Privacy Policy

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.

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.

This version of our Privacy Policy is live from August 2024

What information do we collect?

The information we collect includes some or all of the following:

1. Full name (including title);
2. Address;
3. Phone number;
4. Email address;
5. The date and time you used our services;
6. The pages you visited on our website and how long you visited us for;
7. Device identifiers such as your IP address;
8. Your GPS location (where you have permitted access to this);
9. The internet browser and devices you are using;
10. Cookie, Pixels or Beacon information (for more information please see our Cookie Policy);
11. The website address from which you accessed our website;
12. Details of any transactions between you and us;
13. Any information within correspondence you send to us;
14. Financial and employment details;
15. Banking and credit card details;
16. Documentation relating to your identification; and
17. CCTV.

We only collect information which is necessary, relevant and adequate for the purpose you are providing it for.

How is your personal information collected?

We may collect information about you (and/or your vehicle) from:

• you, including if you contact us (including any email address, Internet Protocol (IP) address or telephone number supplied by your electronic service provider) or if you use our products or services, or engage with our website or other online applications;
• other companies who provide services to us, such as insurance companies.

We may also collect information about you (and/or your vehicle) when you use:

• VWFS’s websites and applications. This online information includes some or all of the following:
  • information you provide when you register to use the sites, browse content on the sites or use other functionality;
  • details of your visits to the sites including, but not limited to traffic data, location data and other communication data, and the resources that you access; and/or
  • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform (please see further our cookie policy);

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).

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:

Consent:

Where you have provided your consent, we may use and process your information (including cookie data) to contact you from time to time about promotions, events, products, services or information which we think may be of interest to you. For further information on our use of cookie data, please see our cookie policy.

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

Contractual performance

We may use and process your personal information where this is necessary to perform and manage 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 and to recover debts.

Legitimate Interests

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

1. To respond to correspondence you send to us and fulfil the requests you make to us (for example, with regards to your finance agreement or account with us);
2. To provide vehicle support and services (for example, with regards to maintenance or insurance);

Processing necessary for us to respond to, or understand, customers’ needs

1. To analyse, evaluate and improve our products and services so that your visit and use of our website, applications, customer service centre and dealer network are more useful and enjoyable (we will generally use data gathered from many people so that it doesn’t identify you personally);
2. 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 that we think you will be interested in. We will only send marketing communications to you if you have provided your consent for us to do so or which we have obtained in the ways mentioned in the paragraphs below;
3. For product development purposes (for example to improve vehicle quality, performance and safety);

Processing necessary for us to assess and respond to complaints, claims and regulators

1. To respond to queries, complaints or claims and to manage legal and regulatory requests and requirements;
2. To enforce or protect our legal rights or to establish, bring or defend legal claims;

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

1. To verify the accuracy of information that we hold about you and create a better understanding of you as a customer;
2. 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;
3. 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);
4. To inform you of updates to our terms and conditions and policies, where possible;

Processing necessary for us to fulfil our legal obligations

1. To comply with our obligations before we provide finance, goods or services to you as both a responsible lender and FCA authorised firm, such as assessing creditworthiness and product suitability, verifying your identity, managing your account, tracing and recovering debts and preventing criminal activity.
2. To prevent fraud and money laundering, and to verify identity before we provide services, goods or financing to you;
3. To ensure that we continue to fulfil our ongoing obligations with regards to preventing fraud and money laundering and to verify identity, in order to protect our business and to comply with laws that apply to us. If we, or a fraud prevention agency, consider you to pose a fraud or money laundering risk, we may refuse to provide the services and financing you have requested, or we may stop providing existing services to you. A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you. If you have any questions about this, please contact us on the details below;
4. To enable us to assess fraud or money laundering risk by automated means, which may indicate that you pose a risk or if our processing reveals your behaviour to be consistent with that of known fraudsters or money launderers; or is inconsistent with your previous submissions; or you appear to have deliberately hidden your true identity. You have rights in relation to automated decision making: if you want to know more please contact the Data Protection Officer using the details below; and/or
5. To comply with other legal or regulatory requirements (for example, to register your car with the DVLA), to assist, or respond to a request for information from, an authorised authority, regulatory body or court, or to respond to a court order.

Vital Interest

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 and third party service providers who fulfil business activities for us (like roadside assistance, 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:

• where the law says we may or must do so;
• to comply with our ongoing obligations to prevent fraud and money laundering by allowing law enforcement and fraud prevention agencies to access and use your personal information to detect, investigate and prevent crime;
• to companies that provide services to us so we can perform activities relating to your contract and/or to enforce any contract we have with you and/or to protect our rights and/or property;
• to our advisors, and investors and their advisors for corporate finance purposes, for example, in the event that we sell or buy any business or assets, or if VWFS or substantially all of its assets are acquired by a third party.

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), where necessary, in order to:

• fulfil orders;
• facilitate transactions;
• handle complaints;
• provide you with service(s) or information that you have requested;
• facilitate audit, statistical analysis, risk management and product and service development purposes; and
• comply with legal requirements.

For example, we will share information with branded trading divisions of Volkswagen Group United Kingdom Limited (“VWG”) 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.

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 http://www.volkswagen.co.uk/privacy .

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 nonspecific 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, fraud prevention agencies may allow the transfer of your personal data outside of the UK. This may be to a country where the UK Government has decided that your data will be protected to UK standards, but if the transfer is to another type of country, then the fraud prevention agencies will ensure your data continues to be protected by ensuring appropriate safeguards are in place.

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/or other third parties who have a business need to know it. 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 will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer an employee, worker or contractor of the company we will retain and securely destroy your personal information in accordance with our Record Retention policy.

In the case of employees, this means that, in most circumstances we will retain their personal data while their employment continues and for seven years after it ends.

How can you manage the information we hold about you?

Under certain circumstances, by law you have the right to:

Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.

Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

Request the transfer of your personal information to another party.

If you wish to enquire about or exercise any of these rights, please contact HR.hub@vwfs.co.uk.

No fee usually required

You will not usually have to pay a fee to access your personal information (or to exercise any of the other rights). However, 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.

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

Email: HR.hub@vwfs.co.uk

Who can you contact if you have a question or a complaint?

If you have any specific data protection concerns or a complaint, please contact HR.hub@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:

Post:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Call: 03031 231 113

If you wish to raise a complaint to the ICO, you can do so via their website under 'Make a complaint' at the following link: https://ico.org.uk/make-a-complaint/

If you would like further information regarding how the fraud prevention agencies process your personal data, you can view their privacy policies on their websites, as below:

CIFAS: www.cifas.org.uk

Hunter: www.nhunter.co.uk