In this Fair Processing Notice we explain:

• Who we are

• Why this policy exists

• What kinds of personal data we collect and hold about you and where we get it from

• Why we collect your personal data and what we use it for

• The legal basis upon which we collect, process and store your personal data

• Where your personal data is stored and processed

• Who we share your personal data with, what personal data we share and why we do so

• How long we will store your personal data

• Your rights to your personal data and:

• your right of access to your personal data

• your right of rectification to your personal data

• your right of erasure of your personal data (also known as the right to be forgotten)

• your right to have processing of your personal data restricted

• your right to object to the processing of your personal data

• your right to data portability

• your right not to be subject to automated decision making and profiling

• your right to complain to The Information Commissioner

• Important information for children

Note: You have the right to object to us processing your personal data - please see section 9(e) below

WHO WE ARE

We are Oxfordshire Finance Ltd . We are an independent finance broker registered in England and Wales under company number 14204170 and we have our registered office at 12 Ellision Drive, Banbury, Oxon, OX17 1GH.

Oxfordshire Finance Ltd is an Appointed Representative of Moorgate Finance Limited T/A MBN (Moorgate Broker Network), which is authorised and regulated by the Financial Conduct Authority, firm number 662419.

Oxfordshire Finance Ltd is a credit broker not a lender, as such can introduce you to a panel of lenders depending on your requirements and circumstances.

We are the data controller for information that you provide to us and of information that we hold about you from third parties.

You can contact us in one of the following ways:

In writing to: 12 Ellision Drive, Banbury, Oxon, OX17 1GH

or by sending an e-mail to: bmoyses@oxfordshirefinance.co.uk

You can also find information about how our business partner collects and processes your personal data here: https://moorgatefinance.com/privacy-policy/ 

WHY THIS POLICY EXISTS

Our Policy explains our treatment of personally identifiable information which we gather from you, including during your use of our website and when you interact with us in other ways offline.

You must not send us personal information about someone else without first getting the individual’s consent for it to be used and disclosed in the ways set out in our Policy. If you give us information (including personal information) on behalf of someone else, you confirm that the other person has given you permission to act on their behalf and has agreed that you can:

• provide their personal information;

• you have the authorisation to give consent to search, automate processing and marketing of all parties both individual and corporate associated in relation to the finance application and that the authorisation supersedes any previous permissions

• receive on their behalf any data protection notices; and

• give consent to the transfer of the individual’s personal data should this be required

WHAT DATA WE COLLECT AND HOLD

We gather various types of information from our users, as explained in detail below, and we use this information in connection with our services, including to personalise, provide and improve our services, to fulfil your requests for certain services and in some cases, to analyse how you use those services.

Where you are applying for or entering a finance arrangement or giving a guarantee or other security either solely or jointly with another person for your own account, as a relevant individual such as an owner, director, officer or authorised signatory of an incorporated entity, or as an attorney, trustee, a partner in a partnership or as a member of an unincorporated club or association; then we may collect and process the following types of personal data about you:

• your title, forename and surname and gender;

• your personal or work related (depending on which you choose to submit) e-mail address

• your personal or work-related contact details (depending on which you choose to submit) such as your telephone number(s), fax numbers and postal address;

• your date of birth and national insurance number;

• your marital status;

• your residential status and address details for the last 3 years;

• occupation, salary and annual income information;

• employment status;

• employer details and time periods in that occupation and with that employer and any other employers within a 3-year period;

• your bank details, including your bank name and address, sort code, account number, account name, account type and time at your bank;

• Health status and history, details of treatment and prognosis, medical reports;

• Any pre-existing investment, mortgage and/or finance products along with terms and conditions relating to these, account balance, interest rate, payments and valuations.

• personal information about your credit history and financial crime results which we obtain from Credit Reference Agencies and fraud prevention agencies including data which originates from Royal Mail (UK postal addresses), local authorities (electoral roll), the insolvency service, Companies’ House, other lenders and providers of credit (who supply data to the Credit Reference Agencies), court judgments decrees and administration orders made publicly available through statutory public registers (see the section on ‘Credit Reference Agencies’ below);

• information about you that we obtain from public registers such as HM Companies House, HM Land Registry or the Charity Commission to confirm your status, for example confirming you are a director of a company.

