Privacy Notice

"We", "our", or "us" means Gouldson & Co Limited and Gouldson Finance Limited of Regency House, Regent Road, St Helier, Jersey JE2 4UZ.

Gouldson & Co Limited and Gouldson Finance Limited are committed to protecting the privacy and security of your personal information.

This Privacy Notice describes how we collect and use personal information about you during and after your relationship with us according to the Data Protection (Jersey) Law 2018 (“DPJL”) and the General Data Protection Regulation (GDPR).

For the purposes of data protection law, we are a data controller with respect to your personal data. We collect and use your personal data, and where applicable, this may include information related to your spouse/partner, directors, partners, and owners (your "representatives"). Gouldson & Co Limited and Gouldson Finance Limited are responsible for ensuring that they use your personal data in compliance with data protection law.

Gouldson is a "Data Controller, " meaning we are responsible for deciding how we hold and use personal information. We are also registered with the Jersey Office of the Information Commissioner (“JOIC”)

• Gouldson & Co Limited (Registration No 60952)
• Gouldson Finance Limited (Registration No 57859)

We will comply with data protection law, the principles of which says that the personal information we hold about you must be: –

• Used lawfully, fairly and transparently.
• Collected only for valid purposes that we have clearly explained to you and not used in any way incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Kept your data only as long as necessary for the purposes we collected it.
• Kept securely.

Gouldson is accountable to you and the authorities for demonstrating compliance with (“DPJL”) and our compliance. We have appointed a DPO to oversee compliance with this Privacy Notice. If you have any questions about this Privacy Notice or how we handle your personal information, contact the DPO at admin@gouldson.co.uk.

You have the right to make a complaint to the JOIC at any time.

Contact details for these are outlined at the bottom of this Privacy Notice.

If you have any questions about this notice, about how we process personal data or about your rights over your personal data, please submit your request in writing addressed to Gouldson & Co Limited and Gouldson Finance Limited of Regency House, Regent Road, St Helier, Jersey, JE2 4UZ.  This notice applies to any personal data we receive from you, create, or obtain from other sources, and it explains how we will use it.  You must take the time to read this notice to understand how we will use your personal data and your rights to your personal data.

This data privacy policy (“Policy”) describes how personal data must be collected, processed, transferred, handled, and stored to meet the requirements of relevant data protection legislation, in particular the Data Protection (Jersey) Law 2018 (the “DPJL 2018”).

We will use your data strictly in accordance with all applicable laws concerning the protection of personal information, and you can be assured that any information you provide will only be used in accordance with this Policy.

Personal data that we collect about you

We will collect and use the following personal data about you and your representatives:

Information you give us

• This is information about you and your representatives that you give us by filling in forms or by corresponding with us by telephone, e-mail or otherwise. The information you give us may include your and your representative's name, address, e-mail address and telephone number, financial and credit card information, employment history, health information, credit history, identification records, qualifications and vehicle or asset details.
• You must ensure that you have obtained the necessary consent to disclose any information you provide us with that does not relate to you (for example, information about your representatives) and provided the individual to whom the information relates with a copy of this notice.
• Whilst we make every effort to maintain the accuracy of personal data, you must assist by promptly contacting us if there are changes to the personal data you have previously provided or if you become aware that we hold inaccurate personal data.

Information we collect or generate about you and your representatives

1)     Website Usage Information - Our website uses Google Analytics to automatically gather statistical information such as visitors' number and frequency and IP addresses.  This information is used as aggregated statistical information about users, providing usage by IP address.  This information helps us to measure how individuals use the website and our services so that we can continually improve them.

2)     We sometimes record telephone conversations to resolve complaints, improve our service, and provide training and quality assurance.

3)     We generate data for statistical analysis.

Use of Cookies

To enable you to sign in and personalise your online experience we use "cookies".  A cookie is a small text file placed on your hard disk by a web page server.  Cookies contain information that can later be read by a web server in the domain that issued the cookie to you.  Cookies cannot be used to run programs or deliver viruses to your computer.  We use cookies to store preferences and other information on your computer to save you time by eliminating the need to enter the same information repeatedly and to display your personalised content and appropriate advertising on your later visits to our website.

Information we receive from other sources

• Financial/Credit Information - We will use the information provided by credit reference agencies when assessing your finance application and verify your or, if applicable, your representatives' identity. Such information may include details about other credit you have taken out, any credit arrangements you have met or failed to meet, and any court judgements against you.
• Fraud Prevention Agencies - When verifying your identity as part of our application process, we may access information recorded by fraud prevention agencies within and outside the UK. This may include information about criminal convictions and any allegations regarding criminal activity that relate to you.
• Intermediaries—We will receive information from dealers, brokers, and introducers, including your personal details, contact details, and relevant asset or policy details, to enter into and administer your agreement.
• Social Media Profile - Where you have clicked through one of our promotions or event notices posted on a third-party social media website such as LinkedIn, we will receive your contact information provided as part of your user profile, such as your name, e-mail address and telephone number and any other relevant business information such as your organisation's name, address and your industry. Some of this information may be prepopulated based on your social media profile; other parts may be completed by you as and when requested.
• Public databases - we may obtain information about individuals from public databases. We use reputable sources, including but not limited to the electoral register, the Jersey Financial Services Commission Companies Registry and the Guernsey Financial Services Commission, as applicable.  We employ appropriate measures to ensure the quality of the information we collect.

