1. Who are we and how do you contact us?

Gendan Limited and our Data Protection Officer

We're Gendan Limited, Great Southgate Farm, Southgate, Swansea. SA3 2BT. We are a data controller of your personal data.

We have a dedicated data protection officer ("DPO"). You can contact the DPO using the details below or by writing to the above address, marking it for the attention of the DPO or going to Contact Us.

2. What kinds of personal information about you do we process?

Personal information that we'll process in connection with all of our products and services, if relevant, includes:

• Personal and contact details, such as title, full name, postal address, contact details and contact details history
• Your date of birth, gender and/or age
• Your nationality, if needed for the product or service
• Records of your contact with us such as via the phone number and, if you get in touch with us online using our online services, email address, IP address and MAC address
• Products and services you hold with us, as well as have been interested in and have held and the associated payment methods used
• The usage of our products and services, any support calls, online support enquiries (and details related to this)
• Marketing to you and analysing data, including history of those communications, whether you open them or click on links, and information about products or services we think you may be interested in, and analysing data to help target offers to you that we think are of interest or relevance to you. Offers may include any of our products and services
• Vehicle information, such as make and model, faults and repairs
• Information about your use of products
• Information we obtained from third parties, including information about instances of suspect fraud
• Personal information which we obtain from Credit Reference Agencies and Fraud Prevention Agencies including public (for example, defaults, CCJs) and shared credit history, financial situation and financial history
• Fraud, debt and theft information, including details of money you owe, suspected instances of fraud or theft, and details of any devices used for fraud
• Information we buy or rent from third parties, including demographic information, vehicle details, details of outstanding finance, marketing lists, publicly available information, and information to help improve the relevance of our products and services
• Insights about you and our customers gained from analysis or profiling of customers
• Tax information, if relevant (for example, for purposes of VAT and taxation)

3. What is the source of your personal information?

We'll collect personal information from the following general sources:

• From you directly
• Information generated about you when you use our products and services
• From other sources such as Fraud Prevention Agencies, Credit Reference Agencies, other lenders, HMRC, DWP, publically available directories and information (for example, telephone directory, social media, internet, news articles), debt recovery and/or tracing agents, other organisations to assist in prevention and detection of crime, police and law enforcement agencies
• We may buy or rent information about you or customers generally from third parties including demographic information, vehicle details, claims history, fraud information, marketing lists, publicly available information and other information to help improve our products and services or our business

4. What do we use your personal data for?

We may use your personal data, including any of the personal data listed in section 1 above, for the following purposes:

• Assessing an order for a product or service, including considering whether or not to offer you the product or service, the risk of doing so, availability of payment method and the terms
• Managing products and services relating to that product or service, or order for one
• Updating your records, tracing your whereabouts and recovering debt
• Managing any aspect of the product or service
• To perform and/or test the performance of, our products, services and internal processes
• To improve the operation of our business
• To follow guidance and best practice under the change to rules of governmental and regulatory bodies
• For management and auditing of our business operations including accounting
• To carry out checks at Credit Reference and Fraud Prevention Agencies pre-order, at order, and periodically after that
• To monitor and to keep records of our communications with you and our staff (see below)
• To administer our good governance requirements, such as internal reporting and compliance obligations
• For market research and analysis and developing statistics
• Assessing and profiling aspects of your vehicle (including faults) and location (if relevant to your product or service)
• For direct marketing communications and related profiling to help us to offer you relevant products and service, including deciding whether or not to offer you certain products and service. We'll send marketing to you by email, post, social media and digital channels (for example, using Facebook Custom Audiences). Offers may relate to any of our products and services and advice we think may be of interest
• To provide personalised content and services to you, such as tailoring our products and services, our digital customer experience and offerings, and deciding which offers or promotions to show you on our digital channels
• To develop new products and services and to review and improve current products and services
• To comply with legal and regulatory obligations, requirements and guidance
• To provide insight and analysis of our customers both for ourselves either as part of providing products or services, helping us improve products or services, or to assess or improve the operating of our business

5. What are the legal grounds for our processing of your personal information (including when we share it with others)?

We rely on the following legal bases to use your personal data:

1. Where it is needed to provide you with our products or services, such as:

a) Assessing an order for a product or service you hold with us, including consider whether or not to offer you the product, the price, the payment methods available and the conditions to attach
b) Managing and supporting products and services you have previously ordered from us
c) Updating your records, tracing your whereabouts to contact you about your account and doing this for recovering debt (where appropriate)
d) Sharing your personal information with business partners and services providers, such as delivery companies (for example Royal Mail and DHL) when you purchase a product
e) All stages and activities relevant to managing the product or service including enquiry, order, administration and management of accounts