• where relevant, information provided by professional advisers during the course of providing a finance facility such as valuers, solicitors, architects, monitoring surveyors, estate agents and accountants. This could include, for example, valuations, financial or property information.

• Additional information that you provide to us when obtaining a quote or applying for finance either on-line, by paper application, over the phone, by e-mail, by post or via our website such as asset details, supplier details and finance requirements.

• Documents that are provided to us when obtaining a quote or applying for finance with us, such as copies of your passport, drivers licence and utility bills.

• your contact and marketing preferences;

• if you take a survey or interact with us in various other ways - demographics information and information about subjects that may interest you;

• information necessary for legal compliance;

• where you "like" us or make posts on our pages on social networking websites, such as Facebook, Twitter, YouTube and Instagram.

• monitoring and recording of telephone calls and email communications where necessary for compliance with regulatory rules or self-regulatory practices or procedures relevant to our business, to prevent or detect crime, for quality, training and security purposes

Special Category Personal Data

We may collect sensitive confidential data known as “special category personal data”, in the form of health information.

Where you ask us to assist you with for example insurance, in particular life insurance and insurance that may assist you in the event of an accident or illness, we will ask you information about your health and medical history (Your Special Data). We will record and use Your Special Data in order to make enquiries in relation to insurance products that may meet your needs and to provide you with advice/guidance regarding the suitability of any product that may be available to you.

WHY WE COLLECT YOUR PERSONAL DATA AND WHAT WE USE IT FOR

We collect and process your personal data:

• so that we can properly provide our services to you, including for example, to search, find and broker to appropriate lenders and business finance providers for you, take instructions and operate your account, manage the relationship with you, deal with payments, assist in dealing with the asset at the end of the finance agreement and close your account

• so that we can fulfil our legal and regulatory obligations, for example, to undertake proper checks on our customers to help detect and prevent crime or fraud

• to comply with our legal and regulatory obligations, for example, to report to regulators and authorities about the products and services that we provide to you

• to offer you the right products and services best suited to your needs

• to maintain and improve the quality of our products and the way we provide our services.

• to protect and defend our legal rights

THE LEGAL BASIS UPON WHICH WE COLLECT, PROCESS AND STORE YOUR PERSONAL DATA

The UK's data protection law allows the use of personal data where its purpose is legitimate and isn't outweighed by the interests, fundamental rights or freedoms of data subjects. The law calls this the legitimate interests condition for personal data processing.

As explained above, we only collect, use and store the minimum amount of personal data about you that is necessary for us provide you with our products and services and to comply with our legal and regulatory obligations arising because of us providing those products and services to you. Accordingly, the basis that we collect, use and store your information is because we have a legitimate interest to do so as a regulated finance broker providing these products and services to you.

Our legitimate interests include:

• to act as a prudent and responsible finance broker; to undertake reference checks, credit checks and risk assessments;

• to help combat financial crime including tax evasion, bribery, fraud and money-laundering; to maintain network and information security;

• to meet our legal and regulatory obligations; to protect and defend our legal rights;

• to maintain accurate records including customer preferences; to enhance, modify and improve our products and services;

• for direct marketing (except if we have asked you for your consent and you have not given it to us);

• to manage third party relationships; and

• to pursue our commercial objectives as a finance broker where this does not override your rights and freedoms as a data subject.

If we have asked you for your consent to process your information for marketing purposes and you have not given it to us then we will not process your information for marketing purposes.

If we process your personal data for marketing purposes either with your consent or under the soft opt-in principle and you decide that you do not wish to receive marketing from us, then we will stop processing your information for marketing purposes at any time you tell us that you no longer wish to receive marketing from us.

WHERE YOUR PERSONAL DATA IS STORED AND PROCESSED

We are based in the UK, and we keep our filing systems and databases here.

