Privacy Policy

ADHERING TO GENERAL DATA PROTECTION REGULATION

The following privacy policy provides an overview how your data is recorded and processed. This policy applies to GRENKE Group and its United Kingdom entities including GRENKE Leasing Ltd, GC Factoring Ltd – GRENKE Franchise and GC Financial Solutions Ltd (GRENKE Belfast Agency).

 

With the following information, we would like to give you an overview of how we process your personal data as well as your rights under the Data Protection Act. What specific data is processed in detail and how it will be used depends on the requested or agreed services.

 

1. Who is responsible for data processing and who can I contact?

 

Contact details as follows:

GRENKE

No.2 London Square

Cross Lanes

Guildford

Surrey GU1 1UN

E-mail: dataprotection@grenke.co.uk 

 

 

You can reach our operational data protection officer at:

GRENKE

Data Protection Officer

No.2 London Square

Cross Lanes

Guildford

Surrey GU1 1UN

E-mail: dataprotection@grenke.co.uk 

 

2. What sources and data do we use? 

 

We process personal data that we receive from our customers as part of our business relationship. In addition, we process – as far as necessary for the provision of our services – personal data that we might collect from publicly accessible sources (e.g. debtor directories, land registers, trade and association registers, press, internet) or that was obtained from our distribution partners or from other third parties (e.g. a credit agency).

 

Relevant personal data includes:

  • Personal details (name, address, birthday, place of birth and nationality)
  • Contact details (telephone, e-mail address)
  • Verification data (e.g. ID data)
  • Authentication data (e.g. signature sample)
  • Order data (e.g. payment order)
  • Data from the fulfilment of our contractual obligations (e.g. sales data in payment transactions)
  • Information about your financial situation (e.g. creditworthiness data, scoring/rating data, source of assets)
  • Advertising and sales data (including advertising scores), documentation data (e.g. consultation minutes)

and other data comparable to the aforementioned categories.

 

 3. What do we process your data for (purpose of processing) and on what legal basis? 


We process personal data in accordance with the provisions of the European General Data Protection Regulation and the Data Protection Act 2018 (GDPR):


a. For the fulfilment of contractual obligations (Article 6 (1) (b) of the GDPR) 


Data is processed in order to provide financial services as part of the execution of our contracts with our customers or to carry out pre-contractual actions, which are carried out upon request. The purposes of data processing are primarily geared towards the specific product (e.g. leasing, factoring) and may include, but are not limited to, needs analysis, consulting and to perform transactions. Further details on the purposes of data processing can be found in the relevant contract documents and terms and conditions. 


b. For the purposes of legitimate interests (Article 6 (1) (f) of the GDPR)
As far as necessary, we process your data beyond the actual fulfilment of the contract for the protection of our legitimate interests or those of third parties, in particular: 

  • Consultation and exchange of data with credit agencies (e.g. Experian) to identify credit risk or default risk

For the purposes of checking any credit or default risks, and to defend ourselves against any criminal acts, we provide data to credit reference agencies data concerning the request and the applicant. The agencies will make the data saved about you available to us through direct electronic mail provided that we have given convincing evidence that our interest in this is legitimate.


The credit agencies will process the data received and use this to create a profile (scoring), in order to provide their contractual partners in the European Economic Area and in Switzerland and, where necessary, other third party countries (provided there is an adequacy decision from the European Commission for this) with information so they can assess the creditworthiness of natural persons, among others.

 

For detailed information as described in Article 14 GDPR regarding activities undertaken by the credit agencies, please refer to the information provided about the respective agencies using the following links:
For Experian, go to https://www.experian.co.uk/
For Equifax, go to https://www.equifax.co.uk/credit_score
For CoCredo, go to http://www.cocredo.co.uk/ 

 

  • Prevention and clarification of criminal acts, assertion of legal claims and defence during legal disputes

We will send personal data collected for the request for, execution and ending of this business relationship to an asset management company, collection agents or bailiffs. For behaviour not in compliance with the contract or for fraudulent behaviour to our solicitors.

