Porsche Financial Services is a trading name of Volkswagen Financial Services (UK) Limited (“VWFS” “we” “our”). VWFS is committed to protecting and respecting any personal information you share with us. This policy describes what types of information we collect from you, how it is used by us, how we share it with others, how you can manage the information we hold and how you can contact us. For data protection purposes, the data controller is Volkswagen Financial Services (UK) Limited.
This policy is supplemental to the data protection privacy notice provided to you before your application was submitted.
Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it. By visiting this website you are accepting and consenting to the practices described in this policy.
We will always give you the option to opt out of receiving marketing communications from us. We will never send you unsolicited ‘junk’ email or communications, or share your data with anyone else who might. We do not sell your information to third parties, but we do work closely with our Group companies, companies that provide services to us and our franchised retailers (known collectively as our selected third parties) who help us to provide you with the information, products and services that you request from us.
Our site may, from time to time, contain links to and from the websites of these selected third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.
The contents of this policy may change from time to time so you may wish to check this page occasionally to ensure you are still happy to share your information with us. Where possible, we may also contact you directly to notify you of these changes.
What information do we collect?
The information we collect includes some or all of the following:
We only collect information which is necessary, relevant and adequate for the purpose you are providing it for. For car insurance this may include the following types of sensitive personal data:-
How is your personal information collected?
We may collect information about you (and/or your vehicle) from:
We may also collect information about you (and/or your vehicle) when you use:
Some of the information that we may obtain about you or your vehicle from our franchised retailers, insurance companies and repairers does not identify you personally, but provides us with information about how you use our services and engage with us (we use this information to improve our services and make them more useful to you).
If you are a fleet customer, we may also obtain additional information required in order for you or your employer to receive or use services on our sites, including but not limited to polls, live chat and personalised services, as well as data required for VWFS to provide products and services to you or your employer or to help us identify you when you contact us.
Lawshield UK Limited (trading as Carbon Insurance Brokers) ( Administrator) Aviva Insurance Limited (Underwriter)
How do we use your information?
VWFS will only process information that is necessary for the purpose for which it has been collected. You will always have the option to opt out of receiving marketing communications from us and you can withdraw your consent or object at any time. We will never send you unsolicited ‘junk’ email or communications, or share your personal information with anyone else who might.
There are various ways in which we may use or process your personal information. We list these below:
You can withdraw your consent at any time by contacting us on the details stated in the section below titled ‘How can you manage the information we hold about you?’ or, in relation to any marketing messages you receive, by using the unsubscribe option included in those messages.
We may use and process your personal information where this is necessary to perform a contract with you, for example, if you are a finance customer, to enable us to manage your account, including responding to your enquiries and complaints.
We may use and process your personal information 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 may also contact you from time to time about promotions, events, products, services or information which we think may be of interest to you and (where you are a finance customer) to communicate your end of contract or contract renewal option(s), where applicable.
Processing necessary for us to support customers with enquiries
Processing necessary for us to respond to, or understand, customers’ needs
Processing necessary for us to promote our business, brands and products and measure the reach and effectiveness of our campaigns
Processing necessary for us to assess and respond to complaints, claims and regulators
Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively
Processing necessary for us to fulfil our legal obligations
Sometimes we will need to process your personal information to contact you if there is an urgent safety or product recall notice and we need to tell you about it.
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
SHARING YOUR PERSONAL INFORMATION
Why might we share your personal information with third parties?
We do not sell your information to third parties but we do work closely with our franchised retailers, third party insurance partners and service providers who fulfil business activities for us (marketing, events and market research etc.) In addition, we may have a legal or other obligation to share your personal information.
Which third parties may process your personal information?
From time to time, we may disclose your information to companies or organisations:
When might we share your personal information with other entities in the Group?
There are circumstances where we share your information with our parent company (or other companies within our Group) in order to:
For example we will share information with Porsche Cars Great Britain Limited where you enquire about their services through us or where you make a complaint to us and later make the same or similar complaint to them.
