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    Privacy policy

    Introduction / Who we are

     

    "We", "our" or "us" means Close Brothers Limited trading as Close Brothers Motor Finance at Roman House, Roman Road, Doncaster, South Yorkshire, DN4 5EZ and its subsidiaries, affiliates and their respective parent and subsidiary companies (“Close Brothers Group”). For the purposes of data protection law, we are the data controller in respect of your personal data.

    This privacy notice explains how, why and when we will use your information, along with the rights you have over that information.  In addition, it explains how others within the Close Brothers Group will use your personal data, see section 5 for further information.

     

    Personal data we collect about you

     

    We collect and use various personal data about you, this usually comes directly from you or your Broker and will include:


    •    Personal details, such as your name, date of birth and nationality 
    •    Contact details, such as postal address, email address, telephone numbers
    •    Identity information such as passports and driving licences, along with sanctions and anti-money laundering checks
    •    Financial information including employment, proof of income and expenditure, assets and liabilities, credit and borrowing history
    •    Voice recordings, and where you attend a Close Brothers premises or Event visual images and/or CCTV images
    •    Any other information which is necessary to fulfil the application, such as the purpose and your personal circumstances


    We will also collect and use special categories of personal data and data related to criminal convictions or offences for limited purposes, these include:


    •    Racial or ethnic origin
    •    Political opinions
    •    Religious or philosophical beliefs
    •    Trade union membership
    •    Information concerning health
    •    Biometric data for the purpose of identifying you

     

    Where you provide personal data about a third party, including family members, joint account holders, guarantors etc you must ensure that they understand the information contained within this Privacy Notice and how we will use their personal data.

     

    How we obtain your personal data

     

    The personal data we collect and use about you is obtained from various sources, and includes the following:
     

    • personal data you give to us or through your relationship with us and the way you manage your products and services including the use of our websites
    • Personal data from other sources, including:
      o    Other Close Brother group companies
      o    Credit reference agencies, fraud prevention agencies, law enforcement or government agencies
      o    Third parties who provide data services to help us improve the personal data we hold about you
      o    Criminal records checks
      o    Joint account holders
      o    Third parties appointed to act on your behalf
      o    Other banks or financial institutions
      o    Publicly available sources, such as the press, the electoral register and companies’ registers, or where you have interacted with our social media pages
      o    Businesses you own or are associated with, including directors, partners, trustees etc.
    • Personal data generated or inferred from your relationship with Close Brothers group companies

     

    What we use your personal data for and the legal basis

     

    To ensure we are meeting our responsibilities when processing your personal data, we must have a suitable legal basis to do so.

    In most cases we will rely on the one of the following:

    • It is necessary for the performance of our contract with you, for example to allow us to provide you with the product or service
    • It is required by law or regulation, for example to meet our obligations in respect of anti-money laundering activities
    • We have a legitimate interest which does not outweigh yours, or your rights or freedoms, and where necessary will be supported by a balancing test, for example security activities, or product and service improvements. * In the UK, we may use recognised legitimate interests as our legal basis for processing. This will only be in accordance with Annex 1 of the UK General Data Protection Regulation.  
    • We may need your consent to process your personal information, such as using your image for promotional activities
    • In exceptional circumstances, it may be necessary to process your personal data to protect your life (vital interests).

     

    By way of a more detailed explanation, the following list outlines the purpose for which we will or may process your personal data, and in each case, the legal basis or bases which we will rely on in order to do so:

     

     

     

    Purpose

    Legal Basis

    To provide and manage our products and services to you including our communications with you Performance of a contract
    Legal obligations
    Legitimate interests
    Assess affordability and suitability of our products and servicesLegal obligation
    Legitimate interests
    Complaints management including analysis and complaint related regulatory reporting Performance of a contract
    Legal obligations
    Legitimate interests
    Where you may be considered a vulnerable customer, we will process your personal data to support accessibility and providing reasonable adjustmentsLegal obligations
    Where special categories of personal data are also processed, we rely on substantial public interests, and either protection of an individual’s economic wellbeing or to prevent and detect unlawful acts, fraud and financial crime
     
    To verify your identity, the identity of joint account holders or third parties acting on your behalfLegal obligation
    Legitimate interests
     
