DATA PRIVACY STATEMENT
Who we are?
White Oak UK is a trading style of LDF Operations Limited, LDF Ops Limited, LDF Finance No.1 Limited, LDF Finance No.2 Limited, LDF Finance No.3 Limited, White Oak UK No.4 Limited, White Oak UK No.5 Limited, White Oak UK No.6 Limited and White Oak UK (CBILS) Limited incorporated in England and Wales, registered office, Second Floor, HQ Offices, 58 Nicholas Street, Chester, England, CH1 2NP.
White Oak UK is a trading style of LDF Ops Limited, incorporated in Scotland, registered office, Sixth Floor, 58 Waterloo Street, Glasgow, G2 7DA.
Data Protection Officer: Michael Hebblewhite
Contact Number: 01244 527300
Email Address: DataProtection@whiteoakuk.com
ICO Registration:
LDF Operations Limited – Z5056435
LDF Ops Limited – Z7782488
LDF Finance No.1 Limited- ZA026073
LDF Finance No.2 Limited – ZA041001
LDF Finance No.3 Limited – ZA041165
White Oak No.4 Limited – ZA520870
White Oak No.5 Limited – ZB147948
White Oak No.6 Limited – ZB147961
White Oak (CBILS) Limited ZA757143
What does this Data Protection Statement cover?
(a) The terms set out in this Data Protection Statement apply to any information you give WO from time to time and to any information you have already provided.
(b) We may revise or supplement our Data Protection Statement from time to time for any of the following reasons:
• to provide for the introduction of new or improved systems, methods of operation, services or facilities; to reflect an actual or expected change in market conditions or general banking practice;
• to comply with or anticipate any changes in any legal or regulatory requirement;
• to ensure that our business is run prudently; and
• to make our Data Protection Statement clearer or more favourable to you; or to rectify any mistake that might be discovered from time to time.
If you do not wish to accept the new Data Protection Statement you should contact us immediately. Otherwise your continued use of WO services shall indicate your acceptance of the updated Data Protection Statement.
(c) You must not send us personal information about someone else without first getting the individual’s consent for it to be used and disclosed in the ways set out in our Data Protection Statement. If you give us information (including personal information) on behalf of someone else, you confirm that the other person has given you permission to act on their behalf and has agreed that you can:
• provide their personal information to us;
• give consent on their behalf to the processing of their personal data;
• receive on their behalf any data protection notices; and
• give consent to the transfer of the individual’s personal data abroad.
Where you do give us information about someone else, or someone else discloses a connection with you, that information may be taken into account with your other personal information when assessing your application to receive our products or services.
(d) We treat your privacy very seriously and we understand that you will wish to know how we will use the information we collect from or about you. We use your personal information in accordance with our Data Protection Statement and will fully comply with all applicable UK data protection legislation (including the EU General Data Protection Regulation as amended or replaced). It is important that you take all necessary and appropriate steps to protect your data yourself (for example, by ensuring that all passwords and access codes are kept secure).
What information do WO collect?
We may collect and process the following information about you:
(a) Information you provide (either directly or through an agent such as a solicitor, independent financial advisor or introducer) by completing an application for our products and services, whether in writing, on our website, over the telephone or by some other means. This information may include your name, address, contact details, date of birth, bank details, details about your employment and financial information and may extend to copies of identification documents (such as passport, driving licence and/or utility bills).
(b) Other personal data supplied by you when you contact us by other means (such as by email or telephone), and records of any correspondence from you or anyone acting on your behalf.
(c) Personal details provided via our website (for example, via the ‘Get in touch’ form). We process data that you provide to us when you complete our online form (such information may include, but may not be limited to, your name, telephone number, postal address and email address).
(d) Details of transactions you carry out with us.
(e) Your credit history, where you have applied for credit or where we have agreed to provide credit to you.
(f) Website technical information. When you visit the website, we record information about your usage of the website, including IP address, location, cookie data and details about the page you visited. Please see our Cookies Policy (below) for further information on the cookie data we process.
We may also collect personal data on you from other third parties from time to time. Please contact us at dataprotection@whiteoakuk.com. if you wish to be provided with a list of the third parties with whom WO regularly engage.
What will you do with my data?
