Privacy Policy

VWFS is committed to protecting and respecting any personal information you share with us. This policy describes what types of information we collect from you, how it is used by us, how we share it with others, how you can manage the information we hold and how you can contact us. For data protection purposes, the data controller is Volkswagen Financial Services (UK) Limited whose registered office is stated above.

This policy is supplemental to the data protection privacy notice provided to you before your application was submitted.

Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it. By visiting this website you are accepting and consenting to the practices described in this policy.

We will always give you the option to opt out of receiving marketing communications from us. We will never send you unsolicited ‘junk’ email or communications, or share your data with anyone else who might. We do not sell your information to third parties, but we do work closely with our Group companies, companies that provide services to us and our franchised retailers (known collectively as our selected third parties) who help us to provide you with the information, products and services that you request from us.

Our site may, from time to time, contain links to and from the websites of these selected third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.

The contents of this policy may change from time to time so you may wish to check this page occasionally to ensure you are still happy to share your information with us. Where possible, we may also contact you directly to notify you of these changes.

This version of our Privacy Policy is live from May 2018.

What information do we collect?

The information we collect includes some or all of the following:

  1. Full name (including title);
  2. Address;
  3. Phone number;
  4. Date of birth;
  5. Email address;
  6. Driving Licence details;
  7. Vehicle information (including registration number, VIN, service reminders, mileage and warranty repair information);
  8. The date and time you used our services;
  9. The pages you visited on our website and how long you visited us for;
  10. Device identifiers such as your IP address;
  11. Your GPS location (where you have permitted access to this);
  12. The internet browser and devices you are using;
  13. Cookie, Pixels or Beacon information (for more information please see our Cookie Policy);
  14. The website address from which you accessed our website;
  15. Start and end of any insurance and/or warranty policy;
  16. Details of any transactions between you and us or any franchised retailer;
  17. Where you engage with us in a business context, we may collect your job title, company contact details (including email addresses), fleet size and company details (some of which we may obtain from an online or public business directories);
  18. Voice recordings of calls you make to our customer service centre;
  19. “Live chat” records;
  20. Any information within correspondence you send to us;
  21. Credit Reference Data;
  22. Financial and employment details;
  23. Banking and credit card details; and
  24. Documentation relating to your identification.

We only collect information which is necessary, relevant and adequate for the purpose you are providing it for. For car insurance this may include the following types of sensitive personal data:-

  1. Notifiable Medical Conditions relevant to driving as required by the DVLA;
  2. Convictions including motoring convictions (spent and unspent);

How is your personal information collected?

We may collect information about you (and/or your vehicle) from:

  • you, including if you contact us (including any email address, Internet Protocol (IP) address or telephone number supplied by your electronic service provider) or if you use our products or services, or engage with our website or other online applications;
  • third parties, such as underwriters and administrators (“insurance partners”) of our white label insurance and warranty products, they will give us information about you, such as your claims history and any complaint information, (for a more detailed list of the entities we receive your data from please see ‘Parties we receive data from per product’ below);
  • our franchised retailers or repairers (some of this information does not identify you personally, but provides us with information about how you use our services and engage with us and we use this information to improve our services and make them more useful to you); and/or
  • other companies who provide services to us and/or that we provide services for.

We may also collect information about you (and/or your vehicle) when you use:

  • VWFS’ websites and applications. This online information includes some or all of the following:
  • information you provide when you register to use the sites, browse content on the sites or use other functionality;
  • details of your visits to the sites including, but not limited to traffic data, location data and other communication data, and the resources that you access; and/or
  • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform (please see further our Cookies Policy);

Some of the information that we obtain about you or your vehicle from our franchised retailers, and insurance partners does not identify you personally, but provides us with information about how they are handling any claims or complaints you make to them and the services you receive (we use this information to improve our services and monitor our service providers).

