Upfront Privacy Notice

1. Introduction

Upfront Car Holdings Limited and affiliated companies (“Upfront”) need to collect and use certain types of information about individuals who come into contact with Upfront in order to carry on our work. The purpose of this notice is to ensure that Upfront:

  • Complies with data protection regulations and good practice
  • Protects the rights of individuals
  • Is open and transparent about how it processes and stores individuals’ data

2. General Data Protection Regulation

The General Data Protection Regulations (GDPR) are designed to protect individuals and their personal data, which is held and processed by others. The regulations cover:

  • Data: any personal information, which relates to a living individual who can be identified. This includes any expression of opinion about the individual.
  • Records: of personal data whether stored in a manual filing system or electronically
  • Data controllers; in this case Upfront Upfront as a processer of your personal data

3. The information we may collect about you

  1. Direct from you
  2. When you access or browse this website (including when you submit personal information to us through data entry fields on the website), continue to use this website and through our application, verification or servicing processes, we may collect information from you, which may include the following personal information about you and or your client:

    1. your name;
    2. your current and previous postal addresses;
    3. your phone, fax and e-mail details;
    4. your date of birth;
    5. your passwords and security question answers;
    6. correspondence with us by email and post;
    7. We may also collect:
    8. financial information (including bank or building society account details and details of debit cards used in relation to our services);
    9. sensitive information (such as any medical information you disclose to us (although we will always get specific permission from you before recording this type of information);
    10. information you provide in our application processes;
    11. data about your activities using Upfront, including information about your computer (for example, your IP address, operating system and browser type).
  3. From third parties
  4. We may also obtain information about you from third parties including credit reference agencies, fraud prevention agencies, insolvency practitioners, debt advisers, tracing agents, commercial databases, marketing databases, public records and other publicly available information sources, including information about your business or company (e.g. previous credit applications, personal credit information, electoral register and fraud prevention information).

  5. From website visits
  6. We may also collect IP address and details about visitors to the website for the purposes of aggregate statistics or reporting purposes and to calculate referral fees. We do this by use of cookies. We may also use this data to trace or deal with any malicious attack on or via our website or systems. A cookie is a piece of data stored on a site visitor's hard drive to help us improve your access to our site and identify repeat visitors to our site. For instance, when we use a cookie to identify you, you would not have to log in a password more than once, thereby saving time while on our site. Cookies can also enable us to track and target the interests of our users to enhance the experience on our site. Usage of a cookie is in no way linked to any personally identifiable information on our site. If you give us false or inaccurate information and we suspect or identify fraud, we will record this and will pass details on to fraud prevention agencies.

4. Basis of processing and how we may use your information

We will use your information for:

Our legitimate interests to:

  • Assess whether or not to offer you a car loan and the terms offered
  • Manage any loan completed through to redemption in accordance with the offer and loan terms and conditions, including collection of monies due, dealing with any arrears and forbearance and taking any action, including legal action, to protect our interests
  • Manage any relationship with intermediaries including a record of introductions, payments made and other relevant information appropriate to managing the relationship
  • To manage business relationships with our professional advisers, contractors and third party providers
  • Share information where necessary with funders, our professional advisers, contractors and third party providers and anyone who may wish to acquire all or any part of our business
  • Share information with other companies in the same group and associated companies
  • Carry out checks with fraud prevention and credit agencies and tracing agencies if required
  • Review CV’s and any other material submitted to us for job applications

For legal purposes to:

  • Meet our legal obligations
  • Supply information to any government body, regulatory authority, law enforcement agency as required and to credit and fraud prevention agencies

You can find out details of how the credit reference agencies use your personal and business data here.

Please contact us for details of fraud prevention agencies.

By consent

We may use your contact information to market to you when you have consented to receiving marketing material from Upfront and associated companies either directly or via a marketing service about our products and services. We do not share or sell your information with unrelated third parties.

If you want to opt out of marketing you may use the unsubscribe box on any emails you may receive or write to the Chief Executive, Labs Triangle, London NW1 8AB. Once this notice has been received Upfront will comply with the request within a reasonable time. In normal circumstances electronic communications should stop within 28 days of receiving the notice, and postal communications should stop within two months.

5. Where you have provided us with information about other people

Where you provide information about other people, e.g. information about partners, or anyone other than yourself then you confirm that they are aware that you will be providing this information and that they have had a copy of this Privacy Notice, including how we may use such information.

6. Retaining your information

We will retain information for our legitimate interests and legal purposes as follows:

  • Loans advanced – up to 6 years after the loan has redeemed but may be longer where legal action has been taken or is pending
  • Enquiries and applications for loans not advanced – up to 2 years from the date the enquiry or application is marked not proceeded with – may be longer where a fraudulent application is made. We may also need to keep any anti-money laundering information gathered for a period of up to 5 years
  • Contractors and third party advisers – up to 6 years from the end of our relationship
  • CV’s and other information submitted for job applications – up to 3 months after we decide not to offer you a job.

Where you have consented to marketing, will retain your contact information for marketing purposes until such time as consent is withdrawn.

7. Data transferring

It may sometimes be necessary to transfer personal information overseas. In these circumstances, personal information will be transferred as follows:

  • To those countries within the European Economic Area (EEA); or
  • To those countries on the European Commissions' list of countries that have an adequate level of protection; or
  • To companies in countries not referred to above where we have a data protection agreement in place that is based on the Data Protection Model Clauses of the European Commission and we are satisfied that equivalent protection is in place.

8. Correcting inaccurate personal data and right to be forgotten

You have the right to ask us to delete and/or correct data held by Upfront if it is proven to be inaccurate, excessive or out of date. If an individual is concerned about the accuracy of the data Upfront holds on them they should contact Upfront via the website or write to the Chief Executive of Upfront Car Holdings, Labs Triangle, London N1 8AB. Upfront will consider whether the data is incorrect and if so if it should be corrected or deleted.

You are also able to exercise your right to be forgotten. This does not mean we will have to automatically delete all information held on you as we may still need to keep appropriate information in order to meet our legal obligations and for our legitimate interests.

9. Data Subject access requests

All individuals who are the subject of personal data held by Upfront are entitled to be:

  • told whether any personal data is being processed;
  • given a description of the personal data, the reasons it is being processed, and whether it will be given to any other organisations or people;
  • given a copy of the information comprising the data;
  • and given details of the source of the data (where this is available).

If an individual or appropriately authorised person on their behalf contacts Upfront requesting this information, this is called a data subject access request. Data subject access requests from individuals should made in writing to the Chief Executive of Upfront Car Holdings, Labs Triangle, London NW1 8AB.

We will provide the relevant data promptly and within 20 calendar days.

10. Complaints

You have the right to complain about the way in which we process your data. If you wish to complain you may do so by writing to The Chief Executive, Upfront Car Holdings, Labs Triangle, London, NW1 8AB

You also have the right to complain to the Information Commissioners Office. You can make a complaint to them via their website www.ico.org.uk or by calling them on 0303 123 1113