About this privacy policy
Toyota Financial Services (UK) PLC will be referred to as “we” “us” or “our”
We are committed to protecting the privacy and security of personal data.
This privacy policy gives you information as to why, how and what we do when you provide or we collect, use, share, process, transfer and store personal data. This policy applies when you contact or deal with us in all situations where you give or we collect your personal data. In particular, when you receive our services or purchase our products.
It is important that you read this privacy policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements any other notices and is not intended to override them.
We may update or amend this policy at any time.
About personal data
‘Personal data’ is also referred to as ‘personal information.’ It is any information about a person that identifies that person or enables that person to be identified. Personal data is not data or information where the identity of a person has been removed, this is anonymous data.
Because we will determine the purposes, means of use and processing of your personal data, under data protection law we are a data controller. If we use and process any personal data that relates to and is about a person, under data protection law that person will be a data subject.
If you fail to provide personal data when we need it we may not be able to perform the contract we have or are trying to enter into with you, or we may be prevented from complying with our legal obligations. As a result, we may have to cancel a product or service you have with us, we will notify you under these circumstances.
If you provide personal information about another person, for example about a person who is a joint product holder or beneficiary or a person who has agreed to indemnify or guarantee your performance under a contract, you must have permission from the other person to provide it.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
About us and what we do
Toyota Financial Services (UK) PLC is a public limited company registered in England and Wales (Company number: 02299961). Its registered address is: Great Burgh, Burgh Heath, Epsom, Surrey KT18 5UZ
We offer and provide finance products and solutions to our customers, primarily in relation to the sale of Toyota brand vehicles and Lexus brand vehicles.
We operate under and using our primary trading names ‘Toyota Financial Services’ and ‘Lexus Financial Services.’
Our finance products are for new and used vehicles, and for private customers and business customers. Examples of the types of finance products we offer are:
- Personal Contract Purchase (referred to as PCP),
- Contract Hire,
- Hire Purchase,
- Lease Purchase.
For the Contract Hire finance product, day to day service operation and administration is managed by our appointed service partner Kinto UK Limited.
In a capacity of an insurance mediator, we offer two types of insurance:
- TLAP Insurance (Total Loss Asset Protection)
- Minor Damage Protection (Minor dents, chips and scuffs)
Our products are offered and made available primarily:
- Through the Toyota and Lexus franchised vehicle dealership network, and
- Online, via our website and apps and the websites and apps of other authorised persons.
We provide an online portal and app 'My Finance' that allows our customers to register to manage their finance agreement by viewing their finance agreement and latest transactions, obtaining settlement quotes and making payments, and to update personal and banking details and direct debit management. It also provides a document library and the ability to communicate with us and other facilities and functionality.
How to contact us
If you would like to contact us about any matters that concern data protection and our use and handling of your personal data, you can contact us using the following channels.
Operational questions and requests: to exercise your data protection rights or if you have any questions about your data protection rights, or for general operational matters about the use of personal information please contact our Customer Experience Team by one of the following methods:
Email: customerexperience@uk.toyota-fs.com
Telephone: 0370 850 5533
Via mail using the following postal address: The Data Protection Officer, Toyota Financial Services, Great Burgh, Burgh Heath, Epsom, Surrey KT18 5UZ
General data protection matters: we have appointed a Data Protection Officer (DPO) who is responsible for overseeing this policy. If you have any questions or for further information about how we use personal information please contact our Data Protection Officer by one of the following methods:
Email: DPO@toyota-fs.com
Telephone: 0370 850 5533
Via mail using the following postal address: The Data Protection Officer, Toyota Financial Services, Great Burgh, Burgh Heath, Epsom, Surrey KT18 5UZ
The types of personal information we collect and use
We may process, collect, use, and store different types of personal information. We will only collect and use personal information that is relevant to the service or product that we are providing. The kinds of personal information we collect and process are as follows:
Identity and contact data: includes first name, maiden name, last name, title, residential address and status, billing address, delivery address, email address and telephone numbers, driving licence, passport, photographs.
Personal details: age, date of birth, gender, marital status and date of birth.
Employment data: employment details including employment status, job title, duration, employment address, telephone number.
Vehicle data: vehicle details including make, model, colour, maintenance and repair history, vehicle registration number, chassis number.