Parties we receive data from per product

Car Insurance

  • U K Insurance Limited (Underwriter and Administrator) for policies first taken from April 2018
  • Ageas Retail Limited (Administrator) for policies first taken between April 2015 and March 2018  
  • Allianz Insurance plc (Underwriter and Administrator) for policies first taken between December 2009 and April 2015 (and renewed before 1st October 2017)
  • Allianz Insurance plc (Underwriter) and Allianz Business Services Limited (Administrator) policies first taken between December 2009 and April 2015 (and renewed from 1st October 2017)
  • Carrot Risk Technologies Limited (Administrator) for one year's insurance at no extra cost taken from April 2016 (and renewed from April 2017)

Gap Insurance

  • MAPFRE Asistencia Compañìa Internacional de Seguros y Reaseguros Sociedad Anonima (“MAPFRE”) (Underwriter)
  • Abraxas Insurance Administration Services Limited (Administrator on behalf of MAPFRE)

Extended Warranty

  • Lawshield UK Limited (Administrator on behalf of Volkswagen Financial Services (UK) Limited)
  • Volkswagen Versicherung AG (Underwriter)

Ensurance

  • Lawshield UK Limited (Administrator)
  • UK General Insurance Limited (Underwriter on behalf of Great Lakes Insurance SE)

Approved Used Warranty

  • Volkswagen Financial Services (UK) Limited (Administrator on behalf of Volkswagen Group United Kingdom Limited)
  • Opteven Services S.A. (Administrator on behalf of Volkswagen Financial Services (UK) Limited)
  • MOT and Key Cover element (where applicable) –
    • Lawshield (UK) Limited (Administrator)
    • UK General Insurance Limited (Underwriter on behalf of Great Lakes Insurance SE)

Approved Used Warranty (for non VW, SEAT, ŠKODA, Audi and VWCV vehicles)

  • Lawshield UK Limited (Administrator on behalf of Volkswagen Financial Services (UK) Limited)
  • Volkswagen Versicherung AG (Underwriter) (see also ‘When might we share your personal information with other entities in the Group?’)
  • MOT and Key Cover element (where applicable) –
    • Lawshield (UK) Limited (Administrator)
    • UK General Insurance Limited (Underwriter on behalf of Great Lakes Insurance SE)

MOT Cover

  • Lawshield UK Limited (Administrator)
  • UK General Insurance Limited (Underwriter on behalf of Great Lakes Insurance SE)

How do we use your information?

VWFS will only process information that is necessary for the purpose for which it has been collected. You will always have the option to opt out of receiving marketing communications from us and you can withdraw your consent or object at any time. We will never send you unsolicited ‘junk’ email or communications, or share your personal information with anyone else who might.

There are various ways in which we may use or process your personal information.  We list these below:

Consent:

Where you have provided your consent, we may use and process your information to contact you from time to time about promotions, events, products, services or information which we think may be of interest to you.

You can withdraw your consent at any time by contacting us on the details stated in the section below titled ‘How can you manage the information we hold about you?’ or, in relation to any marketing messages you receive, by using the unsubscribe option included in those messages.

Contractual performance

We may use and process your personal information where this is necessary to perform a contract with you, for example, if you are an insurance and/or warranty customer, to enable us to manage your account, including responding to your enquiries and complaints.

Legitimate Interests

We may use and process your personal information as set out below where it is necessary for us to carry out activities for which it is in our legitimate interests as a business to do so.

We may also contact you from time to time about promotions, events, products, services or information which we think may be of interest to you.