How we use your personal data

We may use your data in the following ways:

Credit Scoring & Crime Prevention

• To verify your identity as part of the account opening process for new customers.
• For making a credit check on you. We may search with a credit reference agency who will keep a record of our enquiry against your name, which may be linked to your representatives ("associated records").  For any application for products or services from us, you may be assessed regarding "associated records".  Where any search or application is completed, or an agreement is entered into involving joint parties, we may record details at credit reference agencies. As a result, an "association" will be created that will link your financial records.  Details of which credit reference agency we have used are available on request.  We may also add to your or, if applicable, your business record with the credit reference agencies details of your agreement with us, any payment you make under it and any default or failure to keep its terms.  These records will remain in the credit reference agencies' files for six years after our agreement with you is settled or terminated, whether settled by you or, if applicable, your business or by default.  These credit reference agencies may create or add to their record about you or, if applicable, your business, details of our search and your application. This and other information about you or, if applicable, your business and those with whom you are linked financially may be used to make credit decisions about you or your business.  You can contact us for a complete list of the credit reference agencies we use.
• You can find further information about how credit reference agencies Call Credit, Equifax and Experian may process your personal data at www.experian.co.uk/crain or contact us to obtain a paper copy.
• We may use credit scoring techniques and automated decision-making systems to assess your information fully or partially. These techniques and systems may take into account any previous applications for finance, defaults, or existing debt. The results of this decision may decide whether we provide you with our services or not. If you disagree with the results of an automated decision, you can request a review of your application.
• To allow us to detect and prevent fraudulent activity, including sharing personal data with fraud prevention agencies and
• This will allow us to detect and prevent money laundering activity or terrorist financing.

Products & Services

• To provide you with information, products or services that you may request from us;
• To carry out our obligations arising from any agreements you enter into with us;
• To make payments;
• To recover monies;
• Where we are permitted to do so, to send promotional information about our products and services via methods such as e-mail, post, telephone, etc, and
• We may contact you via post, e-mail, or telephone regarding the administration of your account or to carry out quality control research.

Statistical Analysis

• As part of our legal and regulatory obligations, we conduct statistical analysis to improve our credit risk profile, tackle fraud, and improve our credit decisions. This may include statistical analysis of your data even if we decline your application or you decide not to complete your application with us and
• We aim to identify and offer tailored products and services that suit you and improve our service.

Legal basis for processing your data

We process your data pursuant to the following legal bases:

• Your consent to share your data with third-party affiliates who may wish to offer you products and services which may be of interest to you;
• Taking steps (at your request) before agreeing with you and subsequently for the administration and performance of our agreement with you;
• To comply with our legal and regulatory obligations;
• To establish, exercise or defend our legal rights and/or for (or in connection with) legal proceedings; and
• The use of your data as described is necessary for our legitimate business interests, which are:
• Enforcing the terms and conditions of any agreement we have with you;
• The recovery of outstanding debts existing under an agreement with you;
• For statistical analysis to improve our products and services or
• To contact you about products and services that may be of interest to you. You may object to this at any time by contacting us at carl@gouldson.co.uk, by telephone at 01534 840148 or by writing to us at Gouldson & Co Limited and Gouldson Finance Limited of Regency House, Regent Road, St Helier, Jersey, JE2 4UZ.

Sharing your data

We may disclose your data within the company or to third-party service providers in the circumstances described below:

• To ensure the delivery or maintenance of products or services you have taken out with us;
• To ensure the safety and security of our data and
• As part of our internal research and statistical analysis activity.

We will take steps to ensure that personal data is accessed only by personnel who need it for the purposes described in this notice.

We may also share your data outside of this company:

• To our professional advisors to enforce or apply the terms of use and other agreements you have with us;
• To an insurer or insurers for administration;
• To claims handlers and fraud prevention agencies;
• To any guarantor;
• To any funder to enable funders to assess the value of our assets;
• To any broker or introducer of an agreement with us;
• To tracing and repossession agents;
• If we sell any of our business or assets, in which case we may disclose your data to the prospective buyer for due diligence purposes;
• If we are acquired by a third party, in which case personal data held by us about you will be disclosed to the third-party buyer;
• To third-party agents or contractors (for example, the providers of our electronic data storage services or call centres) to provide services to us and
• With your consent to third-party affiliates who may wish to offer you products and services that may interest you.

