Privacy Policy

About us
Data we hold about you
How we use your Personal Data
What about marketing?
Who do we share your Personal Data with?
Will we transfer your information outside the UK?
How long will we keep your information?
Your rights
Making a complaint
How will you know if we amend this Privacy Policy?
Cookies policy

About us

First Asset Finance Ltd of Capital Tower, 91 Waterloo Road, London, SE1 8RT ("we”, "us”) is committed to respecting your privacy when we process Personal Data relating to you (including information you provide through our website www.faf.co.uk ("the Website”)).

We are the ‘data controller’ of the Personal Data we collect, obtain from you and process relating to you.  Personal Data means personally identifiable information (for example, your name, address, telephone number, e-mail address).

You do not have to provide Personal Data to access this Website, but if you do not supply certain information you will not be able to access some of its facilities, such as the ‘Contact Us’ form.

You have certain rights relating to your Personal Data.  For more information on these, please see Your Rights below.

Data we hold about you

We collect and store Personal Data you submit when you contact us. We will ask you to input your name and email address when contacting us. We will also process any other Personal Data that you disclose in the message on the Contact Us form.

We also gather information relating to you and your online behaviour less directly by:

• by tracking you online and across devices, including using cookies (in accordance with our cookies policy – we use this to (i) provide better service to you on our websites, (ii) market our products and services where we have appropriate consents to do so, and (iii) prevent the use of our Website for fraudulent transactions;
• by combining data you provide with other data, in particular, we use this to respond to your query and to help personalise any solutions and offers we provide;

Most of the information described above comes directly from you but we do obtain some from third parties.

We may also anonymise your data and aggregate it with other users' data (so that you could not be identified from this information and is no longer personal information relating to you) and provide data analytic services to certain third parties with whom we have contractual relationships.]

How we use your Personal Data

We process your Personal Data:

•  to be able to carry out our obligations arising from any contracts entered into between you and us
• as necessary in pursuit of our legitimate interests in providing you with the information, offers, products and/or services that you request from us and to address any questions or complaints you may have
• as necessary in pursuit of our legitimate interests in providing the Website and performing any statistical analysis related to the Website to improve it and our services to you
• as is necessary in pursuit of our legitimate interests in administering this Website and maintaining the safety of our computer systems and networks
• as required by authorities or otherwise required by a court order, or other legal process or as otherwise required by applicable laws and/or regulations
• as necessary in to defend against legal claims, to enforce our Website Terms of Use or other agreements or policies.

In any circumstances where we are processing your Personal Data on the basis of our legitimate interests, we have balanced our legitimate interests in performing that processing activity and determined that our interests are not outweighed by any potential risks to your data protection rights and consider that these are outweighed by the significant benefits to you and us in our processing.  You may contact us to obtain more information about our assessment, including the impact on you.

What about marketing?

We may also provide marketing information to you in relation to our services or products where you have given your consent, or we are otherwise legally entitled to do so and it is in our legitimate interests to provide such information to you. 

If you do not wish to be contacted in this way, you can tell us by contacting us using the details set out at the end of this Privacy Policy or using the "unsubscribe” option in communications sent to you.

Who do we share your Personal Data with?

We may share your Personal Data with:

• our IT service and infrastructure providers that we use to develop, host or maintain the Website and provide our IT storage solutions
• any other third party entities who perform functions on our behalf and who also provide services to us (including to aggregate and anonymise Personal Data so that it does not include any information from which any individual can be identified)
• any other third parties as required by law or for the purposes of crime (including fraud), to prevent or investigate breaches of, or to enforce, our contract with you (including our Website Terms of Use), to respond to or investigate security vulnerabilities, or to respond to emergencies, and to protect the rights of third parties
• our group companies, for internal reasons, primarily for business and operational purposes (and, where you have consented to us doing so, for direct marketing purposes)
• companies that may merge with or acquire us. 

Will we transfer your information outside the UK?

We do not transfer personal data outside of the UK or European Economic Area (EEA).

How long will we keep your information?

We only keep your information for as long as is reasonably necessary for the purposes set out in this Privacy Policy and to fulfil our legal obligations. 

We will keep your personal information for the period required to perform the relevant services and then for a reasonable period from the date of our last contact through the Website regarding your issue. 

Sometimes we de-identify your information so it can’t be attributed to you individually and use this data for data analytics and product development purposes.

Otherwise, we securely erase your information once no longer needed.

Your rights

You have the following rights regarding your information:

Rights	What does this mean?
1.     The right to be informed	You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Privacy Policy.
2.     The right of access	You have the right to obtain access to your information (if we’re processing it), and other certain other information (similar to that provided in this Privacy Policy.
3.     The right to rectification	You’re entitled to have your information corrected if it’s inaccurate or incomplete.
4.     The right to erasure	This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
5.     The right to restrict processing	You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.
6.     The right to data portability	You have rights to obtain and reuse your personal data for your own purposes across different services. E.g., if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.
7.     The right to object	You have the right to object to certain types of processing, including processing for direct marketing.

We will usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing information for:

• baseless or excessive/repeated requests
• further copies of the same information.

 Alternatively, we may be entitled to refuse to act on the request. 

Please consider your request responsibly before submitting it.  We’ll respond as soon as we can.  Generally, this will be within one month from the time we receive your request, but if the request would take longer than that to deal with, we will let you know.

Making a complaint

If you are unhappy with how we’ve handled your information or you would like to exercise your rights, contact us here: FAO  Laura Gosshawk, First Asset Finance Ltd, Capital Tower, 91 Waterloo Road, London, SE1 8RT and by email at  laura.gosshawk@faf.co.uk

If you’re not satisfied with our response to your complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to the UK data protection authority, the Information Commissioner’s Office (ICO).

How will you know if we amend this Privacy Policy?

As our business changes regularly we may need to change the way we gather and process your Personal Data. We may need to make changes to this Privacy Policy at any time. If we make any material change to how we collect, use or share your personal information, we will update this Privacy Policy and inform you of these changes by posting prominent notices of the key changes on our website or app. 

Cookies

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Name	Purpose	More information
Google Analytics cookies	We use this cookie to: (a)   measure the number of visitors to our Website (b)   see how visitors navigate the site (c)   see which resources they access. This helps us to improve the way the Website works.	This cookie is non-essential for our Website.   To prevent Google Analytics cookies being set, you may install the Google Analytics Opt-Out Browser Add-On.

For general information about cookies and how to disable them, please visit http://www.allaboutcookies.org

First Asset Finance Ltd's registration number on the register of data controllers maintained by the Information Commissioner is Z9116778.

Privacy Policy version date 25 May 2018