Processing necessary for us to support customers with enquiries

  1. To respond to correspondence you send to us and fulfil the requests you make to us (for example, with regards to your agreement or account with us);
  2. To provide vehicle support and services (for example, with regards to maintenance or insurance);

Processing necessary for us to respond to understanding customers’ needs

  1. To analyse, evaluate and improve our products and services so that your visit and use of our website, applications, customer service centre and dealer network are more useful and enjoyable (we will generally use data gathered from many people so that it doesn’t identify you personally);
  2. To undertake market analysis and research (including contacting you with customer surveys) so that we can better understand you as a customer and provide tailored offers, products and services that we think you will be interested in. We will only send marketing communications to you if you have provided your consent for us to do so or which we have obtained in the ways mentioned in the paragraphs below;
  3. For product development purposes (for example to provide new products or services);

Processing necessary for us to promote our business, brands and products and measure the reach and effectiveness of our campaigns

  1. To provide you with marketing information from time to time after you have purchased a product or service from us or made a purchasing enquiry or closed your browser without finalising a purchase . We will only contact you with information about our own products and services (and in ways the law allows), which we hope you will like. You have the right to object to us sending you this information at any time;
  2. To contact you from time to time with marketing information (unless you object) if you have expressly indicated to us that you are acting on behalf of a business or where we have obtained your business contact details from our authorised dealer network or an online or public business directory. In relation to any such information we send by email or SMS, we will include an option allowing you to object to receiving future messages by unsubscribing;
  3. To contact you with targeted advertising delivered online through social media and other platforms operated by other companies, unless you object. You may receive advertising based on information about you that we have provided to the platform or because, at our request, the platform has identified you as having similar attributes to the individuals whose details it has received from us. To find out more, please refer to the information provided in the help pages of the platforms on which you receive advertising from us;
  4. To identify and record when you have received, opened or engaged with our website or electronic communications (please see our Cookie Policy for more information);
  5. To obtain analytics including those received from search engine providers that assist us in the improvement and optimisation of the site;

Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively

  1. To verify the accuracy of information that we hold about you and create a better understanding of you as a customer;
  2. For network and information security purposes i.e. in order for us to take steps to protect your information against loss, damage, theft or unauthorised access;
  3. To comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);
  4. To inform you of updates to our terms and conditions and policies, where possible;

Processing necessary for us to fulfil our legal obligations

  1. To comply with our obligations before we provide insurance, goods or services to you as both a responsible business and FCA authorised firm, such as assessing product suitability, managing your account.
  2. To prevent fraud and money laundering, and to verify identity before we provide services, insurance and/or warranty to you;
  3. To enable us to assess fraud or money laundering risk by automated means, which may indicate that you pose a risk or if our processing reveals your behaviour to be consistent with that of known fraudsters or money launderers; or is inconsistent with your previous submissions; or you appear to have deliberately hidden your true identity. You have rights in relation to automated decision making: if you want to know more please contact the Data Protection Officer using the details below; and/or
  4. To comply with other legal requirements.

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Why might we share your personal information with third parties?

We do not sell your information to third parties but we do work closely with our franchised retailers and third party insurance partners and service providers who fulfil business activities for us (like the AA for roadside assistance, marketing, events and market research etc.) In addition, we may have a legal or other obligation to share your personal information.

Which third parties may process your personal information?

From time to time, we may disclose your information to companies or organisations:

  • where the law says we may or must do so;
  • where we have ongoing reporting obligations;
  • to comply with our ongoing obligations to prevent fraud and money laundering by allowing law enforcement and fraud prevention agencies to access and use your personal information to detect, investigate and prevent crime;
  • to companies that provide services to us so we can perform activities relating to your contract and/or to enforce any contract we have with you and/or to protect our rights and/or property;
  • to our franchised retailers to provide you with information about your application and our products and services or to manage any request or complaint you have made to us; or
  • to our advisors, and investors and their advisors for corporate finance purposes, for example, in the event that we sell or buy any business or assets, or if VWFS or substantially all of its assets are acquired by a third party.

When might we share your personal information with other entities in the Group?

