WHO WE ARE
“Creative” is a trading style of Creative Funding Solutions Limited, a commercial finance broker based in Crawley, West Sussex. We act as a credit broker and not a lender. Our trading styles include commercialvehicle.finance, cab.finance, fastcar.finance, hardasset.finance, horsebox.finance, lorry.finance, motorhome.finance, racingfinance.co.uk, towtruck.finance, caravans.finance, parkhomes.finance, leisurevehiclefinance.co.uk, Ambulance Trader, Hire Company Finance and Business Funding Solutions.
Creative Funding Solutions Limited is authorised and regulated by the Financial Conduct Authority (Firm Reference No. 631176) and is registered with the Information Commissioner’s Office (Reference No. Z1809054). For the purposes of UK data protection law, we are the data controller of your personal data, and we are committed to processing it in accordance with UK data protection laws.
This notice explains how we collect, use, share and protect your personal data – that is, any information that directly or indirectly identifies you.
How to contact us
Data Protection contact: Tony Smith
Head office: Ground Floor, Unit 3, Amberley Court, Whitworth Road, County Oak Way, Crawley, West Sussex, RH11 7XL
Registered office: Amelia House, Crescent Road, Worthing, BN11 1QR
Email: info@creativefs.co.uk
Telephone: 01293 127377 / 0330 223 1261
OUR LAWFUL BASES FOR HOLDING YOUR DATA
We will only use your personal data where the law allows us to. We rely on the following lawful bases:
• Performance of a contract – to take steps at your request before entering into, and to perform, a contract with you.
• Compliance with legal obligations – to meet our obligations under legislation such as financial crime and anti-money laundering law.
• Legitimate interests – our genuine business and commercial reasons for using your data, where these are not overridden by your interests, rights or freedoms (see “Legitimate Business Purposes” below).
• Consent – where we ask for it, for example to process special category data. You can withdraw consent at any time, and we will stop processing unless we have another lawful basis to continue.
WHAT DATA WE COLLECT
We collect personal data directly from you, automatically when you use our services, and from third parties. Depending on your application, this may include:
• Identity and contact details – name, date of birth, address and address history, email, telephone numbers, IP address, and proof of identity and address.
• Financial information – income, expenditure, bank account details, assets and liabilities, existing loans, credit history and credit profile, and transaction and repayment history.
• Application and asset details – the product and term you want, the asset to be financed (e.g. make, model, VIN, registration), home ownership status, reason for borrowing, employment status and any other business interests.
• Eligibility and household details – nationality and right to reside (where needed for legal/regulatory reasons), marital status, dependants, and guarantor details where relevant.
• Communications and usage data – records of letters, emails, texts, chat and call recordings, survey responses, reviews, and website/app usage gathered through cookies and similar technologies.
• Consent and preference records – your marketing and communication preferences and records of the consents you have given.
In some cases we may ask for medical information or a statement of financial worth signed by an independent qualified accountant.
We will explain why at the time and ask for your consent.
Where we collect your data from
• Directly from you – online, by phone, in writing, in person, through reviews, and when you provide documents.
• Credit reference agencies (typically Experian, Equifax, Creditsafe or TransUnion) and fraud prevention agencies.
• Parties who introduce you to us, such as brokers, suppliers, dealers, financial advisers and finance providers.
• Publicly available sources – e.g. Companies House, the Land Registry, the electoral register, online and social media.
• Your representatives, employers and, where relevant, medical sources.
SPECIAL CATEGORY DATA
During your dealings with us you may share “special category data” – information about your race or ethnic origin, politics, religion, trade union membership, genetics, biometrics, health, sex life or sexual orientation.
Where you share such information – for example about your health or an indicator of vulnerability – we will only store or process it where there is a lawful basis to do so. Where it is not necessary to process your application, we will not store, retain or process it.
Criminal convictions and offences. We may record information about criminal convictions or offences where it relates to money laundering or fraud, or where it may pose a reputational risk to a lender. We process this information only where the law allows us to do so, for the purposes of fraud prevention, anti-money laundering and protecting ourselves and our lenders from financial crime and reputational harm.
Recording indicators of vulnerability
In line with the FCA’s Consumer Duty and our commitment to good customer outcomes, we want finance to be accessible to everyone, including customers in vulnerable circumstances. To support this, we may need to record indicators of vulnerability and, where it helps secure a suitable outcome, share them with prospective and actual lenders.
