Honda Financial Services Privacy Notice

Privacy Policy

Honda Finance Europe PLC t/a Honda Financial Services (“We”) are committed to protecting and respecting your privacy. This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of the Data Protection Act 2018 (“the Act”), the data controller is Honda Financial Services, a subsidiary of Honda Motor Europe Limited, located at: Cain Road, Bracknell, RG12 1HL. 

Information collection

We collect and process the following data about you:

Details that you provide when applying for finance from us and throughout the administration of your agreement with us including,

• Address (and previous addresses if less than 3 years) including time spent at address and nature of tenure (homeowner, tenant…etc)
• Mobile and home telephone numbers
• Email address
• Date of Birth
• Marital status
• Employment status
• Employer and length of time at employer
• Financial information including bank account name and number, sort code, years with bank and number of credit cards held as well as financial history in order to assess your creditworthiness and affordability of any lending to you
• Details of the vehicle being financed, including the make, model, VIN and registration number, description, and any additional information such as extras and accessories
• National Identity Card or other official documents as described on the Home Office Identity Verification list

We may also require additional evidence to validate signatures in some exceptional circumstances.

From time to time during the administration of your account and so as to provide an appropriate service tailored to your circumstances, we may collect sensitive personal data such as health and other special category data where disclosed to us.  Special category data includes data revealing racial or ethnic origin, genetic data, biometric data, health data, sexual orientation or criminal convictions and offences data.

You are provided with an opportunity to opt out from or to give an opt-in consent (depending on what is needed by law) in relation to receiving marketing communications from us or our partners at the time that your details are submitted or at the time you sign the finance agreement and on each occasion that you are contacted thereafter.

Honda Financial Services gather personal information from you for the purposes of underwriting and administering your account. The information we collect is limited to what is necessary for the purposes described. 

How we use your information 

We collect, use and store your personal data for the reasons set out below:

• To process your application for finance, which includes a process of automated decision making in some cases.
• To apply payments to your agreement and to perform the contract between us and you, our customer.
• For our legitimate interests in managing the quality of our service, including where responding to complaints.
• For our legitimate interests in analysing the performance of our products to ensure we continue to offer a competitive and customer-focussed service.
• Where necessary, to comply with a legal obligation including the detection and prevention of financial crime and identity fraud.
• Where information about your health or other special category personal data is provided by you due to arrears activity (i.e. to explain why you are in arrears) or if you have been identified as a vulnerable customer and in both these cases we would process this data with your consent.
• To pursue outstanding payments and recover assets where necessary for our legitimate interests or legal obligations.
• To enforce or protect our legal rights or to establish, bring or defend legal claims.
• To carry out analysis of our products and customers’ preferences through production of management information for our own legitimate interests.
• To understand what products would be best for you and your needs, in line with our obligations under the FCA (the Financial Conduct Authority) Consumer Duty.
• We also collect, use and share aggregated data such as statistical and demographic data for analysis and oversight purposes for our legitimate interests. This may be derived from your personal data however is not considered personal data in law where it does not directly or indirectly identify you. For example, we may analyse product preferences for different customer groups. Where we combine or connect this data with personal data, we treat the combined data as personal data.
• We may process your personal data for the purpose of protecting our legitimate business interests and legal rights. This includes, but is not limited to, use in connection with compliance, regulatory, auditing, legal claims (including disclosure of such information in connection with legal process or litigation) and other ethics and compliance requirements.

We may also use your data, or permit Honda affiliated third parties including our dealer network to use your data, to provide you with information about additional products and services which may be of interest to you and we or they may contact you about these by post, email or telephone in accordance with your preferences. The company we currently use to provide this service to us is Automotive Transformation Group (ATG). For our own direct marketing, depending on our relationship with you and the channel we want to use, we will either ask for your consent (which you can withdraw at any time) or we will do it for our legitimate interests and you can choose to opt-out.  

Where additional information is required to assess the affordability of our products at underwriting stage, with your consent where that’s needed, or based on this being necessary for our legitimate interests (i.e. without consent), we may view your data through Open Banking. 

For more information, please read our supplemental Open Banking Privacy Notice. We do not share your Open Banking data with any third parties.   

How we share your information

(a) Transfers within the Honda Group of Companies

We share your personal data with members of the Honda Group, for example Honda Motor Europe Ltd (HME). HME is the European subsidiary of Honda Motor Group and is responsible for the distribution of vehicles and other Honda products throughout the UK dealer network.

If we transfer personal data outside the UK and EEA, we use standard contractual data protection clauses, which have been approved by the European Commission, as well as the UK Addendum as approved by the UK Government, as an appropriate safeguard in compliance with data protection laws.

(b) Transfers to Honda authorised dealers

We may from time to time share your personal data with Honda authorised dealers in the UK for the purposes of managing your finance agreement, as explained in the section “How we use your information”. This may include at the time you may be discussing part exchange options, for example, data like your settlement figure, current monthly payment, equity position and the car you are driving. At no time will sensitive data be shared with a Honda dealer without your consent.

