AutoMoney Limited: Privacy Notice

14 Automated processing

• In the course of providing products and services to you we may process your personal information by automated means, to include profiling. What this means is that we will use computer software or predictive analysis to automatically evaluate your personal circumstances in order to identify risks or to predict certain outcomes. Examples of this type of processing include;
  1. automatically calculating loan limits;
  2. obtaining credit reference checks for certain products;
  3. the assessment of account activity to detect and prevent fraud; and
  4. the identification of customers in vulnerable situations so that we can offer them support or protection.
• Profiling is a useful tool as we try to understand our customers and their specific needs in more detail. It gives us the opportunity to use personal information to tailor our marketing and product offering but also to ensure that we achieve fair customer outcomes. However, our customers do have rights and entitlements in relation to automated processing and these are covered in Table A. You also have the right to opt out of profiling for marketing purposes.

Schedule A – Purposes of Processing

We will only use and share your information where it is necessary for us to carry out lawful business activities. Your information may be shared with and processed by other Norfolk Capital Group companies. We want to ensure that you fully understand how your information may be used.  We have described the purposes for which your information may be used in detail in the table below:

A – Contractual Necessity

We may process your information where it is necessary to enter into a contract with you for the provision of our products or services or to perform our obligations under that contract.  Please note that if you do not agree to provide us with the requested information, it may not be possible for us to continue to provide products and services to you.

This may include processing to:

1. assess and process applications for products or services;
2. provide and administer those products and services throughout our relationship with you, including opening, setting up or closing your agreement, collecting and issuing all necessary documentation, processing transactions, resolving any queries or discrepancies and administering any changes. Calls to and from us may be recorded and monitored for these purposes;
3. manage and maintain our relationship with you and for ongoing customer service;
4. administer any debts, including agreeing repayment options; and
5. communicate with you about your agreement or the services you receive from us.

B – Legal Obligation

When you apply for a product or service (and throughout your relationship with us), we are required by law to collect and process certain personal information about you. Please note that if you do not agree to provide us with the requested information, it may not be possible for us to provide products and services to you. This may include

processing to:

1. confirm your identity;
2. perform checks and monitor transactions data for the purpose of preventing and detecting crime and to comply with laws relating to money laundering, fraud, terrorist financing, bribery and corruption, and international sanctions. This may require us to process information about criminal convictions and offences, to investigate and gather intelligence on suspected financial crimes, fraud and threats and to share data with law enforcement and regulatory bodies;
3. assess affordability and suitability of credit for initial credit applications and throughout the duration of the relationship, including analysing customer credit data for regulatory reporting;
4. share data with police, law enforcement, tax authorities or other government and fraud prevention agencies where we have a legal obligation, including reporting suspicious activity;
5. deliver mandatory communications to customers or communicating updates to product and service terms and conditions;
6. investigate and resolve complaints;
7. conduct investigations into breaches of conduct and internal policies by our employees;
8. manage contentious regulatory matters, investigations and litigation;
9. provide assurance we have effective processes to identify, manage, monitor and report the risks we are or might be exposed to;
10. coordinate responses to business-disrupting incidents and to ensure facilities, systems and people are available to continue providing services; and
11. provide reasonable adjustments.

C – Legitimate Interest

We may process your information where it is in our legitimate interests do so as an organisation or where it is in the legitimate interest of a third party.

1. We may process your information in the day-to-day running of our business, to manage our business and financial affairs and to protect our customers, employees and property. It is in our interests to ensure that our processes and systems operate effectively and that we can continue operating as a business. This may include processing your information to:
   1. monitor, maintain and improve internal business processes, information and data, technology and communications solutions and services;
   2. ensure business continuity and disaster recovery and respond to information technology and business incidents and emergencies;

• ensure network and information security, including monitoring authorised users’ access to our information technology for the purpose of preventing cyber-attacks, unauthorised use of our telecommunications systems and websites, prevention or detection of crime and protection of your personal data;

1. provide assurance our material risks and reporting to internal management and supervisory authorities on whether we are managing them effectively;
2. perform general, financial and regulatory accounting and reporting;
3. protect our legal rights and interests; and

• enable a proposed or actual sale, reorganisation, transfer or other transaction relating to our business.

1. It is in our interest as a business to ensure that we provide you with the most appropriate products and services and that we continually develop and improve as an organisation. This may require processing your information to enable us to:
   1. identify new business opportunities and to develop enquiries and leads into applications or proposals for new business and to develop our relationship with you;
   2. send you relevant marketing information. We may show or send you marketing material online (on our own and other websites including social media platforms), or by email, SMS or post. We will not share your information with third parties for their own marketing purposes;

• understand our customers’ actions, behaviours, preferences, transactions, feedback and financial history in order to improve our products and services, develop new products and services, and to improve the relevance of offers of products and services offered by us;

1. research your experiences with us and to monitor the performance and effectiveness of products and services;
2. assess the quality of our customer services and to provide staff training. Calls to and from us may be recorded and monitored for these purposes;
3. perform analysis on customer complaints for the purposes of preventing errors and process failures and rectifying negative impacts on customers;

• compensate customers for loss, inconvenience or distress as a result of services, process or regulatory failures;
• combine your information with third party data, such as economic data in order to understand customers’ needs better and improve our services; and

1. consider your welfare needs including any adjustments, support or different products or services which might be suitable or protections to put in place.

1. It is in our interest as a business to manage our risk and to determine what products and services we can offer and the terms of those products and services. It is also in our interest to protect our business and customers and others by preventing financial crime, fraud and other criminal activities. This may include processing your information to:
   1. carry out financial and credit risk assessments;
   2. manage and take decisions about your products and services;

• carry out checks (in addition to statutory requirements) on customers and potential customers, business partners and associated persons, including performing adverse media checks, screening against external databases and sanctions lists and establishing connections to politically exposed persons;

1. share data with credit reference, fraud prevention agencies and law enforcement agencies;
2. trace debtors and recovering outstanding debt;
3. for risk reporting and risk management;

• perform checks, monitoring and investigation to prevent and detect crime including in relation to money laundering, fraud, terrorist financing, bribery and corruption, trafficking and international sanctions. It may involve investigating and gathering intelligence on suspected financial crimes, fraud and threats and sharing data with third parties including law enforcement and regulatory bodies;
• responding and participating in industry improvements and consultations; and

1. responding to and investigating complaints both raised directly to us, or raised through a third party such as a regulatory body.