We may be required to send or allow access to personal data from elsewhere in the world. This might be the case, for example, when someone providing support services to us is based overseas or uses overseas data centres or where suppliers of assets being purchased via finance are based overseas.

While countries in the European Economic Area all ensure a high standard of data protection law, some parts of the world may not provide the same level of legal protection when it comes to personal data.

As a result, if we do send personal data overseas, we will make sure suitable safeguards are in place in accordance with European data protection requirements, to protect the data.

WHO WE SHARE YOUR PERSONAL DATA WITH, WHAT PERSONAL DATA WE SHARE AND WHY

We do not sell any of your information to third parties, we will not give anyone your information, other than those working directly with us, so that they can market to you.

We will pass your relevant details on to selected business finance providers, for the purpose of obtaining you or your business finance. This may be used by them to search credit reference agencies and other third-party verification services.

Third-party finance companies may use your personal details in the same ways and for the same purposes as set out in this policy.

They may pass your details on to credit reference agencies and fraud prevention agencies, and they will receive scores and reports from them.

They and fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime. Please note that 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.

If they, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, they may refuse to provide the services and financing you have requested, or they 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 or financing to you. If you have any questions about this, please contact us on the details provided.

Searches they make with credit reference agencies will leave a 'footprint' on your file and they will also provide them with information relating to your performance under your account or facility. These 'footprints' and performance details may be accessed by other financial companies in connection with any applications for credit that you may make to them and may affect your ability to obtain credit with them.

Your application may be assessed using credit reference agency records relating to anyone with whom you have a joint account or similar financial association. Where you make a joint application, and such a link does not already exist then one may be created. These links will remain until you file a "notice of disassociation" at the credit reference agencies.

We and our business partners may use the services of an online marketing company or an inline customer satisfaction survey company to send you e-mails about us, our finance partners, relevant products and services and to gather your feedback and reviews. To enable them to send you the e-mails, they will be provided with your name and e-mail address and details of the relevant products and services. If you have told us that you do not wish to receive marketing information directly from us by e-mail, then we will not send them any information about you and you will not receive these emails from them.

We and our business partners may share information about you with regulators in order to meet regulatory reporting obligations. Information about you will only be shared with regulators where it is necessary to meet legal and regulatory obligations.

HOW LONG WILL WE STORE YOUR PERSONAL DATA

We shall retain your personal information for the duration of our agreement with you and for the purposes of, complying with our legal obligations, or in our legitimate interests, in accordance with data privacy laws and our retention policy.

YOUR RIGHTS TO YOUR PERSONAL DATA

We recognise that your information is your information - it does not belong to us. You have a number of important rights which put you in control of your information. To help you understand your rights, we will explain them below.

Your right of access to your personal data

You can ask us at any time to tell you what personal data we hold about you and we will do so, without undue delay, and in any event within one month of receipt of your request. That period may be extended by two further months where necessary, considering the complexity and number of the requests. We will tell you of any such extension within one month of receipt of your request, together with the reasons for the delay. Where you make the request by electronic means, we will provide the information by electronic means where possible, unless otherwise requested by you.

We will not charge you any fee for providing this information (unless the request is manifestly unfounded or excessive, in which case we may charge you a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested. Alternatively, we may be entitled to refuse the request). If you request more than one copy of the information, then we may charge you a reasonable fee for the administration of producing the additional copies.

We may ask you to provide us with information to verify your identity before providing you with the information requested.

Your right of rectification to your personal data

You have the right to have any personal data that we hold about you corrected if it is wrong or completed if it is incomplete. To have it corrected or completed, simply tell us what information is wrong or incomplete and give us the correct and complete information. We will update or complete it without undue delay. We may ask you to provide supporting evidence to verify the information you are giving to us for example, proof of address where you tell us that the address details we hold about you are wrong.

Your right of erasure of your personal data (also known as the right to be forgotten)

In some circumstances you have the right to have the personal data that we hold about you permanently erased. You will have this right (1) when it is no longer necessary for us to process your personal data or (2) if there is no legal basis for us to process your personal data or (3) if we unlawfully process your personal data or (4) to comply with a legal obligation to which we are subject. If you believe that any of these circumstances apply to you then please tell us and we will ensure that your personal data is permanently erased without undue delay if one of these circumstances do exist.

