interests in accepting outstanding payments on behalf of customers.
   9. How long do we retain your data?
   10. We retain confirmation of a payment via a website payment form for a period of six years following termination of the relevant contract. We retain credit and debit card details only for so long as required to complete the payment.
4. Business Contacts
5. We also process personal data relating to our business contacts. You are considered a business contact if you are a sole trader, trustee, partner in a partnership, member of an unincorporated club or association, owner, director or officer of a corporate entity or an employee of any of these, where you or your business supply goods or services to us, provide profession services to us, have expressed an interest in us or our business or have any other business relationship with us (including where your organisation is a public authority, an industry body, a regulatory authority or similar).
   1. What information do we collect and process? We may receive personal data about you as a business contact (in particular name, business or work contact details, details about who the individual works for, the individual's role in any such organisation and the individual's credentials) from time to time when you correspond with us by post, phone, email, via social media or otherwise. This includes personal data you provide when you:
      1. negotiate and/or enter into a contract with us; or
      2. provide us with your business card.
      3. We may also receive personal data about you from various third parties and public sources such as:
      4. from your business or from third party references or from professional advisors.
      5. from publicly available sources such as Companies House or your business's website.
   2. How is your information used?
   3. Personal data relating to business contacts is used to manage our business relationships with professional advisors, regulatory authorities, public authorities, law enforcement agencies and others, which will include:
      1. assessing the suitability of any existing or potential supplier of goods and services to us, including undertaking appropriate background checks
      2. negotiating and entering into appropriate contracts for the supply of goods or services to us, carrying out any obligations under such contracts (including obligations of payment) and if necessary enforcing any such contracts
      3. undertaking on-going monitoring and management of our relationship with suppliers
      4. investigating any complaints or enquiries
      5. establishing, exercising or defending our legal rights.
6. With whom do we share your information?
7. We will share your information with your business or organisation, our professional advisors and any applicable regulatory authorities, public authorities or law enforcement agencies or any other third party as may be required in the course of our relationship with you.
8. Lawful basis of processing
9. When we process your personal data in your capacity as a business contact, we do so on the basis that it is necessary for our legitimate interests to perform a contract with your organisation or business, to manage third party relationships, to run our business efficiently and profitably, to enhance, modify and improve our services and products, and to pursue our commercial objectives where this does not override your rights and freedoms as a data subject.
10. How long do we retain your data?
11. We usually retain personal data relating to business contacts for up to six years following termination of any contract or other relationship between us.

Marketing

We do not use your personal details for direct marketing purposes and we do not share your personal details with any third party for their marketing purposes.

Additional Information

1. Compliance with legal obligations, etc
2. We may process (including disclose) your personal data in order to comply with any legal obligations binding on us; to protect the rights, property, or safety of our staff, our customers, or others; and to establish, exercise or defend our legal rights. When we process your personal data for the above purposes, we do so on the basis that such processing is necessary for compliance with a legal obligation to which we are subject or necessary in order to protect the vital interests of a natural person, respectively or necessary in order to pursue our legitimate interests in exercising our legal rights. The legal obligations binding on us include our reporting obligations to the Financial Conduct Authority and HM Revenue & Customs, as well as our obligations under applicable legislation including the Money Laundering Regulations, Bribery Act 2010 and the Modern Slavery Act 2015.
3. Legal advice
4. We may process (including disclose) your personal data to our legal advisors for the purpose of establishing, exercising or defending our legal rights.
5. Corporate governance
6. We may share your personal data with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006. When we process your personal data for this purposes, we do so on the basis that we have a legitimate interest in pursuing business aims and objectives.

Failure to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with financing or other services). In this case, we may have to cancel such financing or service you have with us but we will notify you if this is the case at the time.

Data transfers

We do not transfer personal data outside of the European Economic Area.

Your rights

1. Your personal data is protected by legal rights, which include your rights:
   1. Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
   2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
   3. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
   4. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
   5. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
   6. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to your personal data which you initially provided to us, which is processed based on your consent or based on the performance of a contract between us and which is processed by us using automated means.
   7. Withdraw consent at any time where we are relying on consent to process your personal data. We generally do not rely on consent as the lawful basis to process your personal data. However, where we do, you have the right to withdraw consent at any time, although this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain financing or services to you. We will advise you if this is the case at the time you withdraw your consent.
2. If you want to exercise any of these rights, please contact us using the details above.
3. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
4. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
5. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
6. We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at using the details above. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
7. You also have the right to complain to the Information Commissioner's Office, which regulates the processing of personal data, about how we are processing your personal data.