Last updated: 19th May 2020
Your privacy is important to us, and we are committed to keeping your information secure and managing it in accordance with our legal responsibilities under applicable data protection laws.
- is collected from you when you apply for and/or express an interest in a product or service;
- we obtain during the provision of that product or service;
- is provided to us through www.carcoo.com (the "Website"), over the phone or through social media.
Please read this Privacy Statement carefully as it contains important information to help you understand our practices regarding any personal information that you give to us.
By accessing, browsing or otherwise using the Website you confirm that you have read and agree to this Privacy Statement. If you do not agree with any part of this Privacy Statement, you should not use the Website. If you are applying for one of our products or services online or by phone and do not agree with any part of this Privacy Statement, you should not continue with your application.
1. What information we collect
We may collect personal information (which means any information about an individual whose identity is apparent or can be reasonably ascertained from such information) from you in connection with a service or product provided to you by us, including:
- your name
- telephone number
- email address
- date of birth
- employment details (including place of work and income)
- details of expenditure
- passport information
- driving licence details
- bank details
- credit history
- insurance details
- information regarding your dependants
- IP addresses
- transaction and credit card information
- sensitive data (e.g. health information regarding a disability, illness, or impairment) where you inform us of such circumstances. (See our section on Sensitive Personal Data below for further details).
Where information fields are marked as mandatory on any application form that you complete, you will need to provide such information in order for us to continue with your application. Should you complete mandatory sections of the application form, but not complete the application, we may use the information provided to contact you to provide support with the application process.
2. How we collect your information
We may collect information provided in connection with the following activities:
- If you apply for or purchase any product or service from us;
- Where you provide information to us on our Website, in writing, through social media, or over the phone (including via call recording);
- If you register an interest in a job vacancy, or a product and/or service;
- If you request information or assistance from us;
- If you make a complaint;
- Information provided to us from third parties including lenders, credit reference agencies, tax authorities, fraud prevention agencies, market information sharing databases, motor dealers, brokers and introducers; and
- Use of the features of the Website that may be offered from time to time and may require such information in order to utilise the feature.
3. Lawful basis for processing
The Lawful bases for the processing of data have been defined as follows:
Consent to the processing of personal data for one or more specific purposes are outlined in detail within this privacy statement. In summary these include:
- For marketing activities;
- In connection with the introduction and administration of a consumer credit agreement;
- For the purpose of introduction and administration of related insurance policies; or
- For enabling you to search our motor vehicle database prior to any subsequent dealer introduction.
b. Legal obligations
Processing is necessary in order for Carcoo to adhere to legal and regulatory obligations. These obligations include, but are not limited to:
- HM Government for money laundering and financial crime prevention;
- Financial Conduct Authority (FCA) to evidence robust system and controls; and
- Information Commissioner's Office (ICO) to evidence appropriate technical arrangements for the processing and control of data.
c. Legitimate interests
Processing is necessary for the purposes of credit profiling to enable Carcoo to develop and improve product offering. Any data held for this purpose will be retained only for the purpose of improving product and service offerings and will not be used for any other purpose including communicating directly to you as an individual data subject.
Depending on the continuing relationship with Carcoo, ordinarily all four legal bases for processing will apply and Carcoo will not use personal data for any other purpose than written within this Privacy Statement.
During the processing of your personal data, Carcoo may identify special category data in the course of business. We will always obtain explicit consent from you when recording this data, and it will only be used for the specific purpose of facilitating the contract.
Carcoo will rely on the lawful bases of consent, contract and legal obligations when processing data for the purpose of an application for employment.
4. Use of your information
The lawful bases for the processing of data have been defined as:
a. Service provision and internal processing
- To provide the product or service that you applied for;
- To allow us to consider and process your application and/or enable a Third party lender (from our carefully selected panel of lenders) to provide you with a suitable car finance product or service tailored to your need;
- To evaluate risk in connection with the provision of car finance in the event we process your application and agree suitable car finance products. (See section below on Credit Checking and Automated Decision Making);
- To confirm, update and improve our customer records;
- To allow us to provide a quotation and process your application to enable a Third party insurer to provide you with a suitable insurance product or service tailored to your individual needs;
- To validate claims (i.e. to ensure that your account is not being used without your agreement) and to report on the performance of an account;
- To troubleshoot problems with the Website or mobile application, or to customise your experience on the Website or mobile application;
- To assess what forbearance options are appropriate if you are in financial difficulties;
- To recover debts and/or money which you owe to us;
b. Management of relationship
- To manage, analyse, understand and develop your relationship with us;
- To inform you about improvements to the Website or mobile application;
- To keep you informed of any of our other/new products and services and identify and market products and services that may be of interest to you, where you have chosen to be made aware of this and to assist in any future applications to us;
- To respond to any queries or complaints that you raise;
- To inform you if an application you have started is incomplete;
- For training purposes and to enhance or review the service we provide or have provided to you;
- To conduct statistical analysis and research (where possible using anonymised data);
d. Legal obligations
- To prevent, investigate and prosecute crime, fraud and money laundering; for auditing purposes;
- If we are obliged to disclose information by reason of any law, regulation or court order;
- If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services and financing you have requested, or to employ you, 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 provided)
- The personal data you have provided, we have collected from you, or we have received from third parties will be used to prevent fraud and money laundering, and to verify your identity;
- Both we and fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime;
- To process your personal data on the basis that we have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the services or financing you have requested;
- Fraud prevention agencies can hold your personal data 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;
- To consider you for potential job opportunities where you provide us with a CV, complete an application on LinkedIn or complete a candidate registration form;
- To transfer information to any entity which may acquire rights in us;
- For any other purpose to which you agree.
