Toyota’s Privacy Notice

Toyota (GB) Plc, which also includes Lexus UK, respects your privacy. Whether you deal with Toyota (GB) Plc as a customer, a consumer, a member of the general public, a partner, supplier or staff member, you are entitled to the protection of your personal data.

In this Privacy Notice (“Notice”) we describe how we collect, process, share and protect your data. We also describe why we process your personal data and the associated choices and rights you have with regards to your personal data.

This Notice applies to all the processing of your personal data across the services we deliver at Toyota (GB) Plc and all of the different platforms we use to deliver those services such as online applications, websites, portals, sales and marketing activity and social media platforms. Data captured and processed at a Toyota Dealership is managed separately, which is further described below.

We’ve taken a layered approach to inform you how we deal with your data, as we recognise it can all be a little confusing at times. Therefore, this Notice is split into sections providing you with more specific and concise information on that particular area.

These sections will be communicated to you whenever we need to process your personal data, which could also be via a link to our Notice.

Capitalised terms refer to standard terms set out in within the General Data Protection Regulation (GDPR).

Who is responsible for the processing of your personal data?

Toyota (GB) Plc of Great Burgh, Burgh Heath, Epsom, Surrey KT18 5UX is the Data Controller and responsible for the processing of your data.

However, please note that we also process your data, dependant on your relationship with us, to different Data Controllers, which form part of the Toyota Group but are separate legal entities and will have their own processes and procedures for handling your data. Please see the Data Controllers section below.

Who can you contact in case you have questions or requests?

Toyota (GB) Plc has appointed a Data Protection Officer (DPO) who is available to handle any questions or queries you may have relating to the processing of your data under this Notice.

The DPO can be contacted at privacy@tgb.toyota.co.uk or alternatively by writing to the Data Protection Officer, Toyota (GB) PLC Great Burgh, Burgh Heath, Epsom, Surrey KT18 5UX.

At Toyota (GB) Plc we collect personal data directly from you when:

You request a Test Drive, Brochure, Vehicle Valuation or complete a form on our websites.

This data is often shared between Toyota entities and your local dealership, to provide you with the best possible products, services and offers based on your requirements and preferences. This includes:

• Personal identifying information: full name, title, address (private and/or professional), previous addresses, telephone number (residential, business), e-mail address, nationality.
• Marketing preferences: we will often ask whether you would be interested in the latest news, offers and events via email, post, SMS and telephone communications.

You request a Test Drive, Brochure or complete a form on our partners’ websites.

This data is provided by you and collected by our third-party partners. It includes:

• Personal identifying information: full name, title, address (private and/or professional), telephone number (residential, business), e-mail address.
• Marketing Preferences: we will often ask whether you would be interested in the latest news, offers and events via email, post, SMS and telephone communications.
  

We need to verify your ID or driver’s licence (e.g. test drives, replacement car).
Data that will be collected from you can include:

• IDs assigned by us, types of formal identification data such as passport, driving license and utility bills

Such data will only be used for the specified purpose at the point of collection.

You use our connected and autonomous car services.

The following data can be collected:

• If you have a Toyota vehicle with an on-board Internet connectivity functionality, identification information requested by the mobile network operator which provides the Internet connectivity service (e.g. copy of ID documents, debit/credit card details);Geolocation information linked to your Toyota vehicle and/or your smartphone (e.g. GPS location, planned destination);
• Driving behaviour (e.g. driving logs, journey logs, driving speed, acceleration and brake speed);

If you do not want your Toyota vehicle’s geolocation data to be used, you can activate the “Privacy Mode” through your MyTotota account at any time. If the “Privacy Mode” is active, we will cease to use such geolocation data. However, please note, once activated this will apply to all services relying on geolocation, which could mean they are unavailable, or their quality and accuracy may be affected. You can check the current status of the “privacy mode” through your MyToyota account.

You make a deposit on a vehicle using our online deposit system.

This data is provided by you and collected by us and our third-party processors. It includes:

• Personal identifying information: full name, title, address (private and/or professional), telephone number (residential, business), e-mail address.
• Payment details for the payment of the deposit. This information is processed by a third party payment processor: card number, expiry date, CVS number, issue number (If applicable).

You correspond with us through our call centres (e.g. for customer queries).

We might record the calls in order continuously improve the quality of our services:

• Sound recordings: Recording on tape, call recording.

You interact with Toyota through online channels (e.g. website).

The following information can be captured (in accordance with the cookies policy):

• Electronic identification data, IP addresses, cookies, session cookies, your behaviours and usage of our website

You attend an event and your picture is taken/used on social media.