 

Please refer to the information provided about the respective companies using the following links:
For EBM Plc, go to http://ebmplc.com/ 
For Redwood Collections, go to https://www.redwoodcollections.com/
For Direct Collections Bailiffs, go to http://www.dcbltd.com/ 
For Lester Aldridge, go to https://www.lesteraldridge.com/ 

 

  • Checking business needs for the purposes of direct sales approaches and marketing opportunities
  • Guaranteeing IT security and safeguarding IT operations at our company
  • Building and plant safety measures (e.g. access control)
  • Measures to guarantee domestic authority
  • Business management measures and measures to develop products and services

 

c. On the basis of your consent (Article 6 (1) (a)  GDPR)
Insofar as you have given us your consent to process your personal data for specific purposes (e.g., disclosure of data within the Group, or analysis of payment transaction data for marketing purposes), the legality of this processing is assured on the basis of your consent. Consent that has been issued can be revoked at any time. This also applies to the revocation of declarations of consent that were issued to us before the GDPR came into effect, i.e. before 25 May 2018. The revocation of consent does not affect the legality of the data processed until the revocation.
 
d. Based on statutory provisions or public interest 
If we are required to meet various legal requirements (i.e. the provisions of the Banking Act 2009, Money Laundering Act, tax laws) and banking supervisory specifications (e.g. the European Central Bank, the European Banking Authority, the Bank of England and Financial Supervisory Authority). 

 

4. Who receives my data?


Within our organisation, the entities that gain access to your data are those who need it in order to fulfil our contractual and legal obligations. Our service providers and vicarious agents may also receive data for these purposes. These are companies in the categories of financial services, IT services, logistics, printing services, telecommunications, debt collection, advising and consulting, as well as sales and marketing.


With respect to the disclosure of data to recipients outside our company, we may only disclose information about you if we are required to do so by law or if you have given us your consent to do so. Under these conditions, recipients of personal data may be, for example: 

  • Public bodies and institutions (e.g. the Bank of England, Financial Supervisory Authority, the European Banking Authority, the European Central Bank, tax authorities) if there is a statutory or official obligation to do so. 
  • Other credit and financial service providers or similar institutions to whom we send personal data in order to maintain the business relationship with you (e.g. correspondent banks, credit agencies).
  • Other companies within our Group conducting a risk controlling process because of a statutory or official requirement to do so.
  • Other companies within our Group from which information can be provided that are suitable to the company’s interests and are confirmed as a legitimate interests.

 Other data recipients may be those to whom you have given us your consent for your data to be submitted.

 

5. Is data transmitted to a third-party country or to an international organisation? 


A transfer of data to official bodies in countries outside the European Economic Area (so-called third-party countries) takes place, as far as:

  • this is required in order to execute your orders (e.g. payment orders),
  • this is required by law (e.g. in order to comply with tax reporting obligations), or
  • you have given us your consent. 

 

6. How is my data processed on the website?


Unless otherwise stated, we process your data on our website either to action your request (Article 6 (1) (b) GDPR) or based on our legitimate interests (Article 6 (1) (f) GDPR) as follows:


a. Usage data
Every time you access a page and retrieve a file, this process automatically saves general data to a log file. The storage is exclusively system-related and is purely for statistical purposes or to report criminal offences in exceptional circumstances.
We use this data to improve our websites and to present content tailored to your interests on various sites in the network and on multiple devices. As part of this process, usage data is not merged with personalised data. Should you decide to provide us with your data, this data will be backed up securely during the entry process. The same applies to the storage in our system. For security reasons, we store your IP address. This can be accessed in case of a legitimate interest.


We do not save your browser history. A transfer of data to third parties or any other evaluation does not take place, unless there is a legal obligation to do so.