Customer contract renewals:
In connection with customer contract renewals, VWFS and VWG work together to ensure that follow up activities relating to the renewal of your finance contract(s) are performed as effectively and efficiently as possible. This is achieved, in part, by the sharing of your personal information between VWFS and VWG (and subsequently, with our franchised, authorised retailer network) to co-ordinate and manage the renewals process. For the purposes of data protection laws, VWFS and VWG are “joint data controllers” of this processing of your personal information. This means that both businesses work together to decide why and how your personal information is processed and are jointly responsible to you under the law for that processing. As such, VWFS and VWG have prepared a ‘Joint Privacy Statement’ which describes the relationship between VWFS and VWG, our data protection responsibilities and the personal information that is shared between the parties in respect of finance contract renewals.
In addition, both VWFS and VWG utilise a Customer Engagement Platform (CEP) for the purposes of:
For CEP to operate effectively, VWFS and VWG share certain personal data and cookie data relating to customers and/or websites users. The information shared between VWFS and VWG is the minimum required to fulfil the purpose. Both VWFS and VWG are committed to protecting and respecting any personal data and cookie data shared in accordance with data protection laws. For data protection purposes, VWFS and VWG are independent and separate data controllers of the personal and cookie data utilised by CEP.
For more information regarding VWG's data protection policy or to object to VWG's use of your information, please visit the brand’s website and/or the VWG Privacy Statement available at https://www.porsche.com/uk/privacy-policy/
We will also share your personal information with third parties and/or other companies within our Group if we have a duty to do so, e.g. to register your car with the DVLA, to assist an authorised authority, regulatory body or court, or to enforce or protect our legal rights or to establish, bring or defend legal claims.
How secure is your information with third-party service providers and other entities in our Group?
We take steps to ensure that any third party partners who handle your information comply with data protection legislation and protect your information just as we do. We only disclose personal information that is necessary for them to provide the service that they are undertaking on our behalf. We will aim to anonymise your information or use aggregated none specific data sets wherever possible.
Due to the international nature of our business, there may be some instances where your information is processed or stored outside of the EU. In those instances, we will ensure that appropriate safeguards are in place for that transfer and storage as required by applicable law.
In addition, whenever fraud prevention agencies transfer your personal information outside of the European Economic Area, they impose contractual obligations on the recipients of that data to protect your personal information to the standard required in the European Economic Area. They may also require the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing.
How do we keep your information secure?
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. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and are subject to a duty of confidentiality. Details of these measures may be obtained from the Data Protection Officer (please see contact details below).
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
Finally, we have established procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long do we keep your information for?
We do not retain personal information in an identifiable format for longer than is necessary.
If we have a relationship with you (e.g. you are a customer), we hold your personal information for 6 years from the date our relationship ends. We hold your personal information for this period to establish, bring or defend legal claims. Our relationship may end for a number of reasons including where the vehicle lease expires, or we have been made aware that you no longer own or drive that vehicle.
Where we have obtained your personal information following a request for information, such as a quotation for finance or any other information on any of our products or services, we hold your personal information for 1 year and 6 months from the date we collect that information, unless during that period we form a relationship with you e.g. lease a vehicle. We hold your personal information for this period to give us an opportunity to form a relationship with you.
The only exceptions to the periods mentioned above are where:
In addition, fraud prevention agencies can hold your personal information for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.
How can you manage the information we hold about you?
You have the right as an individual to access the personal information that we hold about you and make corrections if necessary. You also have the right to withdraw any consent you have previously given us and ask us to erase information we hold about you. You can also object to our use of your personal information (where we rely on our business interests to process and use your personal information).
You have a number of rights in relation to your personal information under data protection law. In relation to most rights, we will ask you for information to confirm your identity and, where applicable, to help us search for your personal information. We will respond to you within 30 days (unless there are exceptional circumstances) after we have received any request (including any identification documents requested).
You have the right to:
You can exercise the above rights and/or manage your information by contacting us using the details below:
Post: Volkswagen Financial Services (UK) Limited, One Delaware Drive, Tongwell, Milton Keynes MK15 8HG
Who can you contact if you have a question or a complaint?
If you have any specific data protection concerns or a complaint, you can address it to our Data Protection Team at DPO@vwfs.co.uk
You also have the right to lodge a complaint with a data protection regulator in Europe, in particular in a country you work or live or where your legal rights have been infringed. The contact details for the Information Commissioner’s Office, the data protection regulator in the UK, are below:
Information Commissioner's Office
Call: 0303 123 1113
If you wish to raise a complaint to the ICO, you can do so at https://ico.org.uk/make-a-complaint/ under ‘Make a complaint’.