We occasionally run internal events, promoting the company, our employees and new products and services. These events are often attended by our employees, partner organisations and general visitors to our event locations. We often take pictures and videos at these events and post them on our social media pages on platforms such as Facebook and LinkedIn.

When it comes to using pictures or videos that contain individuals from our partner organisations, suppliers and general visitors to our events, we do so using our legitimate interests but in order to respect your privacy and wishes, you are able to object to this processing at the time or at any point in the future by emailing privacy@tgb.toyota.co.uk.

You use a specific login from your own social media on a Toyota (GB) Plc tool (website, portal, blog).

Your use of such social media means that you have allowed the communication and collection of this information.

Toyota (GB) Plc sometimes facilitates the publication of (personal) data via social media such as Twitter and Facebook. All forms of social media have their own terms of use, which you need to take into account when active on social media.

We remind you that publication on social media may have certain consequences, including for your privacy or for the privacy of persons whose personal data you share. You are fully responsible for your publications and Toyota (GB) Plc will not have any responsibility and liability in this regard.

We process your data based on the lawful grounds listed below:

Your consent

Where you have provided your consent, we may use and process your information to:

• Provide marketing communications - Contact you from time to time about Toyota’s products, offers and events that we think might be of interest to you. We will send these communications by email, phone, SMS or post, or where you give consent to do so by digital channels such as Facebook, Instagram or via online advertising platforms.
• Provide personalised communications - Use your personal data to create an individual profile of you to help us ensure that our communications are as relevant as possible. To do this, we use your profile to understand how you interact as a customer across the Toyota group (including our Authorised Toyota Dealers, Toyota Motor Insurance and Toyota Financial Services). This profile may include data which you have provided to Toyota or which is generated by your use of Toyota products, our website and app and your interaction with our marketing and online campaigns. Where available we may make use of additional information about you when it is available from third parties such as social media platforms, advertising platforms, data cleansing and enrichment organisations and publicly available sources. This helps us reduce the amount of information you receive that is not relevant.

To further ensure we accurately understand your interest and preferences, we will share your profile with specific third parties, such as social media platforms, advertising platforms, data cleansing and enrichment organisations and publicly available sources. These third parties help us analyse your likes, as well as identifying others who may share your interests in our products. This data is only used for this purpose.

For the avoidance of doubt, you will always have the right to withdraw your consent at any time by contacting us at privacy@tgb.toyota.co.uk or, in relation to any marketing messages you receive, by using the unsubscribe option included in each electronic communication. Alternatively, if you have one, you can log into your My Toyota account and update your preferences directly.

Contractual performance

We may use and process your personal data where it is necessary to perform a contract to which you are a party or in order to take steps at your request prior to entering a contract and to fulfil and complete your orders, purchases, service subscriptions and other transactions entered into with us (or our authorised dealer network and affiliates).

Legitimate interests

We may use and process your personal data, as set out below, where it is necessary for us to carry out activities for which it is in our legitimate interests as a business to do so. We will always ensure this legitimate interest is not outweighed by your privacy rights and that the use of your personal data is duly communicated to you in the privacy notice related to that processing.

Processing necessary for us to support customers with sales and other enquiries

• To respond to correspondence you send to us and fulfil the requests you make to us via our web forms, email addresses, telephone contact centres and Live Chat functionality (for example: test drives, service requests, brochure requests or information about specific vehicles);
• To provide service, maintenance and warranty information and reminders, unless you object;
• Processing necessary for us to respond to understanding customers’ and drivers’ needs to analyse, evaluate and improve our products and services so that your visit and use of our website, applications, customer service centre and authorised affiliates and subsidiary companies are more useful and enjoyable (we will generally use data amalgamated from many people so that it doesn’t identify you personally).
• To undertake market analysis and research (including contacting you with customer surveys) so that we can better understand you as a customer and provide tailored offers, products and services. We will only send marketing communications to you if you have provided your consent for us to do so.
• For product development purposes (for example to improve vehicle quality, performance and safety);

Processing necessary for us to promote our business, brands and products by understanding our customer and to measure the reach and effectiveness of our campaigns.