Nationality: nationality or citizenship, length and / or right of residency.
Financial data: bank account and payment card details, sort code and bank statements, billing and invoice information, payment methods.
Financial status: details of salary and other income, savings, money you owe, publicly available and shared credit history including County Court Judgments.
Transaction data: including information about payments to and from you and other details of products and services you have purchased from us.
Technical data: includes device identifiers such as internet protocol (IP) address, username or similar identifier, login data, browser type and version.
Other relevant people: joint product holders, beneficiaries of the product, guarantors and people acting as indemnifiers, other people who benefit from the product or service.
Contact with us: information and records created as a result of your contact with us such as telephone conversations, CCTV footage, postal mail, online contact, contact via app, and including information about how you use our website and apps and contact methods available for our other products and services, contact profiles such as your user name and passwords, purchases and orders made, your interests, preferences, feedback and survey responses.
Our and our partners products and services: information and details about your inquiry, application, purchase and use of our products and services or those of our business partners.
Marketing, communication: including information about your preferences to receive specific types of communication including marketing communication from us and any other of your communication preferences.
Data obtained from third parties: money you owe, publicly available and shared credit history including County Court Judgments, information to check identity, current and historic financial situation including borrowings, loans and outstanding finance, information obtained from Credit Reference Agencies and Fraud Prevention Agencies.
Fraud and crime data: information about fraud or theft and related methods and media, criminal records, allegations or advice of criminal activity.
Health: where relevant information about your health, for example if you are a vulnerable customer.
Special categories of personal data
Special Categories of Personal Data include details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about health and genetic and biometric data.
We will process Special Categories of Personal Data only where relevant and if necessary and as we may be permitted under law, in particular in the following circumstances:
- With your written consent.
- Where we need to carry out our legal obligations.
- Where it is needed in the public interest, or if you are a vulnerable customer, or for equal opportunities monitoring and in line with this Privacy Policy.
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public.
Criminal convictions and investigation
We will only collect information about criminal and fraudulent investigation and convictions where it is relevant and appropriate to enter into a contract for a product or service or to perform any contract entered into.
We or fraud prevention agencies may enable law enforcement agencies to access and use your personal information including information about criminal activity to detect, investigate and prevent crime.
How personal data is collected
We collect personal information about you in the following situations
- From you when we are in direct contact with you and from other relevant people such as a person who is a joint product holder or a person who provides indemnity, guarantees or who benefits from the product or service that we provide.
- When you contact us or inquire about, apply for or take a product or service of ours.
- When you create an account with us.
- When you subscribe to a service or publication of ours.
- When you request marketing or other communications to be sent to you.
- From a service provider, interested party or intermediary who facilitates the provision or delivery of our product or service.
- From the Toyota and Lexus franchised vehicle dealership network or from other relevant companies within the Toyota group of companies if you receive a product or service from them, currently or in the past.
- From other sources that are relevant to our products or services including Credit Reference Agencies, HM Revenue & Customs, law enforcement and detection agencies including the Police service, Fraud Prevention Agencies, debt recovery agents and publicly available resources such as those that are available on the internet
Our legal basis and grounds for our processing of personal data
We will only use and process your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
- Performance of contract: where we need to take steps
- to enter into or to perform a contract we have entered into with you.
- To comply with legal or regulatory obligations: where we need to comply with a legal or regulatory obligations or guidance.
- Legitimate interest: where it is necessary for legitimate interests pursued by us or a third party and your interests and fundamental rights do not override those interests.
We may also use your personal information in the following situations, which are likely to be unusual:
- Where we need to protect your interests (or someone else's interests).
- Where it is needed in the public interest.
How we will use your personal information
We will use and process your personal information for the purposes and situations described in this policy.
For information about the legal basis of use of personal data please see the ‘Our legal basis and grounds for our processing of personal data’ section above.
We will collect, use, process and store your personal information primarily on the basis that we need to take steps to enter into or to perform a contract with you and to comply with laws that apply to us.
Personal information may be used for our legitimate interests or those of relevant third parties such as credit reference agencies or fraud prevention agencies.
Specifically, we will use and process your personal information in the following situations and for the following reasons and on the following primary basis of use.
Performance of contract:
- To assess, process, manage and administer your inquiry or application for a product or service.