5. How we might share your information
The Third parties with whom we may need to share personal information to help us provide services and products to you are detailed within this section:
- Lenders we work with dependent upon your individual credit profile and the specific criteria determined by the lenders;
- Our subsidiaries or affiliates, for the purpose of managing our customer relationships, administering our business and to provide you with information about other products and services which might be of interest to you;
- Service providers who need to know the information in order to provide us or you with a product or service (including our third party service providers who process information on our behalf to help run some of our internal business operations including email distribution, electronic signature processing, storage of customer documentation, our HR careers portal, IT services, customer services and for data analytics (using anonymised data));
- Third party credit providers at your request where you have been unsuccessful in applying for personal lending services and/or product(s) (in which case Third party credit providers will become the relevant data controller);
- Credit and fraud agencies (including Call Credit, Equifax, Experian and Cifas) to help make decisions (See Section 6: Credit Checking and Automated Decision Making for more information);
- Law enforcement bodies in order to comply with any legal obligation or court order;
- Third parties for the purpose of validating and assessing fitness and propriety in connection with any application for employment;
- Entities who may or do acquire any rights in us for the purpose of a business sale or reorganisation;
- Carcoo business advisors, for the purpose of assisting us to better manage, support or develop our business and comply with our legal and regulatory obligations;
- Reputable suppliers of credit and insurance related services that we feel may be of interest to you where you have agreed to receive such marketing;
- Debt recovery agencies or service providers, tracing agents or investigators, solicitors or other agents for the purpose of collecting monies or assets due or outstanding on your account;
- We reserve the right to sell performing and nonperforming accounts. We will inform you if we do this.
6. Credit checking and automated decision making
Whenever you apply for any of our products and/or services we and/or our lenders will carry out checks with credit reference agencies ("CRAs"), including:
- Checks against publicly available information such as the Electoral Register, County Court Judgments (CCJs), bankruptcy or repossession information. These checks may be referred to as "soft searches" or "quotation searches" and are visible to only you;
- Checks against data relating to your financial situation and financial history. These checks may be referred to as "hard searches" or "credit application searches" and may be visible to other third parties, such as potential lenders.
We will use this information to:
- Assess your creditworthiness and whether you can afford to take the product;
- Verify the accuracy of the data you have provided to us;
- Prevent criminal activity, fraud and money laundering;
- Manage your account(s);
- Trace and recover debts; and ensure any offers provided to you are appropriate to your circumstances.
We will continue to exchange information about you with CRAs while you have a relationship with us. We will also inform the CRAs about your settled accounts. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt. This information may be supplied to other organisations by CRAs.
When CRAs receive a search from us they will place a search footprint on your credit file that may be seen by other lenders.
If you are making a joint application, or tell us that you have a spouse or financial associate, we will link your records together, so you should make sure you discuss 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.
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 are explained in more detail within the Credit Reference Agency Information Notice (CRAIN). CRAIN is also accessible from each of the three CRAs clicking on any of these links will also take you to the same CRAIN document: Equifax, Callcredit and Experian.
Whenever fraud prevention agencies transfer your personal data outside of the European Economic Area, they impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the European Economic Area. They may also require the recipient to subscribe to "international frameworks" intended to enable secure data sharing.
Credit scoring is an automated decision. The decision on the provision of credit provided by Carcoo is subject to the use of credit scoring, however is also subject to a manual assessment, however if we were to reject your application solely on the basis of a credit scoring system, you can request human intervention and ask us to reconsider your application.
7. Retention of your personal information
The personal information that you provide will be retained by us in accordance with applicable laws. However, in accordance with our lawful basis, data will only be retained in line with our stated policy approach and only be used for the purposes detailed, any marketing activity will only be undertaken where we have your consent, following the conclusion of your relationship or employment with Carcoo. Where the information is retained under our legitimate interests basis, personal data will be held securely and will not be used to contact you directly or for marketing purposes.
Our retention policies are aligned to individual rights and freedom and any request under those rights will be met in accordance with our stated lawful bases or obligations.
8. Sensitive personal data
Sensitive personal data includes information about an individual's health and other categories of personal information which are closely protected (e.g. criminal convictions). We do not generally process such information, unless you have voluntarily provided that information to us (for example, where you have notified us of a health issue).
You agree that, to the extent that you have provided us with sensitive personal data, you provided it voluntarily and agree that we can use any sensitive personal data that you provide us to deliver products or services to you and/or determine your fitness to avail yourself of our products or services. Where possible we shall seek to minimise the collection and use of such sensitive personal data.
Where you tell us you are happy to receive information from us we may send you communications products that we perceive may be of interest to you (including in relation to products and/or services of our partners where we have your agreement).