We will act proportionately and responsibly when we process, transfer or disclose your information and we will act strictly in accordance with the applicable UK data protection laws. We use your personal data for the following purposes:
We may process, transfer and disclose your information for the purposes of:
• providing you with services, managing your accounts and complying with your instructions;
• verifying your identity;
• making credit decisions, where you have applied for credit or where we have agreed to provide credit to you;
• detecting and preventing fraud;
• complying with laws and regulations (including the rules of any regulatory authority) and public duties;
• monitoring and/or recording your telephone calls and electronic transactions in order to accurately carry out your instructions; assisting in improving our services and in the interests of security and crime prevention;
• market research and providing you with information via mail, telephone or other means about WOUK Group’s products or services from time to time (please see the heading ‘Marketing’ below for further information); and
• analysis in order to assess and improve our business.
Where you have applied for credit or where we have agreed to provide credit to you, we may from time to time make searches of your record at a credit reference agency (‘CRA’). You hereby consent to the processing of your personal data in this manner and confirm that you have obtained specific authority from the partners/co- directors of your business to give consent on their behalf to their personal information being processed in this manner. If the beneficial owners of your business are not the partners or directors of your business, you hereby confirm that you have notified the beneficial owners that we will also conduct due diligence checks on them to prevent fraud and money laundering. Your record includes searches made and information given by other businesses. Details of our searches will be kept by the agency and will be seen by other organisations that make searches with the agency for the purposes of credit assessment, debt recovery, management of your accounts, prevention of money laundering and fraud, and statistical analysis.
To do this, we will supply your personal information to CRAs and they will give us information about you. This will include information from your credit application and about your financial situation and financial history. CRAs will supply to us both public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information.
WO and our panel of lenders complete soft and/or hard searches on your credit file. A hard search is when a company makes a complete search of your credit report. Each hard search is recorded on your report, so any company searching it will be able to see that you have applied for credit. A soft search is an initial look at certain information on your credit report. Companies perform soft searches to decide how successful your application would be without conducting a full examination of your credit history.
We will use your information to:
• Assess your creditworthiness and whether you can afford to take the product;
• Verify the accuracy of the data you have provided to us;
• Prevent criminal activity, fraud and money laundering;
• Manage your account(s);
• Trace and recover debts; and
• Ensure any offers provided to you are appropriate to your circumstances.
We will continue to exchange information about you with CRAs while you have a relationship with us. We will also inform the CRAs about your settled accounts. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt. This information may be supplied to other organisations by CRAs.
If you are making a joint application or tell us that you have a spouse or financial associate, we will link your records together, so you should make sure you discuss this with them, and share with them this information, before lodging the application. CRAs will also link your records together and these links will remain on your and their files until such time as you or your partner successfully files for a disassociation with the CRAs to break that link.
The identities of the CRAs, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRAs are explained in more detail at
• Transunion www.transunion.co.uk/legal/privacy-centre/pc-credit-reference
• Equifax www.equifax.co.uk/crain;
• Experian www.experian.co.uk/crain.
The personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance or employment. Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights, can be found by following this link https://www.cifas.org.uk/fpn or requesting information from your WO representative.
Our Legal Grounds for Handling Your Personal Data
The UK’s Data laws allow us to use your personal data provided where we have a lawful basis to do so. The lawful basis we rely on for processing your data are shown below:
• Performance of contract with you (contractual obligation): We need to use your personal data to legally contact you.
• Compliance with legal obligation: we need to use your personal data so we comply with certain legislation, for example financial crime.
• Legitimate Interests: there are business and commercial reasons for using your data, which we have balanced against your interests. We have certain legitimate interests in using your data which are not weighed by your interests, fundamental rights or freedoms.
• Consent: we may also use your data when you consent to it. You can withdraw your consent at any time, in which case we will cease to use it, unless we have a right and a need to continue processing it for one of the other reasons set out above.
Much of what we do with your personal data is not based on your consent and is instead based on other legal grounds. In the instance however, that the processing of your personal data by us is based on your consent, you may withdraw your consent at any time, by emailing us at DataProtection@whiteoakuk.com. If you withdraw your consent, this will not affect the lawfulness of any processing which has taken place before you have withdrawn your consent.
Marketing
We may from time to time contact you about similar products and services available from the WO Group which we believe may be of interest to you. We may do this by e-mail, text or other electronic means, post or by phone unless you have told us that you do not wish to receive this material. If at any time you wish to stop receiving marketing information from us, you can request this in a number of ways, by simply contacting us by any of the means listed in the contact us section of our website, by emailing dataprotection@whiteoakuk.com or by writing to the address provided at the bottom of this Data Protection Statement
Who we share your data with and why
We may disclose your personal information to the following recipients:
(a) Where you have been introduced to us by an introducer such as an independent financial advisor, we will inform the introducer about the outcome of your application and whether we have agreed to provide you with the product or service for which you have applied. We may also disclose information about you and your relationship with us (including details of any related investment) throughout the term of that relationship. If you do not wish us to disclose this information, please inform us in writing.
(b) We engage other companies and individuals to perform functions on our behalf, including our data hosting and payment processing suppliers. We do not share your personal information with our agents or suppliers except as is necessary in order to enable them to provide us with a service.
(c) Your personal information may be passed to and used by companies within WO Group and its agents and sub- contractors who administer or process the information on its behalf. Please contact the Head of Data at Second Floor, HQ Offices, 58 Nicholas Street, Chester, CH1 2NP for an up-to-date list of the current members of WO Group.
(d) We may also disclose your personal information to third parties in the following circumstances:
In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation.
International data transfers and security
We may transfer your personal information outside the European Economic Area (EEA) to countries which may not offer the same level of data protection as the United Kingdom. If we do so, we shall undertake an assessment and put in place adequate safeguards, in accordance with applicable data protection laws, to ensure third party recipient will provide adequate security of such personal data and respect your rights to privacy.
For further information on the adequate safeguards used by us, please contact us at DataProtection@whiteoakuk.com.
Your Choices and Rights You Have
• Right to be informed: Individuals have the right to be informed about the collection and use of their personal data.
• Right of access to your personal data: Individuals have the right to access and receive s copy of your personal data and other supplementary information. To obtain a copy of their personal data and other supplementary information. To obtain a copy of the personal information we hold, you should write to the Head of Data at White Oak UK Group using the email address DataProtection@whiteoakuk.com. White Oak UK will respond to you within 30 days on receipt of request. You may also request from us details of the credit reference agencies and fraud prevention agencies with which we may have carried out searches.
• Right to rectification: Individuals have the right to have inaccurate personal data rectified or completed. If there are any inaccuracies in the information we hold about you, please notify us of this in order that we may correct the information we hold about you, please contact the Head of Data at dataprotection@whiteoakuk.com
• Right to erasure: Individuals have the right to have their personal data erased, in some circumstances. Please contact the Head of Data at DataProtection@whiteoakuk.com.
• Right to restrict processing: Individuals have the right to request the restriction or suspension of their personal data in some circumstances. Please contact the Head of Data at DataProtection@whiteoakuk.com.
• Right to Portability: This allows individuals to obtain and re-use their personal data for their own purposes across different services, in some circumstances.
• Right to object: This gives the individuals the right to object to the processing of their personal data in certain circumstances, it also gives individuals the right to stop their personal data being used for direct marketing.
• Automated Decision Making and Profiling: This gives individuals the right to object to their data being used in an automated individual decision making process and profiling (profiling can be used as part of an auto-decision making process). If you would like to invoke this right, please contact the Head of Data at DataProtection@whiteoakuk.com
Retention of your personal data
We will not retain your personal data for longer than is necessary for the purposes for which the personal data is processed. This means that your information will only be held for as long as we need to process it to provide you with services, is necessary for legal reasons or in accordance with our legitimate interests, and in accordance with UK data protection laws.
When calculating the appropriate retention period for your data, we consider the nature and sensitivity of the data, the purposes for which we are processing the data, and any applicable statutory retention periods. Using these criteria, we regularly review the personal data which we hold and the purposes for which it is held and processed.
When we determine that personal data can no longer be retained or where you request us to delete your data in accordance with your right to do so, we ensure that this data is securely deleted or destroyed.
For more details about our retention periods, please contact us at dataprotection@whiteoakuk.com.
What you should do if your personal information changes
If your personal information changes, you should tell us without delay so that we can update our records. If you were introduced to us by a broker or other intermediary who is a data controller in its own rights, then you should contact them directly too.
How to contact us
If you have any comments or questions about our Data Protection Statement, please contact the Head of Data at White Oak UK Group at DataProtection@whiteoakuk.com
If you are unhappy about how your personal data has been used by us, please contact the Head of Data at White Oak UK Group at DataProtection@whiteoakuk.com
You also have the right to make a complaint to the Information Commissioner’s Office (ICO). You can contact them using the number 0303 123 1113 or email casework@ico.org.uk
further contact details can be found using the following link https://ico.org.uk/global/contact-us/
Funders Privacy Notices
365 Business Finance – Privacy Policy – 365 Finance
Admiral Leasing & Loans – www.admiral-leasing.co.uk/privacy-policy/
Aldermore Bank PLC – Privacy Policy | Aldermore Bank
Allica Bank – Privacy Policy | Expert SME Banking | Allica Bank
Arkle Finance – https://arklefinance.co.uk/privacy-policy/
Armada Asset Finance – https://www.armadaassetfinance.com/privacy/
Bibby Leasing Ltd – Privacy Notice – Bibby Financial Services
Bizlend Ltd t/a Swiftfund – Privacy Policy – Swiftfund
BNP Paribas – Data Protection – BNP Paribas (group.bnpparibas)
Braemar Finance – Privacy | Braemar Finance
Cambridge and Counties Bank – Your privacy | Our commitments | About us | Cambridge & Counties Bank (ccbank.co.uk)
Carrick Finance – Privacy Policy – Carrick Asset Finance (carrickfinance.com)
Close Brothers Asset Finance Ltd – Privacy (closeassetfinance.co.uk)
Close Brothers Business Finance – Privacy (closeassetfinance.co.uk)
Close Brothers Premium Finance – Privacy (closeassetfinance.co.uk)
Credit 4 – Privacy – Credit4
Dawson Group – Dawsongroup | Privacy Notices
De Lage Landen Leasing Limited – Privacy statement (dllgroup.com)
Eastern Credit Ltd – www.easterncredit.co.uk
Federal Capital – Federal Capital – Legals
Fleximize – Privacy Policy – Terms and Conditions – Fleximize
Got Capital – https://www.gotcapital.co.uk/privacy-policy/
Haydock Finance Ltd – Privacy Policy | Haydock Finance
Investec – https://www.investec.com/en_gb/legal/privacy-policy.html
Iwoca – Customer privacy policy | iwoca – iwoca
Kingsley Asset Finance Ltd – https://www.kingsleyassetfinance.co.uk/privacy-policy
Liberty Leasing Ltd – Privacy notice – Liberty Leasing | Asset Finance Specialists
Lloyds Bank – Privacy Statement | Business Banking | Lloyds Bank
Maximise Capital Ltd – Privacy Policy | MaxCap
Momenta Finance – https://momentafinance.co.uk/legal/privacy-policy/
Northridge Finance- Your Data – Northridge (northridgefinance.com)
Novuna Business Finance – Privacy Policy | Novuna
Nucleus Commercial Finance Ltd – Privacy Notice | Nucleus Commercial Finance
Penny Freedom – Privacy Policy | Penny (pennyfreedom.co.uk)
Praetura Asset Finance – Privacy Policy – Praetura Asset Finance (praeturaaf.com)
Premium Credit Limited – Privacy Notice (premiumcredit.com)
Quantum Funding Ltd – Quantum Funding Limited (investec.com)
Shawbrook Bank Limited – Privacy Notice | Shawbrook
Siemens Financial Services Limited – Privacy Notice – Siemens United Kingdom
Simply Asset Finance – Privacy Policy – Simply
Metro Bank – https://www.metrobankonline.co.uk/about-us/privacy/
Societe Generale Equipment Finance Ltd – https://equipmentfinance.societegenerale.co.uk/en/privacy-policy/
Time Finance – Privacy Policy – Time Finance
Together Commercial Mortgages – Privacy and Cookie Policy | Together (togethermoney.com)
Ultimate Asset Finance – Ultimate Finance | Privacy Policy
United Trust Bank – https://www.utbank.co.uk/privacy-notice/
Youlend – Ultimate Finance | Privacy Policy
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