If your finance agreement was brokered by a dealer no longer operating, we may transfer your data to an alternative dealer within the same group, or to an alternative Honda dealership where the original brokering dealership is no longer operating. We rely on legitimate interests to do this.

Honda’s network of dealerships are independently owned and operated businesses. If you have any concerns about how a Honda dealer processes your personal data, please contact them in the first instance. Please check your preferred dealer privacy notice for details of how they may process your personal data.

A full list of Honda dealers may be accessed below:

• Cars - www.honda.co.uk/cars/dealer-list.html
• Motorcycles - www.honda.co.uk/motorcycles/dealer-list.html
• ATVs - www.honda.co.uk/atv/dealer-list.html

You can also search for your nearest Honda dealer using the following web links:

• Cars - www.honda.co.uk/cars/dealer-search.html
• Motorcycles - www.honda.co.uk/motorcycles/dealer-search.html
• ATVs - www.honda.co.uk/atv/dealer-search.html

(c) Transfers to companies providing services under contract

During the life of your agreement, your personal data may be shared with one or many of the categories of company below providing services under contract:

• IT and Telecoms companies
• Fulfilment and print companies
• Consultancy Services and legal firms
• Contract Hire provider
• Credit Reference Agencies
• From time to time during the administration of accounts in arrears or in order to recover and remarket assets related to agreements in arrears, or otherwise in breach, data may be transferred to a third party to perform services to deliver the contract.

All companies providing services under contract may be reviewed from time to time, in which case your data will be transferred to the new supplier of that service. 

We may share data with regulatory authorities, courts, the financial ombudsman or other legal authorities if requested to.

We may also share your data with third parties if we choose to sell, transfer or merge parts of our business or its assets. If a change happens to our business, then the new owner of the data may use your personal data in the same way as set out in their own privacy notice.

Sharing your information with Credit Reference Agencies

In order to process your application, we will perform credit and identity checks on you with one or more credit reference agencies (”CRAs”). 

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. 

We will use this 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. 

When CRAs receive a search from us they will place a search footprint on your credit file that may be seen by other lenders. 

If you apply with a joint applicant, such as a guarantor, we will link your records together. Therefore, you should make sure you discuss this with them before making the application. CRAs will also link your records together and these links will remain on your and their files until such time as one of you 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 www.experian.co.uk/legal/crain

The Credit Reference Agency Information Notice (CRAIN) is also accessible from each of the three CRAs.  To view the CRAIN document please visit any of the following:  

• Experian - https://www.experian.co.uk/legal/crain  
• Equifax - https:// https://www.equifax.co.uk/crain
• TransUnion - https://www.transunion.co.uk/legal/privacy-centre  

Sharing your information with Fraud Prevention Agencies

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.  

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

Further details of how your information will be used by us and these fraud prevention agencies and your data protection rights, can be obtained by writing to us at Customer Services Honda Finance Europe Cain Road Bracknell Berks RG12 1HL or telephoning us on the number listed below. 

Please call us on 0345 128 8908 if you want details of those credit reference and fraud prevention agencies from which we obtain, and to which we pass information about you. You have a legal right to these details.  

Market Research Surveys

We will process your personal information where you are invited to take part in, or are considering taking part in, one of our market research surveys. Most information collected cannot be used to identify you individually. However, in certain circumstances you may be asked to share personal information which can be used to identify you, including your:

• Name;
• Address;
• Email address;
• Telephone number; and
• Voice and appearance within an audio or video recording of you.

We may also create personal information about you when corresponding with you about your participation in a market research survey, or queries regarding your potential participation. We will only process information that is necessary for the purpose for which it has been received.

Where you have provided your consent, we may use and process your personal information to conduct our market research, analyse the results and produce a report and presentation of the findings which we use to better understand our customers and prospective customers, and the market conditions and trends in which our business operates.  You can withdraw your consent at any time by contacting our survey provider in the first instance, or us. 

Data Retention

We will retain your personal data only for as long as we need it for  the purpose for which it was collected, after which we will take steps to delete your personal data or hold it in a form that no longer identifies you.  

How long we keep your personal data will depend on a number of factors, including:

(i) any laws or regulations that we are required to follow;

(ii) whether we are in a legal or other type of dispute with each other or any third party;

(iii) the type of information that we hold about you; and

(iv) whether we are asked by you or a regulatory authority to keep your personal data for a valid reason.

TELEPHONE CALLS

Some telephone calls may be monitored or recorded but for the purpose only of maintaining and improving our service standards or for training our staff. The companies in our Group include Honda (U.K.) Limited and Honda Motor Europe Limited. 

EMAILING DOCUMENTS

We may send monthly statements, notices and other communications under or in relation to the Agreement (other than communications that are required by law to be sent as paper communications) to the email address you have provided as required to perform the services for you. Communications sent by email will not be password protected but will be in a non-editable format. 

Automated Decision Making

We may use automated decision making (a decision made solely by automated means without any human involvement) to make decisions about your lending eligibility in certain cases.  This means we may decide, in an automated way, whether to accept your lending application or not, based on the information you supply in your application and on other information we collect (as described in this Privacy Notice).   