Depending on the contact preferences you select, we will communicate with you by letter, telephone, SMS, email or other electronic means such as via social and digital media.
If, at any time, you prefer not to receive further communications from us in any or all forms (except in connection with information, products or services that you specifically request), you will have the ability to unsubscribe from such communications by means of a link provided in every e-mail that is sent to you by us or by contacting us (See section on Contact Us below).
10. Refer a friend
When you provide details of a friend to whom an e-mail is to be sent you confirm the following:
- That you have obtained the consent of your friend to pass your friend's details to Carcoo and for your friend to receive the e-mail from us;
- That you are happy for us to disclose your details as the person who asked that we send the e-mail to your friend;
We will not use that person's details for any marketing purposes.
11. Third party websites
Emails sent via the internet can be subject to interception, loss or possible alteration, therefore we cannot guarantee their security. Although we will do our best to protect your personal information, we cannot guarantee the security of your data sent by email and therefore will have no liability to you for any damages or other costs in relation to emails sent by you to us via the internet. If you would like to contact us, please see the section below or use our contact us page.
13. Children’s privacy
It is highly unlikely that we will target particular products at a different age group, the Website is not intended for use by individuals under the age of 18 without the agreement and involvement of a parent or guardian.
We do not knowingly collect personal information from individuals under the age of 18. Where we are able to identify that an individual under the age of 18 has used our services (e.g. the individual may have entered a date of birth into the application form) we will ensure no further processing of the individuals data takes place except for the purpose of erasing the data.
14. Keeping your information secure
We invest appropriate resources to protect your personal information, from loss, misuse, unauthorised access, modification or disclosure, in particular:
- We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorised access to systems;
- We restrict access to personal information to Carcoo employees, contractors and agents who need to know that information in order to process it for us and who are subject to strict contractual confidentiality obligations. They may be disciplined, or their contract terminated if they fail to meet these obligations.
We and the other companies processing your data for the purposes mentioned in Section 4 may from time to time need to undertake some of the processing in countries outside of the European Economic Area. Different privacy laws may apply in these countries and you understand and unambiguously agree to the transfer of personal information to these countries and parties. We only make these arrangements or transfers where we are satisfied that adequate levels of protection are in place to protect any information held in that country or that the service provider acts at all times in compliance with applicable privacy laws.
15. Updates to this privacy statement
Our Privacy Statement applies to all the services offered by Carcoo. We will keep this Privacy Statement under review and make updates from time to time. We will not reduce your rights under Privacy Statement without your explicit consent. We will post any Privacy Statement changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of Privacy Statement changes). If you do not accept the amended Privacy Statement, you should stop using the Website; this may affect our ability to provide certain products and services to you. Please see the section regarding Your Rights for further information regarding continued processing.
17. Your rights and freedoms
You have a number of rights under Data Protection law including:
- Right to be informed - Carcoo provides all customers with this privacy statement to provide transparent and clear information as to arrangements for the collection, control and processing of personal data;
- Right of Access - Copies of personal data held can be requested under an access request and will be met in the 30-day legislative standard ordinarily free of charge. Any extension to these requirements will be advised on the basis of the nature of the request but will be by exception and subject to senior management scrutiny, please see contact us section for further detail;
- Right to Rectification - In the event we hold inaccurate data please advise us of the correct information and records will be updated within 72 hours and confirmation provided accordingly (Subject to satisfactory verification of your identity);
- Right to Restriction of Processing - Data processing will be restricted whilst any claim of accuracy is being contested by you, or you have challenged the legal basis or legitimate grounds for processing for a specific purpose and to establish, exercise or defend legal claim at your request;
- Right to Object - You can object to Carcoo processing on the basis this is contrary to your rights and freedoms, any objection relating to direct marketing will be acted upon within 48 hours, other objections will be treated as a complaint and assessed against our documented legal basis;
- Right to Erasure - Commonly known as the right to be forgotten, Carcoo will adhere to your request ordinarily within 72 hours where legal basis is solely or partially established as consent, any data required for legal, regulatory or legitimate interests maybe maintained in accordance with documented retention schedules. However, our team will confirm and discuss your request to ensure your rights and freedoms are observed at all times;
- Right to Data Portability - You have the right to receive the personal data that you provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller in a timely manner, generally 72 hours unless evidenced to be unduly excessive or unreasonable.
You have a further right in connection with automated decisions, however this is covered in the relevant section of this statement.
Carcoo has established robust policy and procedural requirements to enable your rights as a data subject to be adhered with, however where this is not possible for the reasons outlined, we confirm the detail.
In relation to all these rights, please write to or contact us at the address below. Please note that we will need to verify your identity.
18. Complaints process
If you have a complaint about how we have handled your personal information you may contact us using the details below and we will investigate your complaint. You also have the right to lodge a complaint with a supervisory authority (i.e. the ICO) once you have tried to resolve the issue with us.
19. Contact us
If you have any questions about this Privacy Statement, or you think we have incorrect information or you would like a copy of the information we hold about you, you may request details of personal information which we hold about you please do not hesitate to contact us via the email addresses below: