Privacy Policy

Momentum Warranties Limited is a Registered company in the UK (Company no. SC278548). Our registered address is King James VI Business Centre, Friarton Road, Perth, PH2 8DY.

We take your privacy very seriously and we are committed to protecting your privacy in compliance with data protection laws and regulations in the United Kingdom, including the Data Protection Act 2018 and the UK GDPR (as this is defined in the Data Protection Act 2018) (the “Data Protection Laws”).

We are the controller of the personal data that we process, i.e. the organisation which determines (alone or jointly with another party) how your personal data is processed and for what purposes. This means that we are responsible for ensuring that our systems, processes, suppliers and people comply with the data protection laws in relation to the personal data that we handle.

We will receive personal data from third parties. For example, if you are an individual we may receive personal data from the dealership who sold you your car. We will also share data with third parties, such as any insurers or dealerships responsible for providing any products administered by us. Those third parties may also be controllers and are required to inform you about how they process your personal data in their own privacy notice. More information about this is provided in the Sharing your Personal Data section of this Notice.

Purpose of this notice

This Notice describes how we process the personal data of people who we provide products and services to, including: (a) people who have purchased a warranty product provided or administered by us from a car dealership; and (b) people who have purchased insured products from us which we administer for the insurer. It also applies to people who have enquired about our products and services.

This Notice describes how we process the personal data of users of our website, personnel of our suppliers and partners (such as dealers and insurers), visitors to our premises and people who apply for or enquire about jobs.

This Notice is designed to help you understand what kind of information we collect and how we may use this. This Notice describes how we collect, use, share, retain and safeguard personal data.

This Notice sets out your individual rights; we explain these later in the Notice but in summary these rights include your right to know what data is held about you, how this data is processed and how you can place restrictions on the use of your data.

We keep this Notice under regular review. If we make any changes to this Notice we will post the changes on this page, and place notices on other pages of our website , so that you are made aware of the personal data that we collect and how we use it at all times.

What personal data do we process?

Personal data is information relating to an identified or identifiable natural person. Examples of the information we may collect include an individual’s name, address, email & telephone number.

We may collect and use some or all of the following personal data about you, where this information is required for the purposes described in the How do we use your personal data? Section below: 

• Identification information: such as your title, name, date of birth, your national insurance number other official forms of ID;
• Contact information: such as your address, email address, phone number, and marketing preferences;
• Financial information: such as your bank details, fees information and credit rating;
• Technical information: such as your IP address, records of your visits to our website, your online registration details and login credentials;
• Correspondence information: such as call recordings when contacting our customer care and complaints functions, personal data contained in documents and correspondence exchanged with you or relating to you;
• Special category personal data: such as information relating to your health;
• Criminal offences data: such as information relating to driving offences;
• Images: such as CCTV footage taken at our premises and photos taken at our meetings or events;
• CV and job application information: such as your employment history, qualifications, references and information provided to us during any interview process;
• Other personal data: such as personal data provided to us by you when completing an online quote or contact forms.

If you do not want to provide your personal data to us, we may not be able to provide certain products and services to you.

How do we use your personal data?

We will process your personal data for the following purposes. Under the Data Protection Laws, we are required to have a “lawful basis” for processing your personal data. We have identified our lawful basis in respect of each purpose below. Where we refer to processing being in our (or a third party’s) “Legitimate Interests” please see further details in the “Our Legitimate Interests” section below.  