The automated decisions will be based on certain facts and information that you have provided in your application form which are measured against our criteria for lending. Your application may be accepted on this basis based on the information you provide when applying. Where your application is not accepted, it will undergo a manual credit assessment.

Our lawful basis is that it’s necessary for entering into, or performance of, the contract with you.  Other automated decision making would need explicit consents (not relevant to what we do at this time and if that changes we’ll update this section and seek explicit consents). 

You also have the right to obtain human intervention where a decision has been made about you using automated decision making and to contest the decision.  See below for more details.

Your Rights

• Where our processing of your personal data is based on your consent, you have the right at any time to withdraw your consent. If you do decide to withdraw your consent we will stop processing your personal data for that purpose, unless there is another lawful basis we can rely on – in which case, we will let you know. Your withdrawal of your consent won’t impact any of our processing up to that point.
• Where our processing of your personal data is necessary for our legitimate interests, you can object to this processing at any time. If you do this, we will need to show either a compelling reason why our processing should continue, which overrides your interests, rights and freedoms or that the processing is necessary for us to establish, exercise or defend a legal claim.
• You have the right to request that we erase any data we hold about you where we do not have a legitimate basis for holding it (subject to certain conditions) 
• You have the right to request sight of all of the information we hold about you (this is more commonly known as submitting a “data subject access request”). 
• Subject to certain conditions, you are entitled to receive the personal data which you have provided to us and which is processed by us by automated means, in a structured, commonly-used machine readable format.
• You have the right to challenge the accuracy or completeness of your personal data and have it corrected or completed, as applicable. You have a responsibility to help us to keep your personal information accurate and up to date. To do this see the paragraph below.
• When we make automated decisions about you which have a legal effect or other similarly significant effect (as described directly above) you have the right to ask us to have a human review the automated decision and to contest our decision. 

In order to exercise any of these rights please notify us in writing to the Customer Services Department at Honda Financial Services, Cain Road, Bracknell, RG12 1HL or by telephoning the same department on 0345 128 8908 or by email at hfe.customerservice@honda-eu.com  

You also have the right to lodge a complaint with the Information Commissioner’s Office, which is the UK data protection regulator. More information can be found on the Information Commissioner’s Office website at https://ico.org.uk/.

Choice / opt-in and opt-out

You will be given the opportunity to opt-in or opt-out to having your contact details used for direct marketing purposes. 

If you do want us to use your data for direct marketing, or to pass your details on to third parties for marketing purposes, you can tick the relevant boxes situated on the marketing consent form on which we collect your data

If you no longer wish to receive email or other promotional materials from us, you may opt-out of receiving these communications at any time by one of the following methods: 

• by selecting the unsubscribe option available in each marketing email
• by writing to us at the Customer Services Department at Honda Financial Services, Cain Road, Bracknell, RG12 1HL
• by telephoning the same department on 0345 128 8908 or by email at hfe.customerservice@honda-eu.com

Fake emails using Honda’s name

Honda Financial Services is aware of fake emails, popularly called “phishing” emails which can contain notices such as job advertisements, job offers and competition award notifications. These emails use Honda’s name to pretend they are genuine and exist solely for the purpose of obtaining private information about consumers (e.g. credit card numbers or passwords). These emails have no connection with Honda and Honda does not use these methods for job advertising or for communicating with competition winners.

Unfortunately these fake emails are a growing fraud on the internet. This practice is carried out either by the sending of a bogus email directly to a victim, or by directing them to a website where personal information is requested.

Fake job offers tend to target overseas individuals, as they ask for money to be sent to them for UK visa purposes. Honda never requests payments details in association with any job applications or any communication related to them. If in any doubt about the validity of a recruitment offer, please contact: Human Resources, Honda (UK), Cain Road, Bracknell, RG12 1HL. 

Recent email award notifications have purported to be from Honda. Honda never requests payment details in association with competition winners or any communication related to them.

Honda advises that if you receive an email using Honda’s name that asks for personal information or financial information and you have concerns about its authenticity, then please treat such emails with extreme caution.

Correcting / updating / accessing personal information

If your personal information changes (such as post code, email address, etc.), or if we have inaccurate information, we will endeavour to correct, update or remove your personal information from our database. To notify us of a change or inaccuracy, you can advise us by writing to us at the Customer Services Department at Honda Financial Services, Cain Road, Bracknell, RG12 1HL or by telephoning the same department on 0345 128 8908 or by email at hfe.customerservice@honda-eu.com

Updates to this notice

We may update this notice from time to time to reflect changes to the type of personal data that we process and/or the way in which it is processed. We will update you on material changes to this notice by email. We also encourage you to check this notice on a regular basis.

Where can you find out more?

If you want more information about any of the subjects covered in this privacy notice or if you would like to discuss any issues or concerns with us, you can contact us in any of the following ways:

• By email at: hfe.customerservice@honda-eu.com
• By telephone at: 0345 128 8908
• By post at: Customer Services Department at Honda Financial Services, Cain Road, Bracknell, RG12 1HL