Fair Processing Notice
This Notice sets out how your personal information will be used by JBR Capital Ltd and/or the JBR Capital Group.
(a) The terms set out in this Notice apply to any information you give JBR Capital Ltd and/or any member of the JBR Capital Group from time to time. It will also apply to any information you have already provided.
(b) We may revise or supplement our Notice from time to time for any of the following reasons.
- to provide for the introduction of new or improved systems, methods of operation, services or facilities;
- to reflect an actual or expected change in market conditions or general vehicle lending practice;
- to comply with or anticipate any changes in any legal or regulatory requirement;
- to ensure that our business is run prudently;
- to make our Notice clearer or more favourable to you; or
- to rectify any mistake that might be discovered from time to time.
- Your continued use of any of our services following any update to this Notice will constitute your acceptance of any changes.
(c) You must not send us personal information about someone else without first getting his or her consent for it to be used and disclosed in the ways set out in our Notice. If you give us information (including personal information) on their behalf, you confirm that the other person has given you permission to act on his/her behalf and has agreed that you can:
- provide their personal information to us;
- give consent on their behalf to the processing of their personal data;
- receive on their behalf any data protection notices; and
- give consent to the transfer of the individual’s personal data abroad.
When you give us information about someone else, or someone else discloses a connection with you, that information may be taken into account with your personal information when assessing your application to receive our products or services.
(d) We treat your privacy very seriously and we understand that you will wish to know how we will use the information we collect from or about you. We use your personal information in accordance with our Notice and will fully comply with all applicable UK data protection legislation (including the EU General Data Protection Regulation due to come into force on 25 May 2018, as amended or replaced). It is important that you take all necessary and appropriate steps to protect your data yourself, for example, by ensuring that all passwords are kept secure.
(e) JBR Capital Group consists of JBR Capital Ltd, JBR Auto Holdings Ltd, JBR Auto Finance Ltd, JBR Auto Services Ltd and JBR Capital DD Limited together with the holding companies (and other subsidiaries of those holding companies) and any direct or indirect subsidiaries of those companies.
INFORMATION WHICH WE MAY COLLECT ABOUT YOU
We may collect and process the following information about you:
- Information you provide (either directly or through an agent such as a dealer, solicitor, independent financial advisor or introducer) by completing an application for our products and services, whether in writing, on our website, over the telephone or by some other means. This information may include your name, address, contact details, date of birth, bank details, details about your employment and financial information.
- Monitoring and recording of other personal data supplied by you when you contact us by other means (such as by email or telephone), and records of any correspondence from you or anyone acting on your behalf.
- Personal details that you provide to us via our website when you complete our online form (such information may include, but may not be limited to, your name, telephone number, postal address and email address).
- Details of transactions you carry out with us.
- Your credit history.
USE OF INFORMATION COLLECTED
We will act proportionately and responsibly when we process, transfer or disclose your information and we will act in accordance with applicable UK data protection laws. We use your personal data for the following purposes:
- we may process, transfer and disclose your information to provide you with products and services;
- verifying your identity;
- taking credit decisions;
- detecting and preventing fraud;
- complying with laws and regulations (including the rules of any regulatory authority) and public duties;
- in order to accurately carry out your instructions and/or comply with our regulatory obligations;
- assisting in improving our services and in the interests of security and crime prevention;
- market research and providing you with information via mail, telephone or other means;
- about JBR Capital Group’s products or services from time to time (see ‘Marketing’ below for further information);
- analysis in order to assess and improve our business or the business and services of the JBR Capital Group.
Where you have applied for credit or where we have agreed to provide credit to you, we may from time to time make searches of your record at a credit reference agency. Your record includes searches made and information given by other businesses. Details of our searches will be kept by the agency and will be seen by other organisations that make searches with the agency for the purposes of credit assessment, debt recovery, management of your accounts, prevention of money laundering and fraud, and statistical analysis.
Where you have applied for credit or where we have agreed to provide credit to you, we will regularly submit your data to credit reference agencies. This is done in order to promote responsible lending, and helping to prevent over-indebtness for our customers, helping prevent and detect crime and fraud and anti-money laundering services, and support other activities such as identity verification, supporting tracing and debt collection. The Credit Rating Agencies may, in turn, share your personal data with Fraud Prevention Agencies, resellers, distributors and agents, public bodies, law enforcement and regulators, as well as any additional data Processors. The identities of the CRAs, and the ways in which they use and share personal information, are explained in more detail at www.callcredit.co.uk/crain.
The credit rating agencies will use your information for the following purposes:
- credit reporting and affordability checks;
- verifying identity, age, residence, and preventing and detecting criminal activity, fraud and money laundering;
- account management;
- tracing and debt recovery;
- statistical analysis, analytics and profiling; and database activities.