- To register you as a new customer or user of our product or service and to register other relevant people such as indemnifiers, guarantors and beneficiaries.
- For assessing your creditworthiness, credit score and whether the finance product is suitable and affordable for you.
- To enter into, perform, manage, administer and enforce any product or service including any related contract.
- To share your personal data with our service providers and partners, other Toyota group companies and the Toyota and Lexus franchised vehicle dealership network during the application process or during any contract for any product or service.
- To manage your account and assist you about any matters when you contact us.
- To manage payments of fees and charges.
- To notify you about changes to all applicable terms of supply or use, and our privacy policy or specific privacy notices.
- To update your records and details and to locate and contact you about matters concerning your product or service.
- For automated decision making and profiling as part of your application for a product or service.
Legitimate interest:
- For statistical and market analysis and research.
- To trace and collect money owed to us.
- For pre-approval of further credit.
- For insurance related matters.
- To verify your identity and the accuracy of the data you provide.
- For training and quality assurance.
- To update your records and details and to locate and contact you about matters concerning your product or service.
- To administer and protect our business and business systems and website and apps including trouble shooting, data analysis, testing and security.
- To analyse, enhance and improve our products, services, systems and processes.
- To refer to and conduct checks and searches with fraud prevention agencies and credit reference agencies during your application and from time to time when we are providing the product or service.
- To share your personal information with people or other relevant bodies to support our business systems and processes or to comply with legal or regulatory requirements.
- To monitor, check and record communications between you and us or our agents.
- To facilitate, support and administer our internal systems and procedures such as complaints handling, governance and reporting.
- Requesting that you leave a review or take and complete a survey.
To comply with legal or regulatory obligations:
- For compliance with legal and regulatory requirements.
- To prevent and detect crime, fraud and money laundering.
- Requesting that you leave a review or take and complete a survey.
Communications and marketing
We may contact you in the last twelve months of your finance agreement on the basis that we have a legitimate interest to communicate with you about any end of contract options that are described in your finance agreement, or otherwise in relation to any relevant matters arising from the performance and expiry of your finance agreement.
Where appropriate we provide you with choices about certain personal data uses, particularly in respect of marketing and advertising activities.
We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you, we call this marketing.
You will receive marketing and other communications from us if you have requested these communications and consented to our contacting you for this purpose, or we have a legitimate interest if you have purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion.
You can ask us to stop sending you marketing or other communications at any time. (Please see the ‘Your rights’ section below and the ‘How to contact us’ section above).
Automated decision making
The decision to accept your application for a finance product may be conducted by automated means without human intervention. If your application is not accepted in this way it will be referred for analysis and assessment by a person in our relevant application assessment team.
Any other decisions that are made about you using an electronic system that uses personal information to make a decision without human intervention will be made if it is necessary for entering into or performing a contract or if we are allowed to by law, or if you give your explicit consent to us.
How we may share your personal information
We may have to share your personal data with the other parties set out below for the uses, purposes and situations described in this policy, where we are required to under law, to enter into, manage and administer any contract with you, and in particular for the uses and purposes described in the ‘Our legal basis and grounds for our processing of personal data’ section above.
- Relevant Toyota group companies.
- The Toyota and Lexus franchised vehicle dealership network.
- Our service providers who fulfil or support our products and services systems (including IT systems) and processes, or who analyse and improve our products and services and related systems and processes.
- Our business and product partners.
- Professional advisers.
- Official bodies and regulators including the Financial Conduct Authority (FCA), HM Revenue & Customs (HMR&C), the Information Commissioner’s Office (ICO).
- Law enforcement and detection agencies including the Police service.
Personal data is also shared with credit reference and fraud prevention agencies, please see the ‘Credit reference and fraud prevention agencies’ section below.
Credit reference and fraud prevention agencies
We may share your personal information with Credit Reference Agencies or Fraud Prevention Agencies on the basis that we have to comply with applicable laws. We also have a legitimate interest in preventing fraud and money laundering, to verify identity and to assess your creditworthiness, provided that your interests and fundamental rights do not override those interests.
Credit reference agencies and the Credit Reference Agency Information Notice
In order to process applications for our products or services, we will perform credit and identity checks about you with one or more Credit Reference Agencies (‘CRA’). These CRAs are Equifax and Experian.
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 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 request from us they will place a search footprint on your credit file that may be seen by other lenders.
