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Privacy Policy

This Privacy Policy is effective from 25th May 2018.

 

Societe Generale Equipment Finance Limited ("we” / “our” / “us”) is committed to protecting your personal information and complying with all applicable legislation in relation to data protection.

 

In the course of providing our products and services to you, we will process your personal information. This Privacy Policy explains how we collect, share and use personal information about you and how you can exercise your privacy rights.

 

The data controller of your personal information is Societe Generale Equipment Finance Limited, a limited liability company with registered address at Parkshot House, 5 Kew Road, Richmond, Surrey, TW9 2PR and company registration number 03596854 and which is registered as a data controller with the Information Commissioner's Office with registration number Z4985712.

 

Societe Generale Equipment Finance Limited is authorised and regulated by the Financial Conduct Authority (reference number 717751).

 

If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided under the “How to contact us” heading below.    

 

WHAT THIS PRIVACY POLICY COVERS

 

·                 WHAT PERSONAL INFORMATION WE COLLECT AND WHY

·                 WHEN WE RECORD COMMUNICATIONS

·                 WHO WE SHARE YOUR PERSONAL INFORMATION WITH

·                 LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION

·                 INTERNATIONAL DATA TRANSFERS

·                 YOUR DATA PROTECTION RIGHTS

·                 AUTOMATED DECISIONS

·                 DATA RETENTION

·                 OUR COMMITMENT TO PROTECT AND MAINTAIN THE SECURITY OF YOUR PERSONAL INFORMATION

·                 UPDATES TO THIS PRIVACY POLICY

·                 HOW TO CONTACT US

 

WHAT PERSONAL INFORMATION WE COLLECT AND WHY

We may process your personal information in our communications with you and in providing you with our services. Your personal information will include information about you (where you are an individual) and your employees, directors, ultimate beneficial owners, officers, partners and other members of staff whose information you provide to us in respect of any of our products or services which you apply for.

 

Information that we ask you to provide.

 

We may ask you to provide personal information by filling in forms and documents (for example when you sign a financing agreement with us) or when we correspond by phone, e-mail, letter or otherwise.

This will either be provided directly to us or provided to us via a dealer, supplier or broker, as explained further in the section entitled "Information that we obtain from third party sources" below.

 

The personal information that we collect, and the reasons why we collect it, include:

 

Types of personal information

Why we collect it

 o   Identity details including your name and date of birth. 

 

o   We may ask for copies of identity documents in which case we may collect details including your place of birth and residential address.

o   We will only ever use your identity details and copies of identity documents to carry out money laundering, financial and credit checks and for fraud and crime prevention and detection purposes.

 o   We collect and process this personal information in order to comply with legal and regulatory requirements.

o   Your contact details including your name, postal and email address.

o   To manage your application(s) for our products or services.

o  To respond to correspondence and service-related enquiries you send to us in respect of our products and services.

o   To contact you in order for us to manage, administer and provide our products and services to you.

o  To discuss products or services for which you apply or may be interested in applying for.

o   To communicate any updates to you including any changes to the terms and conditions of your finance agreement with us (if applicable) and any changes to our Privacy Policy and to our website.

 o   To contact you in order to receive your feedback in relation to your experience with us, third parties who may have introduced you to us or who may have advised you on our products and services,

 o   We collect and process this personal information for our legitimate business interests.

o   Financial and credit card information relating to you or your business, specifically, your business accounting information, personal statement of net worth, bank statements, bank details, debit and / or credit card details.

o   To evaluate your eligibility for such products or services including making credit searches with credit reference agencies and fraud searches with fraud prevention agencies.

 o   We collect and process this personal information for our legitimate business interests.

 o   To enable you to make payments for our services.

 o   We collect and process this personal information, as it is necessary, for the entry into and performance of the finance agreement between us (i.e. to assess whether you are eligible for our products and services, and once a finance agreement has been entered into, so that we can collect re-payments from your nominated bank account or credit card).

o  Details of contact that we have had with you such as referrals and quotes.

 

o   To allow us to provide a professional service to you and to contact you with other products and services of ours that we think you may be interested in e.g. other finance products and services when your current finance arrangement is coming to an end.

o   We collect and process this personal information for our legitimate business interests.

o   Details of services you have received.

o  Customer experience and other feedback and information you provide to us.

o  To review your feedback and experience with us so that we can improve our products and services for you and for our other customers.

o   We collect and process this personal information for our legitimate business interests (and we may record calls both for quality and training purposes and to comply with our legal and regulatory obligations)

o   Information about complaints and incidents.

o   Recordings of calls we receive or make.

o Please see section below entitled "When we record communications" for more information

o   All of the personal information described above

o   We may disclose your personal information to third parties where we are required to do so to comply with applicable laws and regulatory requirements including in circumstances where we are required to do so by a Court Order, regulatory authority or any other third party with the lawful right to request and receive the personal information we hold about you (including law enforcement agencies and tax authorities).

 o   We may also use your personal information where it is necessary for us to take legal advice in order to establish our legal rights, to bring a claim against you or any related parties or to defend a claim from you or any related parties.

 o   We collect and process this personal information for our legitimate business interests.