Indicators of vulnerability may involve special category data (such as physical or mental health) or other circumstances (such as a recent bereavement, financial difficulty, a serious life event, caring responsibilities or low financial resilience). Recording and sharing this information allows us and our lenders to provide extra support, make reasonable adjustments, and make fairer, better-informed lending decisions – improving access to finance for vulnerable customers and helping ensure any product offered is suitable for you.
Your explicit consent. By signing this privacy notice you give your explicit consent for us to record indicators of vulnerability (including any related special category data) and to pass them on to prospective and actual lenders, and where relevant to others involved in your application, for the purposes above. This consent is given on a general basis and covers the recording and sharing of such information throughout your application and any resulting agreement.
Your choice. Giving this consent is voluntary. You can decline, or withdraw it at any time by contacting us. If you do, we will stop recording and sharing this information, although this may limit our ability to arrange additional support or access certain products designed to help vulnerable customers. Withdrawing consent does not affect processing carried out beforehand.
LEGITIMATE BUSINESS PURPOSES
One of our lawful bases is our legitimate interests (our legitimate business purposes). This means we may use your data where it is reasonably necessary for our genuine business and commercial interests, provided we have balanced those interests against your rights and concluded they are not overridden. We will not use your data this way where it would be unfair to you or cause unwarranted harm, and you can object to this processing (see “Your Data Protection Rights”).
Examples of our legitimate business purposes
• Assessing your creditworthiness, affordability and financial stability to broker suitable finance.
• Preventing, detecting and investigating fraud, financial crime and money laundering, and verifying your identity.
• Sharing your information with lenders, funders and selected partners to source and arrange finance for you.
• Promoting responsible lending and helping all parties make a fully informed risk assessment.
• Tracing, collections, recoveries, litigation and debt recovery.
• Managing our relationship with you, administering your account(s) and communicating about your application.
• Monitoring product and service performance to ensure good customer outcomes (Consumer Duty).
• Market research, statistical analysis, product development and service improvement.
• Recording and monitoring communications for training, quality, dispute resolution and regulatory purposes.
• Maintaining the security of our IT systems, networks and premises, and keeping accurate business records.
• Establishing or defending legal claims, and managing the sale, transfer or reorganisation of our business.
• Complying with the legal, regulatory and good-practice requirements that apply to us as an FCA-regulated credit broker.
HOW WE USE YOUR DATA
We use your personal data to provide our products and services and to run our business responsibly, including to:
• Process and manage your application and arrange suitable finance.
• Assess creditworthiness, affordability and credit risk, and verify the accuracy of the information you provide.
• Carry out credit and anti-money laundering checks, and prevent and detect fraud and financial crime.
• Manage your account(s), and support recoveries, collections and litigation where necessary.
• Monitor product and service performance to ensure good customer outcomes.
• Send you information about products and services where you have agreed to receive marketing.
• Comply with applicable laws, regulations and codes of practice.
Automated decisions. We may use automated credit assessment based on your data and information from credit reference agencies. This can result in an automated decline where your application does not meet our criteria, which we review regularly for fairness. We may also use automated profiling to consider which products may suit you. You have the right to ask for a manual review of an automated decision and to object to automated profiling.
Credit searches. We carry out a soft search to pitch your proposal appropriately, which leaves no hard trace visible to other lenders. Once a lender assesses your proposal, they may carry out a hard search, and you should expect them to do so.
WHY WE COLLECT YOUR DATA
The table below summarises the main categories of data we collect and our lawful basis for each.
Data Lawful basis
Identity & contact details
Contractual necessity / legitimate interests – to contract with you and communicate about your application.
Financial information
Legitimate interests – to assess creditworthiness and financial stability.
Employment & income Contractual necessity – to verify employment status and income.
Asset / vehicle information Contractual necessity – to process the finance application.
Credit score & history Legitimate interests – to assess credit risk and repayment behaviour.
Proof of identity & address Legal obligation – to comply with anti-fraud and anti-money laundering rules.
Bank account details Contractual necessity – to set up repayments.
Guarantor & insurance details Contractual necessity – to support and secure the agreement.
Marital status & dependants Legitimate interests – to understand financial obligations.