    To monitor, analyse and improve services, and for training and quality purposes. This includes the monitoring and recording of communications including phone callsLegal obligations
    Legitimate interests
    To develop and improve products and services, including identification of new business opportunities. This also personal data of applications which have been declinedLegitimate interests
    To undertake activities relating to the prevention of money laundering, fraud, terrorist financing, bribery and corruption, and international sanctions. This may require us to process information about criminal convictions and offences including sharing of data with law enforcement and regulatory bodiesLegal obligations
    Data sharing with credit references agencies (see below for full details)Legal obligations 
    Legitimate Interests
    To trace debtors including recovery of debt and/or assetsLegal obligations 
    Legitimate Interests
    Data sharing with third party providers of products or services, such as but not limited to insurance productsPerformance of a contract
    Legal obligations
    Legitimate interests
    Data sharing with police, law enforcement, tax authorities or other government and fraud prevention agencies, including reporting suspicious activity and complying with production and court ordersConsent
    To monitor your use of our information and communication systems to ensure they remain secure.Legal obligations
    Legitimate interests
    To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.Legitimate interests
    Compliance with all applicable laws and regulations Legal obligation
    Legitimate interests
    Protection of our legal rights and interests, including in connection with any actual or prospective litigation, internal or regulatory investigation.Legitimate interests
    Provision of marketing information related to Close Brothers groups products and services. This may include provision of marketing online, however, we will not provide your personal data with third parties for their own marketing purposes.Legitimate interests
    Data sharing in relation to a prospective buyer of any Close Brother group companies or assetsLegitimate interests

     

     


     

    Who we will share your personal data with

     

    We will not share your personal data with any third party outside of the Close Brothers group except in the following circumstances:

    •    Close Brothers Group companies for the purposes as set out in Section 4 above. 
    •    Where we have your permission, including your advisors who you have authorised to act on your behalf
    •    If applicable, your broker who introduced you to Close Brothers
    •    With third parties providing services to us, such as customer service and/or complaints services, companies that print our correspondence, data storage providers and technical support.
    •    Other banks and third parties in relation to (actual or suspected) fraud or financial crime activities, such as fraud prevention agencies
    •    Credit reference agencies
    •    Government and tax authorities
    •    Debt collection, tracing and repossession agents 
    •    To our professional advisers including insurers, law firms and auditors
    •    To any potential or actual guarantor, or funder
    •    If we sell any of our business or assets, or we are acquired by a third party, the personal data held by us will be shared under strict duties of confidentiality
    •    Where permitted by law for our legitimate interests and is not incompatible with the purposes in Section 4.


    Credit Reference and Fraud Prevention Agencies

     

    We carry out credit and identity checks on you with credit reference agencies (“CRAs”) and fraud prevention agencies. We do this by suppling your personal data to the agencies and they will give us information about you including both public (including the electoral register) and shared credit information, financial situation, history, and fraud prevention information.

     

    We will use this information to: 


    •    Assess your credit and affordability position for the product applied for
    •    check the accuracy of the data you’ve given to us 
    •    prevent criminal activity, fraud and money laundering 
    •    trace and recover debts if you owe us money 
    •    assess how you’ve managed credit in the past, for example, about any borrowing, including the amount you borrow and your payment history, including any payment arrangements.

     

    We will continue to share information about you with CRAs while you have a relationship with us. We’ll also inform the CRAs about your account status and repayment history. CRAs will provide us with regular information to enable us to carry out the activities in the above list. If you borrow and don’t repay in full and on time, CRAs will record the outstanding debt. CRAs may give this information to other organisations.

     

    When CRAs receive a search request from us they’ll place a search footprint on your credit file that may be seen by other lenders.

    The Credit Reference Agency Information Notice (“CRAIN”) describes how the three main credit reference agencies in the UK use and share personal data. The CRAIN is available on the credit reference agencies’ websites: 
    •    www.transunion.co.uk/crain 
    •    www.equifax.co.uk/crain 
    •    www.experian.co.uk/crain

    The information held by CRAs may be linked to people who are associated with you, such as your partner or other members of your household. These linked records are called associated records. Any enquiry we make to a CRA may be answered from both your own record and any associated records.

     

    Another person’s record will be associated with yours when: 
    •    you are making a joint application 
    •    you tell us about a financial association with another person (for example, that they are your business partner); or 
    •    the CRA already have existing associated records.

     

    An associated record will be taken into account for all future applications made by either or both of you. The association continues until one of you makes a successful application for the credit reference agencies to file a ‘disassociation’, which allows your information to no longer be linked. You can check for any associations by getting your credit record direct from the CRAs.

     

    We and fraud prevention agencies may also share your personal data with law enforcement agencies to detect, investigate and prevent crime. If fraud is detected, you could be refused certain services or finance. Fraud prevention agencies can hold your personal data for different periods of time. If you are considered to pose a risk of fraud or money laundering, your personal data can be held for up to six years.

     

    Transferring your personal data overseas

     

    Where we transfer your personal data overseas outside of the UK, Isle of Man, Channel Islands or the European Economic Area (“EEA”), we will ensure that it is protected in a manner that is consistent with how your personal data is protected in the UK.

     

    We do this by using one of the following safeguards:
    •    the country that we send the data to has been approved as offering an adequate level of protection by the relevant data protection supervisory authority, such as the Information Commissioner’s Office (“ICO”) in the UK; or
    •    we have entered into a contract with the recipient organisation on terms approved by the relevant data protection supervisory authority obliging them to protect your personal data to the same level.