There are circumstances where we share your information with our parent company (or other companies within our Group) in order to fulfil orders, transactions, handle complaints or provide you with a service or information that you have requested or for audit, statistical analysis, risk management and product and service development purposes and to comply with legal requirements.  For example we will share information with branded trading divisions of Volkswagen Group United Kingdom Limited where you enquire about their services through us or where you make a complaint to us and later make the same or similar complaint to them. Volkswagen Group United Kingdom Limited may use your information to provide you with information and carry out their obligations arising from contracts you enter into with them.  For more information, please visit the brand’s website and/or the Privacy Statement available at www.audi.co.uk

For Extended Warranty we will share your personal information with Volkswagen Versicherung AG (the Underwriter) for the purposes of providing the insurance product to you. For more information on how Volkswagen Versicherung AG use and store your information please refer to their privacy policy:

How secure is your information with third-party service providers and other entities in our Group?

We take steps to ensure that any third party partners who handle your information comply with data protection legislation and protect your information just as we do. We only disclose personal information that is necessary for them to provide the service that they are undertaking on our behalf. We will aim to anonymise your information or use aggregated none specific data sets wherever possible.

Due to the international nature of our business, there may be some instances where your information is processed or stored outside of the EU.  In those instances, we will ensure that appropriate safeguards are in place for that transfer and storage as required by applicable law.  

In addition, whenever fraud prevention agencies transfer your personal information outside of the European Economic Area, they impose contractual obligations on the recipients of that data to protect your personal information to the standard required in the European Economic Area. They may also require the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing.

How do we keep your information secure?

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from the Data Protection Officer (please see contact details below).

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

Finally, we have established procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

How long do we keep your information for?

We do not retain personal information in an identifiable format for longer than is necessary.

If we have a relationship with you (e.g. you are a customer), we hold your personal information for 6 years from the date our relationship ends. We hold your personal information for this period to establish, bring or defend legal claims. Our relationship may end for a number of reasons including where the contract of insurance expires.

The only exceptions to the periods mentioned above are where:

  • the law requires us to hold your personal information for a longer period, or delete it sooner;
  • you have raised a complaint or concern regarding a product or service offered by us, in which case we will retain your information for a period of 6 years following the date of that complaint or query; or
  • you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law (see further ‘How can you manage the information we hold about you’);

In addition, fraud prevention agencies can hold your personal information for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.

How can you manage the information we hold about you?

You have the right as an individual to access the personal information that we hold about you and make corrections if necessary. You also have the right to withdraw any consent you have previously given us and ask us to erase information we hold about you. You can also object to our use of your personal information (where we rely on our business interests to process and use your personal information).

You have a number of rights in relation to your personal information under data protection law. In relation to most rights, we will ask you for information to confirm your identity and, where applicable, to help us search for your personal information. We will respond to you within 30 days (unless there are exceptional circumstances) after we have received any request (including any identification documents requested).

You have the right to:

  1. Ask for a copy of the information that we hold about you;
  2. Correct and update your information;
  3. Withdraw your consent (where we rely on it). Please see further ‘How do we use your information?’
  4. Object to our use of your information (where we rely on our legitimate interests to use your personal information) provided we do not have any continuing lawful reason to continue to use and process the information. When we do rely on our legitimate interests to use your personal information for direct marketing, we will always comply with your right to object;
  5. Erase your information (or restrict the use of it), provided we do not have any continuing lawful reason to continue to use and process that information; and/or
  6. Transfer your information in a structured data file (in a commonly used and machine readable format), where we rely on your consent to use and process your personal information or need to process it in connection with your contract.

You can exercise the above rights and/or manage your information by contacting us using the details below:

Post: Volkswagen Financial Services (UK) Limited, One Delaware Drive, Tongwell, Milton Keynes MK15 8HG

Email: DPO@vwfs.co.uk

Who can you contact if you have a question or a complaint?

If you have any specific data protection concerns or a complaint, you can address it to our Data Protection Team at DPO@vwfs.co.uk

You also have the right to lodge a complaint with a data protection regulator in Europe, in particular in a country you work or live or where your legal rights have been infringed. The contact details for the Information Commissioner’s Office, the data protection regulator in the UK, are below:

Post:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Call: 0303 123 1113

Email: casework@ico.org.uk