Consent & marketing preferences Consent – to comply with data protection law.
Communications & feedback Legitimate interests – to manage our relationship and improve our services.
Legal documents & records Legal obligation – to maintain records for legal and compliance purposes.
WHEN WE SHARE YOUR DATA
We may share your personal data, before, during and after any agreement we facilitate, with:
• Our partners, lenders, funders, brokers, agents, sub-contractors, lawyers and associated companies.
• Service providers acting on our behalf, such as IT providers, repossession agents, banks and transport companies.
• Credit reference agencies and fraud prevention agencies, who may share it with others to prevent fraud and money laundering and to verify identity.
• Regulators, ombudsmen, courts and law enforcement agencies, and anyone you authorise us to deal with.
• Parties involved in any sale, merger, reorganisation or financing of our business, who must keep your data safe and use it only as set out in this notice.
Your data may also appear on documents relating to the asset (such as the V5, service history or insurance documents) which may be shared with third parties connected to the asset. If fraud is detected, you may be refused certain services, finance or employment.
Credit reference and fraud prevention agencies
To process your application, your details will be passed to Blue Owl Network Ltd trading as AutoConvert, who carry out credit and identity checks with the credit reference agencies Equifax and Experian. A soft quotation footprint will be placed on your file that is visible only to you and does not affect your credit score. Information from your application and your financial history will be exchanged, including public data (such as the electoral register) and fraud prevention information, even if your application does not proceed.
We continue to exchange information with credit reference agencies while you have a relationship with us, including details of settled accounts and any outstanding debt. If you make a joint application or have a financial associate, our records may be linked until you file for a disassociation. The agencies’ contact details are:
AutoConvert (Blue Owl Network Ltd): 1 Tony Wilson Place, Manchester, M15 4FN – www.autoconvert.co.uk
Equifax Ltd: Customer Services Centre, PO Box 10036, Leicester, LE3 4FS – 0800 014 2955 – www.equifax.co.uk
Experian Ltd: The Sir John Peace Building, Experian Way, NG2 Business Park, Nottingham, NG80 1ZZ – www.experian.co.uk/contact-us/
HOW WE STORE AND RETAIN YOUR DATA
We securely store your data in the UK and follow Cyber Essentials protocols, independently certified by our provider OneMSP. Our IT hosting and maintenance servers are located in the UK. Where we transfer data outside the UK, we take all necessary steps to protect it in line with applicable data privacy laws. No third parties access your data unless the law allows it, and we protect it against loss, theft and unauthorised access, use or disclosure.
Under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, we keep your basic personal data for at least six years after the end of any agreement, after which it is securely destroyed. We may retain data longer to handle disputes, maintain records, demonstrate fair treatment, or for research and statistical purposes (kept private and used only for those purposes). Information about live and settled accounts is kept on credit files for six years from settlement, closure or default.
MARKETING COMMUNICATIONS
Under the Consumer Duty, the level of communication from us may increase to help you understand our products and support you throughout our relationship. With your agreement, we may send you information about our products and services and those of our partner companies. You can opt out of marketing at any time – instructions are included at the bottom of our emails, or you can contact us directly.
YOUR DATA PROTECTION RIGHTS
You have the following rights over your personal data:
• Right to be informed about how we collect and use your data.
• Right of access to a copy of your data and supplementary information.
• Right to rectification of inaccurate or incomplete data.
• Right to erasure of your data in certain circumstances.
• Right to restrict processing of your data in certain circumstances.
• Right to data portability – to obtain and reuse your data across different services.
• Right to object to processing in certain circumstances, including an absolute right to stop direct marketing.
• Rights relating to automated decision-making and profiling – to object to decisions made solely by automated means.
We usually have one month to respond to a request. To exercise any of these rights, please contact us:
Email: info@creativefs.co.uk
Telephone: 0330 223 1261
Post: The Data Protection Officer, Creative Funding Solutions, Ground Floor, Unit 3, Amberley Court, Whitworth Road, County Oak Way, Crawley, West Sussex, RH11 7XL
HOW TO COMPLAIN
If you have a concern about how we handle your data, please contact us first using the details above so we can try to put things right. You also have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection:
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Telephone: 0303 123 1113
Email: casework@ico.org.uk
Website:
https://ico.org.uk/global/contact-us/