Purpose	Lawful Basis
Providing products and services: We gather your personal data to enable us to provide our services to individual customers in accordance with the product terms (either where they have been purchased directly from us or from a dealer). We also gather the personal data of personnel of our dealer clients to manage our relationship with your organisation. This includes where we administer our products, process claims and renewals. We process your personal data if it is necessary to perform a contract with you or where it is necessary in our legitimate interests.	We process your personal data if it is necessary to perform a contract with you or where it is necessary in our legitimate interests.
Customer Service, Feedback or Complaints: If you provide us with feedback or make a complaint about any of our services via our website, we will use your personal data to respond to you and address your concerns. We may record calls you make to our customer care and complaints and other customer focused functions.	We process your personal data if it is necessary to perform a contract with you or where it is necessary in our legitimate interests.
Service Improvement and Security: We may use aggregated information and statistics for the purposes of monitoring website usage in order to help us to develop our website (including our dealer portal) and our products and services. We may also provide such aggregated information to third parties.  The aggregated information or statistics that we disclose for these purposes will not include information that can be used to identify you. We may also process your personal data to keep our premises, website and systems safe and secure. For example, CCTV at our premises or to investigate security breaches, debug or fix errors that impair our website.	We process your personal data if it is necessary to perform a contract with you or where it is necessary in our legitimate interests.
Service Communications: We will use your personal data to send you information which is relevant to the products and services that we are providing to you (or your organisation). This includes providing you with information about renewals.	We process your personal data if it is necessary to perform a contract with you or where it is necessary in our legitimate interests.
Marketing: We will provide you with information about our events, products, services and campaigns if you enquire about them. We may also send you emails about events, products, services and campaigns if: (a) you are a contact at one of our corporate customers and have not opted-out; or (b) if you are an individual customer and you have either given us your consent or you are a recent customer of similar products or services and you have not opted-out. If you would rather not receive this information, please unsubscribe by following the link included in any marketing emails you receive from us.	We process your personal data in this way if we have your consent or it is necessary in our legitimate interests.
Changes to our business: Should we enter into any business arrangements, such as a joint venture with a partner, or if there is a change in our ownership or we merge with another company, we may share your personal data with our new owner or merger partner. The terms of this Policy will continue to apply and those third parties will not use your personal data for any other purposes.	We process your personal data in this way if it is necessary in our (or a third party’s) legitimate interests.
Compliance with laws: We may need to process your personal data to comply with laws and to respond to and comply with requests from the government, regulators and other third parties with legal authority. We may also need to process your personal data to investigate, detect and prevent fraud or crime and carry out related risk assessments.	We process your personal data in this way if it is necessary for our compliance with a legal or regulatory requirement.
Legal claims: We may process your personal data where this is required to exercise or defend legal claims. We may also use your personal data to protect our rights, property, or safety, or that of our staff, our customers, or others.	We process your personal data in this way if it is necessary in our (or a third party’s) legitimate interests.
Job applications: If you apply for a job with us, we will process your personal data as part of our recruitment process.	We process your personal data in this way if it is necessary for the purpose of entering into a contract with you or it is necessary in our legitimate interests.

Legitimate Interests

We have determined, acting reasonably and considering the circumstances, that we are able to rely on legitimate interests as the lawful basis on which to process your personal data in certain circumstances (we have stated this above and set out our legitimate interests). We have reached this decision by carrying out a balancing exercise to make sure our legitimate interest does not override your privacy rights as an individual. We document the balancing exercises that we carry out when relying upon this lawful basis for processing your personal data.

We consider that it is reasonable for us to process your personal data for the purposes of our legitimate interests outlined above as: (a) we process your personal data only so far as is necessary for such purpose; and (b) it can be reasonably expected for us to process your personal data in this way. 

Cookies

We will also collect electronic personal data when you first visit our website where we will place a small text file that is commonly known as a cookie on your computer. Cookies are used to identify visitors and to simplify accessibility, and to monitor visitor behaviour when viewing our website content, navigating our website and when using features. For more information please see our Cookie Policy.

Sharing your personal data

We will share your personal data within our firm and with the companies connected with the performance of the products you have purchased (for example, the dealer you purchased a product from or their (or our) insurer or any insurers whose products we have sold to you). As explained earlier in this Notice, those third parties will be controllers of the personal data that they process and will be responsible for that activity. They will tell you how they process your personal data in their own privacy policies.

When processing your personal data for the purposes set out in this Notice, we may share your personal data with:

• other companies within our company group;
• if we are part of a merger or acquisition or joint venture, the purchasers of our business or assets or our joint venture partner;
• companies that enable us to administer and provide our products and services, including maintenance and repair companies, breakdown recovery companies, and claims handling companies;
• our professional advisors and auditors, such as accountants, tax, legal or other corporate advisors who provide professional services to us;
• insolvency practitioners in the event that we are the subject of any insolvency situation;
• other third party suppliers, business partners and sub-contractors for business administration, support, or IT purposes;
• other third party suppliers for marketing purposes, including third party survey tools, analytics tools or tools for pushing messages to you; and
• our regulators, law enforcement or fraud prevention agencies, as well as our legal advisers, courts, the police and any other authorised bodies, for the purposes of investigating any actual or suspected criminal activity or other regulatory or legal matters.

Retaining your personal data

We take steps to permanently delete or anonymise your personal data (which means that we are no longer able to identify you from it) when it is no longer necessary for the purpose that it was collected and we are not required by law to keep it.