     

    You can obtain more details of the protections given to your personal data when it is transferred overseas (including a copy of the data protection clauses) by contacting us in accordance with the “How to contact us” section below.

     

    How long will we keep your personal data

     

    The length of time we hold your personal data for will vary dependent upon the purpose the data was collected or generated. Once our relationship has ended, we will usually retain your personal data for seven years.

     

    There may be circumstances where we need to retain your personal data after this time, for example:
    •    To meet legal or regulatory obligations
    •    Evidence of business activities
    •    To help detect or prevent fraud and financial crime
    •    Defend or take legal action
    •    Comply with court orders or investigations from law enforcement agencies or regulators

     

    Marketing

     

    Where we have appropriate marketing permissions, we will provide you with details about our products and services including those of the Close Brothers Group.

    We may also use information gathered from third party organisations which provide personal data for marketing purposes to help us improve our marketing offerings to you.

    We will not share your personal data with any third party organisations for their own marketing purposes.

    You can contact us at any time to ask us to stop using your personal data in this way. We will still send you important information such as changes to your terms and conditions, or if we need to tell you something to comply with our regulatory obligations.

     

    Your rights

     

    You have a number of rights in relation to the personal data that we hold about you.

     

    These rights include:


    •    Right of Access: This means we will provide you with a copy of the personal data we hold about you. This is an entitlement to a copy of the information only, you are not entitled to documents although these may be provided on occasion. 
    •    Right of Rectification: This means if we hold any incorrect information about you, we will correct it.
    •    Right of Erasure: This means you can request we delete the personal data we hold about you. Please note, we may not be able to comply with this request in full where, for example, we have a legal or regulatory obligation to retain your personal data. 
    •    Right to Restrict processing: This means we will pause processing your personal data in certain circumstances, such as where you believe it is inaccurate and we are investigating these claims. 
    •    Right to Portability: We will provide your or a third party an electronic copy of the personal data you have given us in a commonly used electronic format
    •    Right to Object: This means you can object to us processing or holding your personal data. We may refuse a request where we can reasonably demonstrate legitimate grounds for continuing use. We will not refuse an objection request which relates to marketing activity.
    Withdraw consent: Where consent is our lawful basis of processing your personal data, you can withdraw your consent at any time. 
    •    Right to object to any automated decision making (including profiling) which we conduct based on your personal data, which significantly affects you. Please note that there may be circumstances where you object to us conducting automated decision making but we are legally entitled to refuse that request
    •    Complaint: You have the right to complain to us about how your personal data is being processed. You can also complaint directly to the relevant data protection supervisory authority.

     

    You can exercise your rights by contacting us or the relevant data protection supervisory authority using the details set out in the “How to contact us” section below.


    Automated Processing

     

    During our relationship with you, we may process your personal data by automated means which includes profiling, so we can make decisions about you, predict risks or outcomes.

     

    Examples of this type of processing are:
    •    Credit and affordability checks for products and services
    •    Anti-money laundering and sanctions checks
    •    Screening of politically exposed persons
    •    Identification of customers who may need additional assistance, such as vulnerable customers in line with regulators requirements
    •    To provide tailored marketable populations

     

    You have the right to object to an automated decision we have made and request that a person reviews it.

    We may also process your personal data using artificial intelligence technology (“AI”), which includes generative artificial intelligence, machine learning or large language models provided by third party organisations.  

    AI may be used for many purposes, including personal productivity, risk management, improve the quality and efficiency of our services and analysis activities.

    When using these technologies, your personal data may be used to train our AI models, including those of our third party service providers.



    Cookies

     

    We use cookies and similar technologies on our website and in our emails for many reasons.

     

    An example of some uses:


    •    Storage of preferences 
    •    Analysis of online traffic to improve online experience
    •    Serve non tailored marketing materials
    •    In emails, tracking if you opened an email and if you visited our website

     

    For full details on what cookies are, what they do, and which cookies are used by us, please see our Cookie Policy.

     

    How to contact us


    If you have any questions about our Privacy Notice, or want to exercise your rights, you can:

     

    •    Write to us: Close Brothers Motor Finance at Roman House, Roman Road, Doncaster, South Yorkshire, DN4 5EZ; or
    •    Call us: 0333 321 6060; or
    •    Email: [email protected]


    You can contact Data Protection Officer (“DPO”) by emailing [email protected] or writing to DPO, Close Brothers, 10 Crown Place, London EC2A 4FT.

     

    You can also complain directly to the relevant data protection supervisory authority:

    In the UK, please contact the Information Commissioner’s Office. 
    In Jersey, please contact the Office of the Information Commissioner.
    In Guernsey, please contact the Office of the Data Protection Commissioner.
    In Isle of Man, please contact the Information Commissioner.


    Changes to our Privacy Notice

     

    We keep our privacy notice under regular review, and any changes will be updated here. Where a change has a significant effect on how we use your personal data you will also be notified by e-mail.

     

    Correct as at February 2026.