In detail, the following data record is saved each time it is accessed: 

  • Device used
  • Name of the accessed file
  • Date and time of access
  • Time zone
  • Transferred data volume
  • Report as to whether the access was successful
  • Description of the type of web browser used
  • Operating system used
  • The previously visited site
  • Provider
  • User's IP address  

 

b. Contact 
In order to be able to give you the best possible advice as part of a request via our contact forms, the appropriate group company that is best suited to respond to your request will be identified after inquiring about your specific interest at the top of the page. If you contact us (e.g. via contact forms), the designated company will save your data in order to process your request (Article 6 (1) (b) GDPR) or in case any further correspondence is required. If several companies are listed there, they will process your personal data as joint data processors within the meaning of Art. 26 DS-GVO.  Further information on joint responsibility can be obtained by sending an e-mail to dataprotection@grenke.co.uk 


If you expressly agree to be contacted by e-mail, telephone or post (according to Art. 6 Para. 1 a GDPR) within the scope of the contact form, you grant GRENKE AG, GRENKE Leasing Ltd (UK), GC Financial Solutions Ltd (GRENKE Belfast) and GC Factoring Ltd the opportunity to inform you in future by telephone, e-mail or post about current products and services, in the selected category. We may also store your data for the purpose of sending you our newsletter. In addition, we store your IP address and the date of your registration in order to be able to prove your newsletter subscription in case of doubt. You can object to the use of your data for advertising purposes at any time or unsubscribe from the newsletter at any time by clicking on the unsubscribe link in the footer of the newsletter. 
 
If you do not give your consent, your data will be deleted after your request has been processed. Excluded from this is data for which legal or otherwise prescribed storage obligations exist. 


c. Registration 
The data provided during registration will only be used by us to enable you to use our website (Article 6 (1) (b) GDPR).
 We collect the following data for the registration process: 

  • E-mail address
  • Username
  • Password 

 

d. Newsletter 
We are happy to inform you on the basis of your consent (Article 6 (1) (a) GDPR) about the latest news with our newsletter. 
In order to receive the newsletter, you must enter your name and e-mail address. You can also enter and submit further optional information. After you have submitted your e-mail address, you will receive an e-mail from us to the e-mail address you have specified, in which you must click a confirmation link to verify the e-mail address you provided. 
Your data will be stored by us only for the purposes of sending our newsletter. In addition, we store your IP address and the date of your registration in order to be able to prove the newsletter subscription in case of doubt. 
You can unsubscribe from the newsletter at any time by clicking the unsubscribe link at the bottom of the newsletter.  
 

e. Use of cookies 
i) General information
In order to make your visit to our websites more pleasant and to enable the use of certain functions, we use so-called cookies on various sites. These are small text files that are stored on your device. Some of the cookies we use are deleted after the end of the browser session, i.e. after closing your browser (so-called session cookies). Other cookies remain on your device and allow us or our affiliates to recognise your browser on your next visit (so-called persistent cookies).
Cookies cannot access other files on your computer or identify your email address.


ii) Use of cookies
Like most websites you visit, our website also uses cookies to improve the user experience on both one-time and repeated website visits. This allows you to quickly and easily switch between sites, save your configurations, and use third-party tools (such as YouTube videos) on the website.


Cookies are either placed on our website (first party cookies) or on other websites whose content appears on our website (third-party cookies). These third-party providers (such as Facebook) may set cookies if you are logged in to their pages and visit our website. We have no influence on the cookie settings of these websites. Please visit the third-party websites for more information on their use of cookies.


iii) Legitimacy of the storage of cookies
The essential, functional and statistical cookies are stored on the basis of our legitimate interests (Article 6 (1) (f) GDPR) for the optimisation and needs-based design of our website.
Cookies are stored for marketing purposes on the basis of the user's consent (Article 6 (1) (a) GDPR). These cookies are therefore only set if the user agrees to the storage by issuing their consent to the cookie notification on the website.


iv) Deactivating and deleting cookies
The setting you choose on the first visit in response to the cookie notification will be saved. The selected settings can be adjusted here in the privacy settings at any time.
 

Call us

Get in touch with us via

+44 1483 401 700

Mo - Fr 8 am - 6 pm

Privacy Settings


Most browsers are otherwise set to automatically accept cookies. If the default settings for cookies are stored in your browser, all processes run in the background without any notifications. However, you can change these settings at any time.


