Who is responsible for your information?
When you apply for a loan with RAC loans there will be three data controllers responsible for using your information – RAC as intermediary, a credit broker and the lender.
This privacy notice only covers how RAC handles your information. The brokers and lenders have their own privacy notices which explain how they will use your information.
1. RAC as an intermediary
RAC Loans is an intermediary service provided by the RAC. RAC does not provide the loans but we are involved in the selection of the panel of lenders and in negotiating the terms of the loan you receive.
RAC Loans is a trading name of RAC Financial Services Limited. RAC will be the data controller of your personal data used for acting as an intermediary between you and the brokers, for marketing the RAC Loans service and for analytical purposes.
2. The broker
RAC Loans works with two credit brokers:
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Loan applications through RAC’s website: Freedom Finance acts as the credit broker for loans where the application has been made through our website (https://www.rac.co.uk/loans) and will be the data controller for the personal data used for that purpose. Freedom Finance is a trading style of Freedom Finance Limited of Atlantic House, Atlas Business Park, Simonsway, Manchester M22 5PR. You can find out how Freedom Finance uses your data by reading their privacy notice (www.freedomfinance.co.uk/privacy-policy).
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Loan applications via aggregators: The aggregator website will be the credit broker for loans where the application has been made through an aggregator website.
3. The loan provider
The loan provider will also be a data controller of your information which is used for the purpose of providing and administering the loan. The loan provider will be:
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Loan applications through RAC’s website: One of a panel of lenders selected by RAC Loans and engaged by Freedom Finance.
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Loan applications via aggregators: Shawbrook Bank will be the lender for these applications and will be the data controller for the personal data which is used for the purpose of such loan applications. Shawbrook Bank Limited is registered in England and Wales. Registered company number: 00388466. Registered office: Lutea House, Warley Hill Business Park, The Drive, Great Warley, Brentwood, Essex, CM13 3BE. You can find out how Shawbrook uses your data by reading their privacy notice (https://www.shawbrook.co.uk/privacy-notice).
The purpose and legal basis for using your data
When you apply for an RAC Loan, RAC will typically be the data controller for the following purposes:
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Our purpose for using your data
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Our lawful basis
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Our business activities
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Pricing activities: Statistical and analytical purposes: Making improvements to RAC products and services including internal testing, reporting and analysis; business processes and operations including quality assurance, governance, management and audit practices.
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Legitimate interest
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Marketing: Using your information for the purpose of marketing activities, including the use of determining the marketing communications we send to you (which may include profiling) and analysis of our marketing activities.
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Legitimate interest
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For each different purpose for which we use your data, we need to have a lawful basis. The different lawful basis are set out in the General Data Protection Regulation (GDPR). The ones we’re relying on are:
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Legitimate interest: We rely on this basis when our use of your data is necessary for the purposes of our legitimate interest which does not unduly impact you rights and freedoms. This legal basis is set out in article 6(1)(f) of the GDPR.
The information we collect
The information which we use about you relating to your RAC Loan will include:
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Category of information
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Examples
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Information we already hold due to our existing relationship
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Key personal details
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Name, date of birth, etc
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Contact details
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Home address, email address, telephone number
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Marketing preferences
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Your preferences for the marketing you would like to receive from us
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Information about your loan application which we receive from the broker
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Key personal details
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Name, date of birth, etc
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Contact details
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Home address, email address, telephone number
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Details of the loan
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The purpose, status and term of your loan as well as the date of your loan application.
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How we receive your information
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Our brokers and lenders provide us with the information about your loan application and the status of your loan.
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From you if you contact us directly, or you are already an RAC member, we could collect information from you.
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Information Commissioner’s Office, law enforcement agencies and other public bodies may provide us with information about individuals who have made a complaint or in relation to their investigations and law enforcement activities.
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Regulatory bodies such the Financial Ombudsman Service and the Financial Conduct Authority may provide us with information about individuals who have made a complaint
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Data services providers such as data science organisations, who collect demographic data and publicly available information which is used to help us improve and tailor our products and services or information used to identify products and services that we believe you may be interested in.
How long we keep your information for
We usually hold your data for up to 7 years.
Who we share your information with
We share your data with our brokers and we may share your data with third parties?who are instructed by us, such as:
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RAC group companies
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IT providers: providers of IT services for administration and management of our internal systems
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Regulators: Regulators and governmental bodies, such as the Financial Conduct Authority or Information Commissioner’s Office if necessary to meet our mandatory reporting requirements.
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Professional advisors and purchasers: Our professional advisors for the purpose of providing us with professional advice. If RAC is sold, we may need to disclose your personal information to our advisers and any prospective purchasers and their advisers.
Automated decision-making
Automated decisions are decisions which are made about you using only technology and which aren’t made with the direct input of an actual person.
We use automated decision-making, including profiling, for several different purposes:
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to determine the marketing and communications we send to you
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to decide whether to offer a product or service; and
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the price of the product or service.
We use automated decision making where it’s necessary in order to provide you with the product or service.
Where your information is held
We are a UK based organisation but we do offer services to our members across Europe, such as our European Breakdown cover. It is possible that we may transfer your personal information outside of Europe, for example, where one of service providers has operations outside of Europe and such transfer is necessary.
Where your data is transferred outside of Europe, we will ensure that suitable safeguards are in place to make sure that your data is protected. The safeguard will usually be reliance on standard contractual clauses.
What happens if you do not provide us with your personal information
Unfortunately, if you do not provide us with the personal information which we need in order to provide you with a product or service, we may not be able to provide you with that product or service.