Willow Leasing Limited T/A Willow Leasing (hereinafter referred to as Willow Leasing, we or us) is a UK-registered company that provides UK organisations with credit broking services, in both the public and private sectors, with a range of specialist financial services centred around asset leasing, supporting thousands of partners and customers ranging from sole traders, partnerships, small SMEs to large, global corporates. We have direct servicing support to a number of specific partner channels, Technology, Interiors, Vehicles, Health & Fitness and General Assets. In addition, we also have a direct business-to-customer relationship, specifically with those customers who were originally introduced via a business partner. We do not otherwise trade directly with end business users.
Willow Leasing is authorised and regulated by the Financial Conduct Authority and registered with the Information Commissioner’s Office under number ZA483132.
This notice explains what personal data we collect from you and how it will be used by us and why.
Before we provide services, goods or credit broking to you, we will need to collect certain details from you for the purpose of entering into an agreement with you for providing goods (for example, a sale agreement), services (for example, a rental agreement), or credit broking; administering any agreement with you; and in order to undertake checks for the purposes of preventing money laundering or to verify your identity; and if you access our website we collect information about your browsing experience, for the purposes of understanding and improving our website, customer experience and our products and services.
We will collect and process the following personal data about you:
Information you give us when purchasing or making an application for finance (Submitted Information): The information you give us comprises your name, date of birth, residential address and address history for the last five years, contact details such as email address and telephone numbers, financial information and employment details or company information. Financial and employment details may include, but not be limited to, your business accounts, bank statements, your salary, P60, wage slips, employer’s name, address and time you have worked there. Additionally, you may be required to provide further information for your application as proof of identification. These may include but are not limited to, a passport, driving licence and utility bills.
Information we receive about you from third parties (Third Party Information): This information may include your personal and financial information, your employer, companies that you are connected with (such as a Director) or other persons connected with your finance application; information about the asset you are purchasing or finance you require; credit information, such as previous applications, the conduct of accounts in your and your financial associate’s name (this is anyone linked to you for credit or finance purposes), any business accounts you have and public information such as County Court Judgments, bankruptcies and the Electoral Register.
We may combine Submitted Information with Third Party Information and may use both these categories of information and the combined information for the purposes set out below.
Account processing and administration
Sale or Supply Agreement Administration: this will mean verifying identity; customer services; investigating and responding to a complaint; complying with legal, regulatory and compliance obligations that apply to us (for example, anti-money laundering and counter-terrorism checks) and detection and prevention of fraud and other crimes; account management; call monitoring;
General Administration: which will mean tax administration; auditing; reporting and accounting functions; statistical analysis and market research; market, regulatory and operational risk management; systems testing; network monitoring.
Marketing Activities: which may mean conducting customer service surveys and offering goods and services such as alternative products; profiling of your data for marketing purposes; contacting you to offer you other products and services; analysis of our customer database to understand our customer’s activities and preferences, and to improve our services to you.
Commercial Activities: which will mean assigning our rights or obligations to a third party; obtaining funding for our business, and understanding and improving our products and services, (and when we use your data for each of these purposes we do so on the basis that we have a legitimate interest in doing so).
When you phone us or we phone you: call recording and customer identification
We will also use your personal data to check your identity if you get in touch with us.
We may monitor, and record calls made to us for monitoring and training purposes and to improve the services we offer.
We use your information in this way in our legitimate interest, to improve the services, we provide to you.
Verifying your identity and preventing fraud and money laundering
We will use certain personal data you have provided to us in order to confirm your identity and prevent money laundering. More details about these checks are set out below.
Legal Basis for Processing Data: When we use your personal data for these purposes we do so on the basis that we have a legitimate interest in assessing your application, preventing fraud and money laundering, and verifying identity, in order to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the services you have requested, and we will not be able to process your application without undertaking these checks. However, we may also process your data when it will be in your vital interests for us to do so, when it is in the public’s interest for us to do so, or when we are compelled to do so by law.
As part of your original finance application, the lender will collect its own data in order to assess your application. However, should your application with one of our selected lenders be unsuccessful we may pass your application details to another finance company to help fulfil your lending requirement.
That company will obtain their own credit reference and fraud prevention searches. We may from time to time add & remove lenders from our panel and we will always let you know if we pass your data to a lender, not on our usual panel.
We, as the introducing broker, will have access to your information up to the point that your finance agreement is executed with the finance company, to facilitate your application for finance. However, we may also gain access to your information after the execution of any finance agreement to assist in a regulatory or servicing requirement, such as complaints handling and settlement values for any finance agreement arranged through us for you.
If you decide to proceed with an application with us, we will use your information to obtain credit and identity checks on you with one or more credit reference agencies ("CRAs").
To do this, we or the financiers to whom we send your application (together "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:
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 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 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 any of these three links: www.callcredit.co.uk/crain; www.equifax.co.uk/crain; www.experian.co.uk/crain
All personal data you provide to us, or which we obtain from third parties, will be stored on our secure servers (or those of third parties or contractors we engage to help us run our business). All these servers are located within the UK and we will never transfer your data outside of the UK without first obtaining your express consent.
We will keep information no longer than we need to for the purpose for which we collected it. The period for which we keep personal data depends on our various legal and regulatory requirements, the purpose for which the information was obtained, and our business needs. If you have any questions about this privacy notice or how we use your personal data, please contact us via email@example.com
We will keep information about any account you hold with us for at least a period of 6 years from the end of any Agreement, in line with our data retention policy that stipulates the timescales in line with our lawful purpose for processing your data. For applications which do not result in an Agreement we normally retain information for a period of 12 months.
To enable us to provide our products & services to you, we may share your personal data with other companies in our group or with other third parties acting on our behalf, such as finance companies to whom we apply for finance on your behalf. This may be necessary for administrative processing purposes or for the operation and maintenance of your business with us. These include but are not limited to our service, system, support and outsourcing providers; retailers/dealers and manufacturers of goods relating to your agreement; regulatory bodies, and law enforcement agencies.
A full list of the firms we share your data with can be made available upon request. We may also share your personal data with any person (and their or our professional advisors for this purpose) with whom we are negotiating any sale, transfer or re-organisation of our business or where we are organising our commercial funding. If this proceeds, the acquiring party or part of it may use your personal details in the same ways and for the same purposes as set out in this policy. We will give you their details once any business change has been completed.
We may also share your data with any other third party when so doing is in your vital interests, in the public’s interest or when we are compelled to do so by law.
You have a right to object to our processing of your information on grounds relating to your particular situation.
You also have the right, at any time, to stop us from contacting you or processing your information for marketing purposes.
You have the following additional rights (subject to certain statutory exemptions):
If you are unhappy about how your personal data has been used, you can contact us using the details above. You also have a right to complain to the Information Commissioner’s Office (ICO), which regulates the processing of personal data.
You can refer your concerns to the ICO by:
If you would like more information about how we process personal data or are unable to access any of the links or further information referred to in this document; or would like to exercise any of your data protection rights; then please contact us using the contact details set out in this notice.