You can set your browser so that you are informed about the setting of cookies and can decide on a case-by-case basis whether they are to be accepted or deactivated for specific cases or in general.


A general objection to the use of cookies for marketing or advertising purposes can be issued for a variety of services via the website http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by switching them off in your browser settings. Please note that this may mean you won’t be able to use all the features of this website.

 

v) Overview of the cookies we use:


Essential cookies
Essential cookies are required in order to be able to use our website as they enable basic functions such as site navigation and access to secure areas of the website. The website may not work properly without these cookies.
 

Name of the cookie
Purpose of the cookie
Storage time
Session or permanent cookie

Bloomreach

Technical cookie for the load balancer

2 years

Permanent

Functional cookies

 

Functional cookies allow a website to store information that has already been entered (such as preferred language), and to provide the user with enhanced, more personalised features. Functional cookies are used for instance to enable requested functions such as playing videos. These cookies collect anonymised information; they cannot track your movements on other websites.

Name of the cookie
Purpose of the cookie
Storage time
Session or permanent cookie

Bloomreach

These cookies collect information that is either used to track the interests of our customers' users and to help improve the experience on their websites or to help us understand how our products and services are used.

2 years

Permanent

Statistical cookies

 

Statistical cookies collect information about the use of a website – such as the user’s most frequently visited pages and whether the user receives error messages when using a website. These cookies do not store information that allows the user to be identified. The information gathered is pooled and therefore evaluated anonymously. These cookies are used exclusively to improve a website's performance and thus the user experience.

Name of the cookie
Purpose of the cookie
Storage time
Session or permanent cookie

Piwik Pro

Piwik

Used to send data about the device and the visitor's behaviour to PIWIK.

30 minutes – 1 year

Session or permanent cookie

Piwik Pro

Piwik

To detect if a visitor has deliberately deactivated tracking.

Unlimited

Permanent

Cookies for marketing purposes

 

Cookies for marketing purposes are used to play targeted advertisements relevant to the user and adapted to their interests. They are also used to limit the frequency of an ad and to measure the effectiveness of advertising campaigns. They register whether you have visited a website or not. This information may be shared with third parties, such as advertisers. Cookies to improve targeting and advertising are often linked to third-party site functionalities.

 

 

Name of the cookie
Purpose of the cookie
Storage time
Session or permanent cookie

Facebook

These cookies enable behavioural advertising and analysis of Facebook

2 years

Permanent

Google Adwords

These cookies enable behavioural advertising and analysis on the Google AdWords platform.

30 days–2 years

Permanent

LinkedIn

These cookies enable behavioural advertising and analysis of LinkedIn

2 years

Permanent

Twitter

These cookies enable behavioural advertising and analysis of Twitter.

2 years

Permanent

Bloomreach

These cookies collect information that is either used to track the interests of our customers' users and to help improve the experience on their websites or to help us understand how our products and services are used.

2 years

Permanent

Eloqua

These cookies enable behavioural advertising and analysis within the context of email marketing and measuring the effectiveness of email advertising. Tracking is done anonymously until a user identifies him or herself by submitting a form.

2 years

Permanent

f. Range analysis using Piwik

Based on our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our website within the meaning of Art. 6 (1) (f) GDPR), we use Piwik, a software for the statistical evaluation of user access. 


Your IP address will be abbreviated before it is saved. However, Piwik uses cookies that are stored on users' computers and enable the user’s use of the website to be analysed. In this case, pseudonymous usage profiles of the users can be created from the processed data. The information generated by the cookie regarding your use of this online content is stored on our server and not passed on to third parties. 


You can revoke your consent to this data processing as follows:
 

Privacy Settings


g. Use of Eloqua


We use the Eloqua service to collect statistical data about the use of our website, to send our newsletters and to optimize our services accordingly. The Eloqua servers of the supplier ORACLE Nederland B.V., Hertogswetering 163, 3543 AS Utrecht, P.O. Box 40387, 3504 AD Utrecht, Netherlands are located in the EU.


