Introduction

Top Rate Finance offers vehicle finance to High Net worth individuals. We are a new innovative lending facility with the aim to ease any concerns you may have when seeking vehicle finance any provide guidance you can trust. 

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Personal Data

Top Rate will collect data for the purposes of processing vehicle sales, for finance applications and the management of finance agreements, which may include asset recovery. This data is processed on the lawful basis of legitimate interest and is stored in a secure, and only accessible only by a very limited number of employees. It typically includes proof of ID  (passport, drivers licence) your residential address and proof of income, the latter is also to be signed by a charted accountant. It may also include, age, nationality and gender. A record/recording of every email and phone conversation is also kept in order to avoid any forgotten dialog further down the line. 

 

Use and Processing of Personal Data

We only collect data needed to process your loan, nothing will be shared unnecessary with a third party or used to notify yourself of a promotional/marketing strategy. By choosing to provide Top Rate Finance with your personal information you indicate your willingness to share and have your information stored by Top Rate Finance and to be considered, when appropriate. 

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Occasionally, we may share data with selected third parties to fulfil the purposes above, this may include credit reference agencies, introducers or agents who will act on our behalf, which may include group companies and where any of our obligations under a finance agreement are sold or assigned, or to help us enforce our rights under an agreement. We will also share data with Law Enforcement or other bodies where we are obliged to. If necessary, we may also share information with approved and vetted asset recovery or debt collection partners.

 

In order to process your application, we may perform credit and identity checks on you with one or more credit reference agencies (“CRAs”). Where you take finance from us we may also make periodic searches at CRAs to manage your account with us. To do this, we will supply your personal information to CRAs and they will give us information about you. This will include information from your credit application and about your financial situation and financial history. CRAs will supply to us both public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information.

 

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.

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Data Security and Integrity

We use our best efforts to ensure that data is accurate, complete, current and reliable for its intended use. We use appropriate technical and organisational measures and safeguards to help protect your personal data from unauthorised access, misuse, alteration or loss.

 

Our internal policies and procedures are designed to help ensure we safeguard the privacy and accuracy of all data we collect or process. To the extent that we disclose personal data to clients or third parties, we will request that they properly protect the security and confidentiality of such information and otherwise process such data in accordance with applicable law.

 

How Long We Keep your Data

We will generally keep your personal data for no longer than necessary, phone conversations may be kept for up to 5 years which is then destroyed if no longer required for the purpose(s) for which it was obtained.

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At the expiry of our retention period your data will be securely disposed of, where that data is held physically we will arrange its lawful destruction. Where data is held in electronic format we will lawfully dispose of it in accordance with data destruction practices at that time relating to electronic data.

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We will retain data for the following terms:

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• If you have had an agreement with us we will hold the information relating to that agreement for 5 years after the agreement is finished.

• If you apply for finance but the application does not proceed we will hold that information for 1 year after your application.

• If you exercise your right to withdraw from an agreement within the first 14 days we will hold your information for 3 years from the date of withdrawal.

Your Rights

 

You have the right to obtain access to your personal data; to have it updated or corrected if it is inaccurate or incomplete; to request that we restrict its processing or remove your data entirely from our system. When asked to remove a record from our database, Top Rate Finance will retain minimal information to ensure we do not contact you or collect such information again or to keep a record of any information disclosed to our clients.

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Our basis / bases for processing data

Sales Process: Contract

Underwriting: Contract

Performance of existing agreements: Contract

Debt / asset recovery: Contract

The data relating to completed agreements: Legitimate Interest (HMRC requirements)

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In some instances, such as if we are required to provide data to a governmental or law enforcement body, then our basis will be a legal obligation. In the unlikely event that we need to release data in a ‘life or death’ situation, I.E. to prevent or minimise a threat to the life of a natural person, our basis will be vital interest.

You should be aware that:

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• The right of erasure does not apply to processing on the basis of legal obligation.

• The right of portability only applies to processing on the bases of consent or contract.

• The right to object only applies to processing on the basis of legitimate interests.

 

If you dispute the processing of your data, or feel your data has not been processed in accordance with the relevant data protection legislation, you should first raise your concern through our customer services department. You may also lodge your complaint with the Information Commissioner‘s Office, by visiting their website at https://ico.org.uk/, telephoning 0303 123 1113, or writing to: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

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Changes to the Privacy Policy

Top Rate Finance reserves the right to modify or amend the Privacy Policy at any time and for any reason, as permitted by applicable law. If there are material changes to the Privacy Policy, we will post those changes here.

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This policy was last updated on 21 May 2018

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