 

If we ask you to provide any other personal information not described above, then the personal information we will ask you to provide, and the reasons why we ask you to provide it, will be made clear to you at the point we collect your personal information.

 

Information that we obtain from third party sources

 

We may also receive personal information about you from third party sources, but only where we have checked that these third parties are legally permitted or required to disclose your personal information to us.

 

In particular, we are likely to receive personal information about you from the following types of organisation who may have been assisting you:


  • dealers, suppliers, manufacturers who will supply you with equipment you have chosen to finance using our products and services and who may advise you on our services, discuss your finance requirements and recommend specific equipment to you;
  • dealers, suppliers, manufacturers who will only supply you with equipment and who may introduce you to us to discuss your finance requirements;
  • brokers, who may discuss your finance requirements with you and advise you on our products and services and who will execute any financial arrangements that you have chosen to enter into, using our products and services.
  • our group companies who you may have a relationship with and who may introduce you to us to discuss your finance requirements.
  • compliance and risk solution providers who may help us to identify and manage financial, regulatory and reputational risk and who may assist us in making decisions about suitability, capacity and affordability.

 

In each instance, we obtain your personal information from these organisations in order to allow us to provide you with any products and services that you have requested from us and it is necessary for us to process your personal information to enter into and perform our obligations under our agreement with you.

 

We will also receive personal information about you from Credit Reference Agencies (CRAs) and Fraud Prevention Agencies (FPAs), in particular information on your previous financial and credit applications, any current finance and credit agreements and your management of those finance and credit agreements.  This may include details of the products and services you have applied for, those lenders, finance and credit organisations with whom you have (and have had) an agreement with, the amounts advanced, the amount and frequency of repayments and whether you have made your repayments on time and in full.  This will help us make the best possible assessment of your financial situation before we decide whether we can provide you with our products and services and it is in our legitimate interests to process your personal information for this purpose.

 

CRAs and FPAs obtain information about any county court judgments, bankruptcy and other similar orders relating to you from publicly accessible sources such as the electoral register, and from your previous applications to banks, building societies, credit card companies and from the conduct of any accounts you have held. For more information about the use of your personal data by CRAs and FPAs, please refer to the Credit Reference Agency Information Notice (CRAIN) which can be found at http://www.experian.co.uk/crain/index.html.

 

The Information Commissioner’s Office also publishes advice and information for consumers in its 'Credit Explained' leaflet, available at  https://ico.org.uk/media/for-thepublic/documents/1282/credit-explained-dp-guidance.pdf

 

WHEN WE RECORD COMMUNICATIONS

We, and persons acting on our behalf, may record and/or monitor communications (including telephone conversations over landlines and mobile phones, emails, fax and other electronic communications) between you and us, and between you and our employees, agents, consultants, contractors or other personnel and other people (such as employees of our clients). We only do this to the extent permitted by applicable law for legitimate business purposes or other purposes permitted by law. We collect your personal information for the following purposes:

 

·                 recording facts;

 

·                 complying with applicable law and regulation;

 

·                 complying with internal procedures and policies;

·                 facilitating administration and support;

·                 assisting with security, crime prevention and fraud purposes; and

·                 investigating or detecting unauthorised use, wrongful use or abuse of our services, systems or other materials.

 

WHO WE SHARE YOUR PERSONAL INFORMATION WITH

We do not, and will not, sell, rent or trade your personal information.   Your personal information will not be used by these third parties to market their own products and services to you.  They may only send you marketing communications about their own products and services, if they have your consent, or otherwise where the law permits them to do so.

We may disclose your personal information to the following categories of recipients for the purposes explained below:

 

  • to our suppliers and partners who are responsible for providing:

         o   our IT systems to assist us in providing you with an efficient and professional service;

o     our Telephone system to assist us with communications and call recording;

 

o     Collections and recovery agents who may assist us with enforcement of our rights under finance agreements, if required.

 

o     Our lawyers who assist us with legal advice, complaints handling, and enforcing our contracts with customer and third parties, if necessary.

 

  • to Credit Reference Agencies (CRAs) and Fraud Prevention Agencies (FPAs) to help us make the best possible assessment of your financial situation before we decide whether we can provide you with products and services.  We are also required to provide information to CRAs and FPAs so that they can update the information which they hold about you and which they may share with other lenders like us.  For more information about the use of your personal information by CRAs and FPAs, please refer to the Credit Reference Agency Information Notice (CRAIN) which can be found at http://www.experian.co.uk/crain/index.html

 

  • to other financial institutions, anti-money laundering check providers and regulatory bodies with whom information is shared for money laundering checks, credit risk reduction and other fraud and crime prevention purposes;

 

  • to our group companies who process personal information for purposes that are described in this Privacy Policy.