Eloqua uses "cookies", which are text files placed on your computer, to help the website analyze how users utilize the site. If you have already used a website that uses Eloqua, you may already have an Eloqua cookie. Even if this cookie is set on other websites, the information from your visit to our websites is only visible to us and is not shared with Oracle or any other users of the Eloqua system. It is also not possible for us to use this cookie to record or view information about your visits to any other websites.


If you have not expressly consented to this use, our legal basis for this is our justified interest in optimizing our offers (Art. 6 Para. 1 S. 1 lit. f DS-GVO).

The information generated by the cookie about your use of this website is transferred to a server and stored there. On our behalf, Eloqua uses this information to evaluate your use of the website and to compile reports on website activity. If you wish to prevent the use of Eloqua cookies or the evaluation of usage behavior on your device in the future, this is possible via the following link: Eloqua Opt-Out .


E-mails sent with the help of Eloqua use tracking technologies. We use this information primarily to determine which topics are of interest to you by tracking whether our emails are opened and which links you click. We then use this information to improve the emails we send you and the services we provide, as well as to link them to existing tracking or profiling information. You will not be able to track emails if you have disabled image viewing by default in your email program. In this case, however, the newsletter will not be displayed in full and you may not be able to use all functions. If you display the images manually, the above tracking will take place.


You can find further information on data protection in connection with the use of Eloqua here: Oracle Privacy Policy.


h. Integration of social media plug-ins


We are currently using the following social media plug-ins: Facebook, Instagram, Twitter, LinkedIn.


When you visit a page that contains such a plug-in, the browser will connect to the social media providers' servers and provide the information that you have accessed the corresponding sub-page of our website. In addition, the data referred to in section 3 of this declaration will be transmitted, whereby in the case of Facebook and XING, according to the respective providers in Germany, only an anonymous IP is recorded. This happens regardless of whether you have an account with this plug-in provider and are logged in there. If you are logged in to the plug-in provider, this data will be assigned directly to your account. If you click the button, the plug-in provider also stores this information in your user account and informs your contacts publicly. If you do not want your profile to be linked with the plug-in provider, you must log out before clicking the button. 


The plug-in provider stores this data as usage profiles and uses it for the purposes of advertising, market research and/or tailored website design. Such an evaluation is carried out in particular (also for non-logged-in users) to present needs-based advertising and to inform other users of the social network about your activities on our website. You have a right to object to the formation of these user profiles; you must contact the respective plug-in provider to exercise them.


For more information on the purpose and scope of the data collection and its processing by the plug-in provider, please refer to the privacy statements of these providers, which can be found below. You will also find further information about your rights and settings options to protect your privacy here.


 Addresses of the respective providers and URLs with their privacy policies: 

 

i. Integration of Google Maps 
We integrate the maps of the service "Google Maps" provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The data processed may include, but is not limited to, the IP addresses and location data of users, without their consent (usually performed as part of the settings of their mobile devices). Unless you have expressly consented to the use, our legal basis for this data processing is our legitimate interest (Art. 6 Para. 1 S. 1 lit. f DS-GVO) in order to design our website to meet your needs. The data could also be processed in the USA. Privacy policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated

 

7. How long will my data be stored? 


Unless explicitly stated in this privacy statement, the usage and registration data stored with us is deleted as soon as it is no longer required for its intended use and the deletion does not conflict with any statutory retention obligations. 


We process and store other personal data as long as it is necessary for the fulfilment of our contractual and legal obligations. It should be noted that our business relationship is a continuing obligation, which is designed to last for years. If the data is no longer required for the fulfilment of contractual or legal obligations, it is regularly deleted, unless its - temporary - further processing is necessary for the following purposes: 

  • Fulfilment of a duty to preserve the data under commercial and tax laws, i.e. the UK Commercial Law, UK Company Law, HM Revenue & Customs, the UK Banking Act (2009), the Money Laundering Act and the UK Securities Trading Act (2001). These laws require data to be kept/documented for 6 years after the end of the finance agreement.
  • Retaining evidence in accordance with the statutory periods of limitation that apply.  