• To send you information on our extended warranty and roadside assistance products where you are benefiting from a current Toyota service and it is about to expire. You have the right to object to us sending this information at any time;
• To contact you from time to time with marketing information (unless you object) if you have expressly indicated to us that you are acting on behalf of a business or where we have obtained business contact details from our authorised dealer network and affiliates.
• To contact you with targeted advertising delivered online through social media and other platforms operated by third party companies unless you object and only where you have consented to the use of advertising cookies to enable this. You may receive advertising based on information about you that we have provided to the platform, including your interests, likes and product renewal status as determined by your use of our websites, products, and services or because, at our request, the platform has identified you as having similar attributes to the individuals whose details it has received from us.
• To provide you with tailored advertising, based on your location, through your television subscription service. For example, delivering an advert ahead of an event at your local dealership. As part of these adverts, we also carry out quality and frequency checks, such as whether adverts were displayed correctly and how often particular adverts have been shown. You can choose not to receive this kind of tailored advertising by contacting us to opt-out or managing your preferences through your television service provider.
• To identify and record when you have received, opened or engaged with our electronic communications or website(please see our Cookie Policy for more information).
• To contact you when your local Toyota Centre opens, closes or moves premises.
• We may analyse your personal data to create a customer profile of your interests, preferences and interactions across the Toyota group and authorised retailers, so that we can tailor our products, services and communications in a way that is timely and relevant to our customers by better understanding our customer’s needs and preferences. We share this information across the Toyota Group and authorised retailers, as this allows us to be more focused, efficient, and cost effective with our resources and ensures our customers only receive relevant products, services and communications from any member of the Toyota group and authorised retailers. We are committed to putting you in control of your data, so you are free to object to your information being used in this way at any time.

Processing is necessary for us to operate the administrative and technical aspects of our business efficiently and effectively

• To verify the accuracy of information that we hold about you and create a better understanding of you as a customer;
• To comply with a request from you in connection with the exercise of your rights (for example, where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);
• For network and information security purposes i.e. in order for us to take steps to protect your information against loss, damage, theft or unauthorised access;
• To inform you of updates to our terms and conditions and policies.

Our legal obligations

• To comply with the law, requests from authorities, court orders, legal procedures, obligations related to the reporting and filing of information with authorities.
• To verify or enforce compliance with Toyota (GB) Plc’s policies and agreements.
• To protect the rights, property or safety of Toyota (GB) Plc and/or its customers.
• In connection with corporate transactions: in the context of a transfer or divestiture of all or a portion of its business, or otherwise in connection with a merger, consolidation, change in control, reorganisation or liquidation of all or part of Toyota (GB) Plc’s business.

To protect the vital interests of you or another person

Sometimes we will need to process your personal data to contact you if there is an urgent safety or product recall notice and we need to tell you about it.

We only retain your data for as long as required by law or where we have an appropriate business justification.

For further information on how long personal data is likely to be kept before being removed from our systems and databases, please contact us using the details provided.

Protecting your personal data

We have implemented a set of technical and organisational security measures to protect your personal data against unlawful or unauthorised access, use of modification, in addition to protection against accidental loss or damage.

Your personal data will only be processed by a third-party Data Processor if that Data Processor agrees to comply with a set of agreed contractual clauses, in addition to appropriate technical and organisational security measures.

Appropriate security means ensuring controls are in place to protect the confidentiality, integrity and availability of your personal data:

• Confidentiality: we will protect your personal data from unlawful disclosure to third parties. 
• Integrity: we will protect your personal data from being modified by unauthorised third parties.
• Availability: we will ensure that authorised parties are able to access your personal data when needed.

We use cookies on our websites. This helps us to provide you with a better experience when you browse our website and also allows us to make improvements to our site.

We have put together specific information on how we process cookies in a policy document for you. Explore how we process cookies.

Depending on the purposes for which we collect your personal data, we may disclose it to the following categories of recipients, who will then process your personal data only within the framework of the purposes detailed below.

Within our organisations and our brand environment:

Our affiliates and subsidiary companies:

• Members of our Authorised Dealerships and Authorised Repairers network which you have indicated as preferred Authorised Dealerships or Authorised Repairers, or which are located near you (based on your postcode, address) or which you have been in contact with;
• Toyota Motor Insurance (TMI) – your data will be passed to TMI if you decide to have insurance with them. They operate as a separate Data Controller and you should view their Privacy Notice to understand how your data is processed by them.
• Toyota Financial Services (TFS) – if you complete a financial agreement or request a quotation with Toyota, this is delivered by TFS, not by TGB. This includes all financial services on the Toyota (GB) Plc website. TFS operate as a separate Data Controller and you should view their Privacy Notice to understand how your data is processed by them.
• Toyota Motor Europe (TME) – for personalised marketing communications we share your information with TME, as they provide system support to us and allow us to manage your preferences. TME also manage certain systems on our behalf, request certain business-related information from us to undertake European wide analysis of our customers experience and satisfaction. 
• KINTO UK Limited (KINTO) – a Toyota brand delivering full-service leasing products to our customers. KINTO operate as a separate Data Controller, and you should view their Privacy Notice to understand how your data is processed by them.
• To centralise, combine, update and rectify your personal data via systems operated by us or by any other Toyota recipient of your personal data, including your personal data which would originate from several sources or which would already be available to us via other systems operated by us or any other Toyota recipient.