These third parties will be subject to confidentiality requirements and will only use your data as described in this privacy notice.  We may also share your data outside of this company to the extent required by law, for example, if we are under a duty to disclose your data to comply with any legal obligation, including but not limited to disclosures made to:

• Credit agencies;
• The Jersey Financial Services Commission Registry;
• The Guernsey Financial Services Commission;

and to establish, exercise or defend our legal rights.

Transfer of personal data outside the European Economic Area

The information you provide us will be transferred to and stored on our secure servers in the European Economic Area ("EEA") (which for this section shall include Jersey and Guernsey).  However, your data may occasionally be transferred to, stored in, or accessed from a destination outside the EEA.  It may also be processed by staff outside of the EEA who work for another or one of our suppliers.  Where we transfer your data outside the EEA, we will ensure that it is protected in a manner consistent with how we will protect your data in the EEA.  This can be done in several ways, for instance:

• The country that we send the data to might be approved by the European Commission or a relevant data protection authority;
• The recipient might have signed up to a contract based on "model contractual clauses" approved by the European Commission obliging them to protect their data or
• Where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme.

In other circumstances, the law may permit us to transfer your data outside the EEA.  In all cases, however, we will ensure that any transfer of your data is compliant with data protection law.  You can obtain more details of the protection given to your data when transferred outside the EEA (including a copy of the standard data protection clauses we entered into with recipients of your data) by contacting us per the "Contact us" section below.

How long we keep your data

How long we hold your data will vary.  The retention period will be determined by various criteria, including:

• The purpose for which we are using it - we will need to keep the data for as long as is necessary for that purpose, and
• Legal obligations - laws or regulations may set a minimum period for which we have to store your data.

If you are a customer, we will retain your data for seven years following the end of our relationship with you unless we are required by law to keep it for a longer period (in which case, we will keep it until the expiry of the period required by law).

Your rights

Your rights about your data are included within applicable data protection requirements, which include the DPJL 2018 and the General Data Protection Regulation 2016 (“GDPR”) (if applicable);

Depending on where you reside and because of the implementation of one of the above, you have rights as an individual, which you can exercise regarding the personal data we hold about you. Your rights are listed below:

• The right to object to our processing of your data where we process your data under our legitimate business interests. Please note that there may be circumstances where you object to our processing of your data, but we may be legally entitled to refuse that request;
• The right to obtain information regarding the processing of your data and access to the personal data which we hold about you;
• The right to withdraw your consent to our data processing at any time. Please note, however, that we may still be entitled to process your data if we have another legitimate reason (other than consent) for doing so;
• In some circumstances, we can receive personal data in a structured, commonly used, and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to us;
• The right to request that we rectify your data if it is inaccurate or incomplete;
• The right to request that we erase your data in certain circumstances. Please note there may be circumstances where you ask us to erase your data, but we are entitled to retain it;
• The right to request that we restrict the processing of your data in certain circumstances. Please note that there may be circumstances where you ask us to restrict our processing of your data, but we are legally entitled to refuse that request;
• The right to object to any automated decision-making (including profiling) that we conduct based on your data significantly affects you. Please note that there may be circumstances where you object to us conducting automated decision-making, but we are legally entitled to refuse that request;
• The right to object to the processing of your data for direct marketing purposes; and
• You have the right to complain to the data protection regulator (details of which are provided below) if you think we have infringed any of your rights.

You can exercise your rights by contacting us using the details in the "Contact Us" section below.

You can find more information about your rights by contacting the data protection regulator, the Jersey Information Commissioner, or their website at https://jerseyoic.org

Changes to our privacy policy

We keep our privacy policy under regular review.  Any changes we make to our privacy policy in the future will be updated and, where appropriate, notified to you by email or sent out in the post.

Contact us

We are registered in Jersey. Our registered address is Gouldson & Co Limited, and Gouldson Finance Limited, Regency House, Regent Road, St Helier, Jersey, JE2 4UZ, and our company registration number is 118711.

Please get in touch with us at the above address if you have any questions about our privacy policy or the personal data we hold about you:

By telephone: 01534 840148 or 07797738518

By email: carl@gouldson.co.uk

This privacy statement was last updated on 19 March 2024

Channel Island Financial Ombudsman

If you are an individual consumer, a microenterprise, or a specific Channel Islands charity, you can complain to the Channel Islands Financial Ombudsman.  You have a right to complain to the Ombudsman if we cannot resolve your complaint within eight weeks of receipt of the complaint or after we have issued a final response.

The Ombudsman can be contacted by telephone on 01534 748610 or 01481 722218 or by email to enquires@ci-fo.org or in writing to Channel Islands Financial Ombudsman (CIFO), PO Box 114, Jersey, JE4 9QG.  Alternatively, you can visit their website at https://ci-fo.org/.

Jersey Office of the Information Commissioner

The Information Commissioner can be contacted by telephone on 01534 716530 or by email to enquiries@jerseyoic.org or in writing to Jersey Office of the Information Commissioner, 2nd Floor, 5 Castle Street, St Helier, Jersey JE2 3BT. Alternatively, you can visit their website at https://jerseyoic.org.