 

8. Which data protection rights do I have?


 Every affected person has with respect to us

  • the right to information under Art. 15 GDPR,
  • the right to a correction under Art. 16 GDPR,
  • the right to deletion under Art. 17 GDPR,
  • the right to restrict the processing under Art. 18 GDPR,
  • the right to object from Art. 21 GDPR,
  • and the right to data portability under Art. 20 GDPR.

Each individual also has a right to complain to the Information Commissioner’s Office https://ico.org.uk/concerns.


You may withdraw your consent to your personal data being processed by us at any time. This also applies to the withdrawal of declarations of consent received before GDPR came into effect, i.e. before 25 May 2018. Please note that this withdrawal will apply going forward. It will not apply to any data processed before the withdrawal.
You have the right, at any time, to opt out of any processing of your personal data taking for reasons relating to your own particular situation. 


9. Am I obligated to provide data?


As part of our business relationship, you must provide the personal data required in order to enter into a business relationship and perform its associated contractual obligations, or the personal data that we are required to collect by law. Without this information, we will generally not be able to conclude or execute the contract with you.
 
In particular, according to the money laundering regulations, we are obligated to identify you prior to entering into a business relationship with you on the basis of your identification document and to record and save your name, place of birth, date of birth, nationality, address and identification data. In order for us to be able to fulfil this legal obligation, you must provide us with the necessary information and documents in accordance with the Money Laundering Act and immediately notify us of any changes during the course of the business relationship. If you do not provide us with the necessary information and documents, we may not enter into or continue your desired business relationship.


 10. To what extent is there an automated decision-making process?


In principle, we do not use any fully automated decision-making processes pursuant to Art. 22 GDPR in order to justify or maintain the business relationship. If we do use these procedures in individual cases, we will inform you about this separately, if this is required by law. If you disagree with a decision that we have made based on your credit score, you have the right to require the decision to be reviewed by human evaluation, taking into account your point of view.


 11. Does profiling take place?


We sometimes process your data automatically with the aim of evaluating certain personal aspects (profiling). For example, we use profiling in the following cases:

  • Due to legal and regulatory requirements, we are committed to combating money laundering, the financing of terrorism, and property-related offences. At the same time, data evaluations are also carried out (inter alia in payment transactions). These measures are also in place for your protection.
  • In order to provide you with targeted information and advice on products, we use evaluation tools. These enable needs-based communication and advertising, including market and opinion research.
  • We use the scoring to assess your creditworthiness. This calculates the probability with which a customer will meet their payment obligations in accordance with the contract. The calculation may include, for example, income, expenses, existing liabilities, occupation, employer, duration of employment, past business experience, past repayment of the loan, and information from credit reporting agencies. The scoring is based on a mathematically-statistically recognised and proven procedure. The calculated scores help us make decisions within the context of product sales and are part of ongoing risk management.

 Information about your right of revocation according to Art. 21 GDPR


1. Case-specific right of revocation
You have the right at any time, for reasons arising from your particular situation, to revoke your consent for the processing of personal data relating to you, which takes place on the basis of Article 6 (1) (e) GDPR (data processing in the public interest) and Article 6 (1) (f) GDPR (data processing on the basis of a balance of interests); this also applies to profiling based on this provision within the meaning of Art. 4 (4) GDPR.
 
If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or unless the processing serves the establishment, exercise or defence of legal claims.


2. Right to revoke your consent to the processing of data for direct advertising purposes
In individual cases, we process your personal data in order to perform direct advertising. You have the right to object at any time to the processing of personal data concerning you for such advertising, which includes profiling to the extent that it is related to such direct advertising.
 
If you object to the processing for direct advertising purposes, your personal data will no longer be processed for such purposes.
 
You can revoke your consent to this by sending a correspondingly worded letter to GRENKE, Data Protection Officer, No.2 London Square, Cross Lanes, Guildford, Surrey GU1 1UN or email dataprotection@grenke.co.uk .