Where we permanently erase your personal data, we will also take reasonable steps to inform any third parties to whom we have provided your personal data of your request to have the personal data erased.

Your right to have processing of your personal data restricted

In some circumstances you have the right to have the processing of your personal data restricted. You will have this right

• if you tell us that your personal data is inaccurate, for a period enabling us to verify its accuracy; or

• if we are not processing your personal data lawfully and you tell us that you would rather have us restrict the processing than erase it; or

• we no longer need your personal data but you need us to store it because you need it for the establishment, exercise or defence of legal claims; or

• if you have objected to us processing your personal data, for a period enabling us to verify whether the legitimate grounds on which we are processing it override your grounds for objection.

This is not an absolute right, and your personal data may still be processed where certain grounds exist. This is:

• with your consent;

• for the establishment, exercise, or defence of legal claims;

• for the protection of the rights of another natural or legal person;

• for reasons of important public interest.

Only one of these grounds needs to be demonstrated to continue data processing.

We will consider and respond to requests we receive, including assessing the applicability of these exemptions.

We will tell you once a restriction on processing has been applied and before lifting any restriction.

Where we restrict the processing of your personal data, we will also take reasonable steps to inform any third parties to whom we have provided your personal data of your request to have the personal data restricted.

Your right to object to the processing of your personal data

As explained in this Fair Processing Notice, we process your personal data because we have a legitimate interest in doing so. However, you have the right to object to us processing your personal data, on grounds relating to your situation. If you object then we will stop processing your personal data unless we can show compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims. For example, where we detect fraud, it is unlikely that your objection may prevent us supplying that information to fraud prevention agencies and legal authorities. Another example is that it is unlikely that your objection may prevent us reporting to the regulator in relation to your account even if you object to us processing your personal data.

The only exception to this relates to where you have previously given consent to us to market to you and you change your mind and object to us using your personal data to market to you. In this case we will without undue delay stop marketing to you and we will take your objection as a withdrawal of that consent, and we will update your marketing preferences

Your right to data portability

New data protection legislation also contains a right to data portability that may give consumers a right in some data processing contexts, to receive their personal data in a portable format when it's processed on certain grounds, such as consent. This is not a right that will apply to your personal data because we process your personal data on the grounds of legitimate interests.

Your right not to be subject to automated decision making and profiling

New data protection legislation also contains a right not to be subject to a decision based solely on automated processing.

Some lenders can decide based solely on automated processing.

Should you exert your right not to be subject to automated processing this needs to be confirmed in writing in advance of our provision of services.

Your right to complain to the Information Commissioner

If you are not satisfied with the way that we have processed your personal data or the way that we have dealt with you when exercising any of your rights, then you may follow our complaints procedure by contacting us directly on 07738 916569 or sending an email to bmoyses@oxfordshirefinance.co.uk

Without prejudice to any other administrative or judicial remedy you might have, you have the right to lodge a complaint with the UK’s Information Commissioner if you consider that we have infringed applicable data privacy laws when processing your personal data. In the UK the Information Commissioner’s Office can be contacted using one of the following and giving our ICO registration number CSN0556736

1. Phone: 03031 231113

2. Writing: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, SK9 SAF

3. Website: www.ico.org.uk

IMPORTANT INFORMATION FOR CHILDREN

We do not offer products or services to children - i.e. anyone under the age of 18. However, we may collect and process information about children when it is necessary and incidental to the provision of our products and services. Examples of this include where children are beneficial owners of a company which is our customer and, in these circumstances, we process the child's personal data so that we can properly understand who our customer is and meet our combating financial crime obligations.

We will not send marketing information to children.

If you are a child whose personal data we hold then please be aware that this Fair Processing Notice also relates to you and you should read it so that you understand how we process your personal data.

Please note that children have the same rights to their personal data, as explained in this Fair Processing Notice, as an adult.