Finclusion Limited

Customer Privacy Notice

This privacy notice tells you what to expect us to do with your personal information.

Contact details

What information we collect, use, and why

Lawful bases and data protection rights

Where we get personal information from

How long we keep information

Who we share information with

How to complain

Contact details

Post

1 Heddon Street, LONDON, W1B 4BD, GB

Telephone

+44 (0)1625 324445

Email

contact@finclusion.co.uk

What information we collect, use, and why

We collect or use the following information to provide services and goods, including delivery:

Names and contact details

Addresses

Date of birth

Purchase or account history

Payment details (including card or bank information for transfers and direct debits)

Credit reference information

Health information
Account information

Website user information (including user journeys and cookie tracking)

Call recordings

Identification documents

Information relating to compliments or complaints

We also collect or use the following special category information to provide services and goods, including delivery. This information is subject to additional protection due to its sensitive nature:

We collect or use the following information for the operation of customer accounts and guarantees:

Names and contact details

Addresses

Payment details (including card or bank information for transfers and direct debits)

Purchase history

Account information, including registration details

Information used for security purposes

Marketing preferences

We also collect or use the following special category information for the operation of customer accounts and guarantees. This information is subject to additional protection due to its sensitive nature:

We collect or use the following information to prevent, detect, investigate or prosecute crimes:

Names and contact information

Customer or client accounts and records

Financial transaction information

We also collect or use the following special category information to prevent, detect, investigate or prosecute crimes. This information is subject to additional protection due to its sensitive nature:

We collect or use the following information for service updates or marketing purposes:

Names and contact details

Addresses

Marketing preferences

Location data

Call recordings

IP addresses

Website and app user journey information

Records of consent, where appropriate

We collect or use the following information to comply with legal requirements:

Name

Contact information

Identification documents

Financial transaction information

Any other personal information required to comply with legal obligations

We also collect or use the following special category information to comply with legal requirements. This information is subject to additional protection due to its sensitive nature:

We collect or use the following personal information for dealing with queries, complaints or claims:

Names and contact details

Address

Payment details

Account information

Purchase or service history

Call recordings

Customer or client accounts and records

Financial transaction information

Correspondence

We also collect the following special category information for dealing with queries, complaints or claims. This information is subject to additional protection due to its sensitive nature:

Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.
Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.
Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure.
Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.
Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing.
Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.
Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.
The right to request a review of any automated decision making we use with regard to your finance application

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide services and goods are:

Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

For example: Assessing your application fairly and accurately helps us avoid lending irresponsibly and protects you from financial hardship. Verifying identity and carrying out fraud checks helps safeguard all parties from criminal activity. Ongoing account management and communications ensure that we can support you throughout your agreement and respond effectively to any issues. Analytics and service improvement allow us to develop better products and deliver a better customer experience. We believe the benefits of processing your personal data, such as improved access to credit, personalised services, and enhanced security, are balanced against the minimal risk of harm. We apply robust safeguards, including encryption, data minimisation, and strict access controls, to protect your rights and interests.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Our lawful bases for collecting or using personal information for the operation of customer accounts and guarantees are:

Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

At Finclusion Ltd, we process personal information to provide responsible and effective motor finance services. The data we collect enables us to assess your creditworthiness, verify your identity, comply with legal and regulatory obligations, and tailor finance options to suit your circumstances. We do this to ensure that the finance we provide is affordable, appropriate, and aligned with your needs. This processing is both necessary and in our legitimate interests, as well as those of our customers and partners. For example: Assessing your application fairly and accurately helps us avoid lending irresponsibly and protects you from financial hardship. Verifying identity and carrying out fraud checks helps safeguard all parties from criminal activity. Ongoing account management and communications ensure that we can support you throughout your agreement and respond effectively to any issues.

Analytics and service improvement allow us to develop better products and deliver a better customer experience. We believe the benefits of processing your personal data, such as improved access to credit, personalised services, and enhanced security, are balanced against the minimal risk of harm. We apply robust safeguards, including encryption, data minimisation, and strict access controls, to protect your rights and interests.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Our lawful bases for collecting or using personal information to prevent, detect, investigate or prosecute crimes are:

Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

Preventing and Detecting Crime

As a responsible motor finance provider, Finclusion Ltd processes certain personal information to help prevent, detect, investigate, and, where appropriate, support the prosecution of crime, including fraud, identity theft, money laundering, and other financial crimes. This is necessary and in our legitimate interests, as well as in the public interest and in the interest of our customers and partners. Criminal activity undermines trust in financial services and can cause significant financial harm to individuals and organisations.

By using personal information, such as identity data, transaction history, and behavioural patterns, we can detect unusual or suspicious activity that may indicate fraud or other criminal behaviour. For example, we may: Verify your identity using third-party data sources and fraud prevention agencies. Monitor applications and transactions for signs of fraud or misuse. Share information with law enforcement or regulatory bodies where required or appropriate. The benefit of this processing is enhanced protection for you, our business, and the wider financial system. We always strive to ensure that our use of personal data for these purposes is proportionate, targeted, and respectful of your privacy.

We implement strong security and governance measures to prevent misuse or overreach, and regularly review our processes to ensure they remain justified and compliant.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Our lawful bases for collecting or using personal information for service updates or marketing purposes are:

Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

Our lawful bases for collecting or using personal information for legal requirements are:

Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

Finclusion Ltd processes personal information to respond to and resolve customer queries, complaints, and claims effectively and fairly. This is necessary for the ongoing management of our relationship with you and is in both our legitimate interests and yours. Accurate and complete personal information allows us to: Identify you and understand the nature of your concern. Investigate issues thoroughly and respond in a timely and appropriate way. Keep accurate records of communications and decisions. Engage with third parties such as legal representatives, the Financial Ombudsman Service, or insurers where required.

This processing supports transparency, accountability, and regulatory compliance. It enables us to improve our services, protect your rights, and fulfil our obligations under complaint-handling rules. The benefits of processing this information, ensuring fair outcomes and providing you with a clear and responsive service, are significant and clearly outweigh any minimal impact on your privacy. We handle this data securely, retain it only for as long as necessary, and restrict access to authorised personnel. We do not use this information for any purpose that would be unfair or unexpected, and our approach ensures that your interests and rights are always respected.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Where we get personal information from

Directly from you

Credit reference agencies

Finclusion Ltd obtains customer personal information from motor retailers, for the purposes of assessing motor finance applications.

How long we keep information

Our data retention period is 10 years from the conclusion of your contract with us.

For more information on how long we store your personal information or the criteria we use to determine this please contact us using the details provided above.

Who we share information with

Joint data controllers

We have joint controller relationships with other organisations that use your personal information. We process your personal information with that joint controller for the following reasons:

Processing of your motor finance application.