Third party business partners:

From time to time, we may disclose your personal data to trusted organisations who handle services on our behalf.

When we disclose your personal data, we take steps to ensure that any third-party partners who handle your personal data comply with data protection legislation and protect your personal data just as we do.

We only disclose the information that is necessary for them to provide the following services:

• Research, advertising, marketing and promotional agencies: to help us deliver and analyse the effectiveness of our advertising campaigns, promotions and products;
• Roadside assistance service providers;
• Customer contact centres: to help us administer your vehicle protection;
• Providers of IT related services

Specific contact with our authorised dealerships and repairers

If you purchase a car or another product or service from one of our Authorised Dealerships or Authorised Repairers or if you give them your personal data, you will have a separate relationship with this Authorised Dealer or Authorised Repairer.

In this case, they become the Data controller of your personal Data, possibly together with us. For all questions or requests about the collection and use of your personal Data by one of the Authorised Dealerships or Authorised Repairers, please contact them directly

How is your preferred Authorised Dealer or Authorised Repairer identified?

The preferred Authorised Dealer or Authorised Repairer is chosen either by options you’ve chosen via the settings of your MyToyota account (which you can change at any time), automatically based on location (the nearest to you based on your postcode, address), or your historical contact with our network.

Toyota operates on a global scale and as a result, your personal data may be stored and processed by us or our partners in multiple countries. This is to enable us to deliver our services to you.

When your personal data is transferred to countries outside the UK (United Kingdom) that do not generally offer the same level of data protection as in the UK, Toyota (GB) Plc will implement appropriate specific measures to ensure an adequate level of protection of your personal data.

We want to be as transparent as possible with you, so that you can make meaningful choices about how you want us to use your personal data. To exercise your Rights under Data Protection Law, please use the DPO Contact Details.

Your choices on how you want to be contacted and withdrawing consent

You can make a variety of choices about how you want to be contacted by us, through which channel (for example, email, mail, SMS, phone), for which purpose and how frequently. This can be done by adjusting the privacy setting on the relevant device, updating your user or account profile or by following the unsubscribe instructions included in the communication .

Your right to access

You have the right to know whether or not we are processing your personal data, to access that information and additionally specified information regarding how we process your information.

Your right to rectification

If you find any mistakes in your personal data, you find it incomplete or incorrect, you may also ask us to correct or amend it. This can be done by providing details of your request to us, using the contact details provided.

Restriction of processing

You have the right to ask us to restrict the Processing of your personal data. This may be whilst we check the accuracy of the information we hold on you. This can be done by providing details of your request to us, using the contact details provided.

Right to object to processing

You may also object to the use of your personal data for direct marketing purposes or, if you prefer, you can tell us through which channel and how frequently you prefer us to contact you. You may also object to us sharing your personal data with a third party for the same purpose. Opting Out – If we are using your consent to process your data, you may withdraw that consent at any time. You may withdraw your consent by unsubscribing to an email, changing your preferences in your account, visiting our Opt-Out form or using the contact details provided.

Your right to erasure

You may want us to delete your personal data. If you do, please provide details of your request to us, using the contact details provided. We will assess your request and if we are able to erase your data we will inform you of the outcome.

Your right to data portability

You have the right to request that data you have provided is sent to you in a structured, commonly used and machine-readable format and have the right to transmit that data to another organisation. This can be done by providing details of your request to us, using the contact details provided.

Making a complaint

If you wish to make a complaint, please contact our Data Protection Officer. If you are unhappy with the response from the Data Protection Officer then you have the right to lodge a complaint with the Information Commissioners Officer (ICO) whose contact details are:

Postal address: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

Email: casework@ico.org.uk

Website: https://ico.org.uk/global/contact-us/

We may occasionally make alterations to this Notice, which will reflect how we process and look after your data. This is to ensure our commitment to being transparent with you, protecting your information and upholding your rights. If significant changes are made to this Notice or the way in which we process your personal data, we will draw your attention to this either through updates to this Notice on our website, through our service lines or by another means of communication such as email.

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:

1. With your written consent.
2. Where we need to carry out our legal obligations.
3. 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:

1. Performance of contract: where we need to take steps
2. to enter into or to perform a contract we have entered into with you.
3. To comply with legal or regulatory obligations: where we need to comply with a legal or regulatory obligations or guidance.
4. 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:

1. Where we need to protect your interests (or someone else's interests).
2. 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)