 

  • to dealers, suppliers, manufacturers

 

o     to enable us and them to perform, manage and administer our respective contractual relationships with you, including so we, and they, can report on portfolio management in relation to equipment supplied directly or indirectly by them to you, and which is on finance, with us;

o     to assist us in enforcing our rights under our finance agreement with you, if we need to;

o     to assist us with complaints handling (if applicable); and

o     we may also share information about our relationship with you (for example, that your current finance agreement is coming to an end and you may be interested in hearing about a new finance product that we can offer to you in conjunction with offers these third parties may have available).

 

  • to brokers

 

o     to assist you with complaints, queries or settlement quotes; and

o     to enable us to manage and administer our finance agreement with you, and to assist us in enforcing our rights under the agreement, if we need to. 

 

  • to a prospective buyer (and its agents and advisers) in the event we intend to sell any part of our business or its assets or if substantially all of our assets are acquired by a third party, in which case your personal information could form part of one of the assets we sell, provided that we inform the buyer it must use your personal information only for the purposes described in this Privacy Policy;

 

  • to any national and/or international regulatory, enforcement body, government agency or court where we believe disclosure is necessary (i) as a matter of applicable law or regulation (including where we are required by law to provide information to organisations such as HMRC), (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person; and

            

  • to any other person where you have consented to the disclosure or where we are permitted to do so by law.

 

LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION

Our legal basis for collecting and using your personal information will depend on the personal information concerned and the specific context in which we collect it.  In respect of the personal information and the purposes for which we may process your personal information which are set out in this Privacy Policy, we have confirmed the legal basis upon which we collect and process your personal information.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). 

Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “How to contact us” heading below.

 

INTERNATIONAL DATA TRANSFERS

We store your personal data on our servers located in the UK.

 

We also use service providers who are located outside the European Economic Area to process your personal to provide services to us.  Where we transfer your personal data to an organisation in a country or territory outside the European Economic Area, we will implement appropriate safeguards so that your personal data is protected in accordance with this Privacy Policy.  These include implementing the European Commission's standard contractual clauses or ensuring that the country or territory has an adequacy decision from the European Commission (for example, the EU/US Privacy Shield).   If you would like more information about the safeguards we have in place, please get in touch with us using the details in the 'How to Contact Us' section below.

 

YOUR DATA PROTECTION RIGHTS

You have the following data protection rights:

 

  • If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the “How to contact us” heading below.
  • In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below.
  • You have the right to opt-out of marketing communications we send to you at any time.  We will explain how you can exercise this right, in the marketing emails that we send to you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “How to contact us” heading below.
  • Similarly, if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
  • You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority:

     


The Information Commissioner’s Office

Water Lane,

Wycliffe House,

Wilmslow, 

Cheshire,         

SK9 5AF 

 

Tel:    01625 545 745


E-mail:               
international.team@ico.org.uk


Website:            https://ico.org.uk

 

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

 

AUTOMATED DECISIONS

We may have used an automated credit decision system to assess your application for finance, and where this is the case, this means that our decision on whether or not to approve your application for finance is made automatically on the basis of a computer determination which uses software algorithms without manual review by our staff.  We have implemented measures to safeguard your rights and interests when we use our credit decision including the right to manual intervention or review or to have your concerns heard and investigated if required.   If your application for finance is declined, you can ask to have the decision manually reviewed by us by getting in touch with us using the details in the 'How to Contact Us' section below.

 

DATA RETENTION

We retain personal information we collect from you where we have an ongoing legitimate need to do so (for example, to provide you with a product or service you have requested us to provide or to comply with applicable legal, tax or accounting requirements). 

When we have no ongoing legitimate need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

 

OUR COMMITMENT TO PROTECT AND MAINTAIN THE SECURITY OF YOUR PERSONAL INFORMATION

As a member of a responsible banking Group, we are committed to protect and maintain the security of your personal information against any unauthorised attempt to use it, or disclose it, and against any disclosure that does not comply with our data protection commitments or applicable data protection law.

The protection and responsible use of all personal data is central to our activities.  We have policies, procedures and tools in place to rigorously secure our operations and information systems.

 

UPDATES TO THIS PRIVACY POLICY

We may change or update this Privacy Policy in order to maintain our compliance with applicable law and regulation or following an update to our internal practices. When we update our Privacy Policy, we will take appropriate measures to information you, consistent with the significance of the changes we make.

 

HOW TO CONTACT US

If you would like to contact us in relation to this Privacy Policy, or anything else in connection with the personal information we collect about you, please contact us using the details set out below.

 

Email:                     compliance@sgef.co.uk

 

Post:                       Head of Compliance

Societe Generale Equipment Finance Limited

Parkshot House,

5 Kew Road,

Richmond,

Surrey TW9 2PR

 

Telephone:             020 8973 2000