In particular,  we will retain your personal data at the end of any contractual agreement for a period of 6 years. Where you have submitted a claim, we will retain your data for a period of 6 years. Where you have requested a quote, we will retain your personal data for a period of 6 months, where you have contacted us for details of our services and products, we will retain your personal data for 6 months. Where you have made a complaint we will retain the data for 3 years. Where you or law enforcement agencies inform us about any active investigation or potential criminal prosecution, we will comply with legal requirements when retaining this data.

The retaining of data is necessary where required for contractual, legal or regulatory purposes or for our legitimate business interests for statistical analysis (profiling) and product development.

Sometimes we may need to retain your data for longer, for example if we are representing you or defending ourselves in a legal dispute or as required by law or where evidence exists that a future claim may occur.

Please contact our Data Privacy Representative if you object to the use of, or you have any questions relating to the use of, your data, the retention of your personal data.

Protecting your data

We will take all appropriate technical and organisational steps to protect the confidentiality, integrity, availability and authenticity of your data, including when sharing your data within our firm and authorised third parties.

International transfers of personal data

We will transfer your data to third parties based outside the United Kingdom. This is necessary for the purposes of administering out business and underwriting and claims processing purposes. Such parties are not permitted to use your personal data for any other purpose than for what has been agreed with us.

If we transfer personal data to countries outside of the United Kingdom, we may rely on:  (a) a lawful exception to the rules relating to overseas data transfers (for example, you have given your explicit consent or it is necessary to make the transfer to fulfil our contract with you); (b) a decision from the Secretary of State (or other mechanism permitted under the Data Protection Laws) determining that the country provides an adequate level of protection to the Data Protection Laws; or (c) appropriate safeguards in respect of transfers of personal data to a country outside of United Kingdom (for example, by requiring the recipient of the personal data in the other country to agree to the standard contractual clauses or international data transfer agreement approved under the Data Protection Laws).

Please contact our Data Privacy Representative for a list of countries and organisations your personal data is transferred to and/or for further information on the measures undertaken to safeguard your data.

Your rights

Individuals are provided with legal rights governing the use of their personal data. These grant individuals the right to understand what personal data relating to them is held, for what purpose, how it is collected and used, with whom it is shared, where it is located, to object to its processing, to have the data corrected if inaccurate, to take copies of the data and to place restrictions on its processing. Individuals can also request the deletion of their personal data.

These rights are known as Individual Rights under the Data Protection Laws. The following list details these rights:

• The right to be informed about the personal data being processed;
• The right of access to your personal data;
• The right to object to the processing of your personal data;
• The right to restrict the processing of your personal data;
• The right to rectification of your personal data;
• The right to erasure of your personal data;
• The right to data portability (to receive an electronic copy of your personal data);
• The right to withdraw your consent;
• Rights relating to automated decision making including profiling.

Individuals can exercise their Individual Rights at any time. As mandated by law we will not charge a fee to process these requests, however if your request is considered to be repetitive, wholly unfounded and/or excessive, we are entitled to charge a reasonable administration fee. In exercising your Individual Rights, you should understand that in some situations we may be unable to fully meet your request, for example if you make a request for us to delete all your personal data, we may be required to retain some data for taxation, prevention of crime and for regulatory and other statutory purposes.

You should understand that when exercising your rights, a substantial public or vital interest may take precedence over any request you make. In addition, where these interests apply, we are required by law to grant access to this data for law enforcement, legal and/or health related matters.

If you require further information on your Individual Rights or you wish to exercise your Individual Rights, please contact us using the contact details set out below.

Data privacy representative

To ensure data privacy and protection has appropriate focus within our organisation we have a Data Privacy Representative who reports to our senior management team. The Data Privacy Representative’s contact details are as follows:

The Data Privacy Representative,
Momentum Warranties Ltd, King James VI Business Centre,
Friarton Road,
Perth, PH2 8DY
or email support@mometumwarranties.co.uk or by telephoning 0330 445 0059.

Complaints

If you are dissatisfied with any aspect of the way in which we process your personal data please contact our Data Privacy Representative. You also have the right to complain to the UK’s data protection supervisory authority, the Information Commissioner’s Office (ICO). The ICO may be contacted via its website which is ico.org.uk/concerns, by live chat or by calling their helpline on 0303 123 1113.

How to contact us

If you have any questions regarding this Notice, the use of your data and your Individual Rights please contact our Data Privacy Representative, Momentum Warranties Ltd, King James VI Business Centre, Friarton Road, Perth, PH2 8DY or by e-mailing support@mometumwarranties.co.uk or by telephoning 0330 445 0059.

Last updated: 26/04/2024

Version number: MW V001