If you are making a joint application, or tell us that you have a spouse or financial associate, we will link your records together, so you should make sure you discuss this with them, and share with them this information, before lodging the application. CRAs will also link your records together and these links will remain on your and their files until such time as you or your partner successfully files for a disassociation with the CRAs to break that link.
If we share your personal information with a CRA your personal information will be used and processed by the CRA in accordance with the provisions of the CRA’s Credit Reference Agency Information Notice (referred to as the ‘CRAIN’).
The identities of the CRAs, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRAs are explained in more detail in their respective CRAINs.
The CRAINs are accessible from each of the CRAs on their websites. Their websites and CRAINs are located at the following web addresses:
Equifax
Equifax: www.equifax.co.uk
Equifax CRAIN: www.equifax.co.uk/crain.html
Experian
Experian: www.experian.co.uk
Experian CRAIN: www.experian.co.uk/crain/
Fraud prevention agencies
Cifas is the data controller of the Cifas National Fraud Database.
Personal information that we collect from you may be shared with Cifas and fraud prevention agencies who will use it to prevent fraud and money laundering and to verify your identity. If fraud or a money laundering risk is detected, you could be refused certain services, finance or employment.
Further details of how your information will be used by Cifas and these fraud prevention agencies, and your data protection rights, can be found on the Cifas website located at:
Cifas: www.cifas.org.uk/
Transferring information outside of the European Economic Area
Our business, products and services are provided and targeted within the United Kingdom. For this reason we do not envisage that we will need to transfer your personal information outside of the European Economic Area.
If we do need to need to transfer your personal information outside of the European Economic Area we will ensure that the personal information is protected by appropriate safeguards, such safeguards include at least one of the following:
- The destination country has been deemed to provide an adequate level of protection for personal data by the European Commission.
- The service provider is bound by relevant and specific contractual obligations.
- If a transfer is to the USA, that the service provider is part of the US Privacy Shield which requires similar protection to personal data shared between the Europe and the USA.
Retention - how long we will use and retain your personal information
We retain your personal information for as long as we consider is necessary. In retaining your personal data we consider:
- The duration of the purposes that we collected it for, importantly the duration that we are obliged to provide the relevant product or service.
- Fulfilling, managing and concluding our relationship with you.
- The time periods within which we have rights to claim against and pursue you and the time periods within which you have the right to claim against and pursue us.
We also retain personal data for the purposes of satisfying any legal, regulatory, accounting or reporting requirements and guidance. Typically this is a period of six years after you cease to have a contract or relationship with us.
We may irreversibly anonymise your personal data so that it can no longer be associated with you, in which case we may use this anonymous information indefinitely without further notice to you.
Data security
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
We have put in place procedures to deal with any suspected data security breach or incident and will notify you and any applicable regulator of a suspected breach or incident where we are legally required to do so.
If we share personal information with third parties, we require that they take appropriate security measures to protect your personal information. We do not allow third party service providers to use your personal information for their own irrelevant purposes, they are only allowed to use and process your personal information for specified purposes and in accordance with our instructions.
Your rights
Data protection law requires us to tell you about our use and processing of your personal data and gives you rights in relation to the use of your personal data. Under certain circumstances you have the right to:
Request access: is commonly known as a ‘data subject access request.’ This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction: this enables you to have any incomplete or inaccurate personal data we hold about you corrected, though we may need to verify the accuracy of the new personal data you provide to us.
Request erasure: this enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with law. We may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing: you have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to our processing. For further information about the right to object please see the ‘Right of objection’ section below.
Request restriction of processing: this enables you to ask us to suspend the processing of your personal data in the following circumstances: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer: of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time: where we are relying on your consent to process your personal data. Any withdrawal will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you would like to exercise any of these rights please contact us (See the ‘How to contact us’ section above).
Right of objection
You have a right to object to our use of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
If you would like to exercise your right to object please contact us (See the ‘How to contact us’ section above).
No fee usually required
You will not have to pay a fee to access your personal information or to exercise any of your other rights. We may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information or to exercise any of your other rights. This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Information Commissioner’s Office
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO). We would recommend that any questions or concerns are directed to us in first instance, before the ICO is approached. The ICO is the UK supervisory authority for data protection issues (www.ico.org.uk)