We may at any time search your record with a fraud prevention agency. If at any time you give us or procure the giving of false or inaccurate information and we suspect fraud we will record this. The fraud prevention agency will use information recorded for statistical analysis about fraud and will also share it with other organisations who will use it to prevent fraud and to help make decisions on finance proposals requested by you, members of your household or any other businesses associated with you.
Where you apply for credit we will tell you, where permitted by law, if we make a decision about you relating to your credit scoring or eligibility for our products or services solely using an automatic decision making process. You can then request a review by us of the decision using other means.
If a joint application is made, or the application refers to a business or financial partner, this may result in the CRA’s associating you with the other party when you and/or they make any application for finance in the future. In addition, if you are making an application on behalf of any other person(s), by doing so you confirm that you have their authority to disclose their personal information to us, and to give consent on their behalf to the use of their personal data as set out in this Notice.
We use your personal data on the following legal bases, depending on the purpose of our processing:
- to enable us to perform the contract between you and us (if you have entered into a contract with us for products or services);
- your consent (for example, in respect of marketing);
- otherwise in our legitimate interests (for example, to make available the website to you); or
- to comply with a legal obligation.
Where the processing of your personal data by us is based on your consent, you may withdraw your consent at any time, by emailing us at firstname.lastname@example.org. If you withdraw your consent, this will not affect the lawfulness of any processing which has taken place before you have withdrawn your consent.
We may from time to time contact you about products and services available from JBR Capital Group which we believe may be of interest to you. We may do this by post or by phone unless you have told us in writing not to; and by e-mail, text or other electronic means if you have told us that we can. You can tell us at any time if you change your mind, by email (at email@example.com or in writing to the address at the end of this Notice).
DISCLOSURE OF YOUR INFORMATION
We may disclose your personal information to the following recipients:
- Where you have been introduced to us by an introducer such as a dealer or finance broker, we will inform the introducer about the outcome of your application and whether we have agreed to provide you with the product or service for which you have applied. We may also disclose information about you and your relationship with us throughout the term of that relationship. If you do not wish us to disclose this information, please inform us in writing at firstname.lastname@example.org.
- We engage other companies and individuals to perform functions on our behalf, including our data hosting and payment processing suppliers. We do not share your personal information with our agents or suppliers except as is necessary in order to enable them to provide us with a service.
We may also disclose your personal information to third parties in the following circumstances:
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer.
- If JBR Capital Ltd is acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- If the rights to any agreement between you and a JBR Capital Group company are assigned to a third party.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property, or safety of JBR Capital Ltd, any JBR Capital Group company, our customers, or others.
- Your personal information may be passed to and used by companies within JBR Capital Group and our agents and sub- contractors who administer or process the information on our behalf. Please contact Stephen Halstead at email@example.com for an up-to-date list of the current members of JBR Capital Group.
SECURITY AND INTERNATIONAL TRANSFERS OF PERSONAL DATA
We are committed to ensuring that your information will be treated confidentially and securely, and we have put in place appropriate measures to ensure the security of your personal data.
We may transfer your data abroad to other countries outside the European Economic Area, for the purposes of this Notice. If we do so, we shall undertake an assessment and adopt adequate safeguards, in accordance with applicable data protection laws, to ensure any third party recipient will provide adequate security of personal data and your rights to privacy. For further information on the adequate safeguards used by us, please contact Stephen Halstead at firstname.lastname@example.org.
RETENTION OF YOUR PERSONAL DATA
Your information will only be held for as long as we need to process it in accordance with our legitimate interests, and in accordance with UK data protection laws.
You may at any time request access to and/or, if incorrect, rectification of your personal data by writing to Stephen Halstead at email@example.com. We reserve the right to ask you for proof of your identity.
You may also request from us details of the credit reference agencies and fraud prevention agencies with which we may have carried out searches. If there are any inaccuracies in the information we hold about you, please notify us of this in order that we may correct the information we hold about you.
Under the GDPR, or any equivalent rules in the UK, you may be entitled to additional rights in relation to our handling of your personal data. For example, the right to have your personal data erased, the right to object to or restrict us from processing your personal data, and the right to data portability. If you would like to exercise these rights once they come into force, please contact Stephen Halstead at firstname.lastname@example.org.
Should you have any complaints about how we handle your personal information, please contact Stephen Halstead at email@example.com. Should we be unable to resolve your complaint and you wish to take your complaint further, you may do so by contacting the UK Information Commissioner’s Office.
HOW TO CONTACT US
If you have any comments or questions about our Notice please contact Stephen Halstead at firstname.lastname@example.org or in writing to JBR Capital Ltd, 773 Finchley Road, Hampstead, London, NW11 8DN.