2. Where it is in our legitimate interests to do so, such as:

a) Managing your products and services relating to that, updating your records to contact you about your account and doing this for recovering debt (where appropriate)
b) To perform and/or test the performance of, our products, services and internal processes
c) To follow guidance and recommended best practice of government and regulatory bodies
d) For management and audit of our business operations including accounting
e) To carry out searches at Credit Reference Agencies pre-order, at the order stage, and periodically after that
f) To carry out monitoring and to keep records of our communications with you and our staff (see below)
g) To administer our good governance requirements, such as internal reporting and compliance obligations
h) For market research and analysis and developing statistics
i) For direct marketing communications and related profiling to help us to offer you relevant products and services, including deciding whether or not to offer you certain products and service. We will send marketing to you by email, post, social media and digital channels (for example, using Facebook Custom Audiences)
j) Subject to the appropriate controls, to provide insight and analysis of our customers either as part of providing products or services, helping us improve products or services, or to assess or to improve the operating of our business
k) Where we need to share your personal information with people or organisations in order to run our business or comply with any legal and/or regulatory obligations

3. To comply with our legal obligations
4. With your consent or explicit consent, for some direct marketing communications

6. When do we share your personal information with other organisations?

We may share information with the following third parties for the purposes listed above:

• Governmental and regulatory bodies such as HMRC, the Financial Conduct Authority, the Ombudsman, the Information Commissioner's Office and under the Financial Services Compensation Scheme
• Other organisations and businesses who provide services to us such as debt recovery agencies, back up and server hosting providers, IT software and maintenance providers, document storage providers and suppliers of other back office functions
• Courier companies who need your name, address and contact information to deliver or collect goods ordered or returned
• Credit Reference and Fraud Prevention Agencies

7. How and when can you withdraw your consent?

Where we're relying upon your consent to process personal data, you can withdraw this at any time by contacting us using the details below.

8. Is your personal information transferred outside the UK or the EEA?

We're based in the UK but in the unlikely event that your personal information needs be transferred outside the European Economic Area, we'll make sure that suitable safeguards are in place, for example by using approved contractual agreements, unless certain exceptions apply.

9. What should you do if your personal information changes?

You should tell us so that we can update our records using the details in the Contact Us section of our website. We'll then update your records if we can.

10. Do you have to provide your personal information to us?

We're unable to provide you with our products or services if you do not provide certain information to us. In cases where providing some personal information is optional, we'll make this clear.

11. Do we do any monitoring involving processing of your personal information?

In this section monitoring means any: listening to, recording of, viewing of, intercepting of, or taking and keeping records (as the case may be) of calls, email, text messages, social media messages, in person (face to face) meetings and other communications.

We may monitor where permitted by law and we'll do this where the law requires it, or to comply with regulatory rules, to prevent or detect crime, in the interests of protecting the security of our communications systems and procedures and for quality control and staff training purposes. This information may be shared for the purposes described above.

12. For how long is your personal information retained by us?

Unless we explain otherwise to you, we'll hold your personal information based on the following criteria:

• For as long as we have reasonable business needs, such as managing our relationship with you and managing our operations
• For as long as we provide goods and/or services to you and then for as long as someone could bring a claim against us; and/or
• Retention periods in line with legal and regulatory requirements or guidance.

13. What are your rights under data protection laws?

Here is a list of the rights that all individuals have under data protection laws. They don't apply in all circumstances. If you wish to use any of them, we'll explain at that time if they are engaged or not. The right of data portability is only relevant from May 2018.

• The right to be informed about the processing of your personal information
• The right to have your personal information corrected if it is inaccurate and to have incomplete personal information completed
• The right to object to processing of your personal information
• The right to restrict processing of your personal information
• The right to have your personal information erased (the "right to be forgotten")
• The right to request access to your personal information and to obtain information about how we process it
• The right to move, copy or transfer your personal information ("data portability")
• Rights in relation to automated decision making which has a legal effect or otherwise significantly affects you

You have the right to complain to the Information Commissioner's Office which enforces data protection laws: https://ico.org.uk/. You can contact us using the details below.

14. Your right to object

You have the right to object to certain purposes for processing, in particular to data processed for direct marketing purposes and to data processed for certain reasons based on our legitimate interests. You can contact us by going to the Contact Us section of our website to exercise these rights.

15. What are your marketing preferences and what do they mean?

We may use your home address, email address and social media or digital channels (for example, Facebook, Google and message facilities in other platforms) to contact you according to your marketing preferences. You can stop our marketing at any time by contacting us using the details below or by following the instructions in the communication.