Faff-free Privacy Notice

If you choose to download and install the cinch app, you’ll be able to create an account, browse and purchase a car, and apply for finance in the same way as if you visit the cinch website.  We’ll collect and use your personal data for the same purposes explained in this Privacy Notice. In addition, we'll provide useful information through the app, such as the MOT due date for your car and a summary of your finance agreement and term remaining, if you have taken out finance through cinch.

Device level permissions are needed when the app is installed, in order to access file storage to upload documents for finance applications.

We also use cookies and similar technologies in our app. Some are necessary and cannot be switched off. Other cookies are optional for marketing purposes. You can control the use of these at any time by visiting Settings in the app. More information on our use of cookies is available in our Cookie Policy.

To create an account we’ll need:

- your name;

- e-mail address; and

- a password.

Other than that, you aren’t obliged to provide any more personal data, but in addition to the above, you are able to enter the following:

- Your phone number; and

- Your marketing preferences

You can also save favourites to your account. As part of this function, we will keep you informed if the car's price changes or if the car is no longer available.

As explained in our Cookie Policy, if you allow the use of cookies we’ll also use this data to create a personalised cinch profile to tailor our content, both on our website and in our marketing communications.

Lawful basis: performance of a contract (namely, our Terms of Use) and our legitimate interests in creating a personalised cinch profile for you, to allow you to manage your account, store your favourite search results and view your order history, and for us to communicate with you about your favourited cars.

We may use your personal data to send you marketing by post, by phone, by email and by SMS message. You will always be in full control of any marketing we provide to you.

Lawful basis: We will only use your personal data for marketing purposes if we have your consent or a legitimate interest, depending on how and when we have collected your details (for example via a third party such as our event sponsorship partners, or when you create an account with cinch). 

Where we provide newsletters, marketing communications or other offers or information, we’ll use your data to tailor and send these to you, until you change or cancel your marketing preferences.

Lawful basis: where we have a lawful basis to provide you with newsletters,  marketing communications or other offers or information from us,  we rely on our legitimate interests where we tailor those communications to suit your preferences – we do this so that we can provide you with communications and offers that are relevant to you.

We’ll analyse captured data and share certain personal data with third parties to expand our knowledge of customer categories, use and habits though matching the personal data we collect with other databases. Allowing us to create a more personalised experience for different customer segments and improve cinch. 

Lawful basis: where we have a lawful basis to provide you with marketing, we rely on our legitimate interests to share the data we collect such as name, postcode, address and telephone number with credit agencies and customer matching databases. This enables us to understand our customers better and improve cinch in line with customer expectations.

If you receive any marketing communications from cinch and don’t wish to receive such information in future, then please log in to your account to change your preferences, call us or email us at [email protected]. You will also have the opportunity to opt out of future communications whenever cinch sends you any such material, using the instructions provided.

When you find a car that you would like to buy from cinch, we’ll need the following information from you to enter into the contract of sale with you, process the payment and arrange delivery or collection (as applicable) and to pick up your part exchange car if applicable.:

- Name

- Mobile phone number

- E-mail address

- Current address (we’ll ask for your proof of address upon delivery or collection too by asking for a photocard UK driving licence or other form of ID accepted by us)

- Payment details

If the registered keeper of the part exchange car is not you then we will also need this information from the registered keeper and this Privacy Notice will apply to our use of their data as well.

Lawful basis: performance of a contract (namely, our Car Purchase Terms and Conditions).

If you would like to receive an indication of your financial eligibility, you can choose to carry out a soft credit search (which is arranged via our third party broker, Evolution Funding). We’ll need to collect the following information from you which we will provide to Evolution Funding:

- Full name

- Date of birth

- Current address

- Previous addresses if less than 3 years at current address

Lawful basis: performance of a contract. To provide you with the requested information on your financial eligibility when looking to purchase a car with cinch. We collect this information on behalf of our third-party finance broker, Evolution Funding who carries out the eligibility check. You can view the privacy notice or information about how they use your data, including the section on "Conducting Credit Searches"

If you would like to purchase a car using our finance option (which is arranged via our third party finance broker, Evolution Funding), we’ll need to collect the following personal data from you which we will provide to Evolution Funding and, in some cases, Black Horse (a lender):

- Title;

- Full name (including middle names);

- Gender;

- Date of birth;

- Marital status;

- Nationality;

- Previous addresses if less than 3 years at current address;

- Employment type and history;

- Employer address;

- Time with employer;

- Mobile phone number;

- Residential status;

- Driving licence type;

- Outgoings (including monthly mortgage/rent and other general outgoings);

- Gross annual income;

- Type of proof of income;

- Bank account number and sort code; and

- Number of years you have held that bank account

Lawful basis: We collect this personal data on behalf of our third party finance broker, Evolution Funding, and you can view their privacy notice for information about how they use your data independently to cinch. Our third party finance broker will also share your personal data with lenders considering your finance application. We may also share your data with Black Horse and you should view their privacy notice for information about how they use your data independently to cinch.

Credit Reference Agencies

You should note in particular that our third party finance broker, or the lender that is considering your finance application, will carry out credit and identity checks on you, and will supply your personal data to credit reference agencies (CRAs) who will in turn give them information about you as an output to the credit and identity check.

CRAs will supply to them both public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information. When CRAs receive a search from them, the CRA will place a search footprint on your credit file that may be seen by other lenders. Our third party finance broker or lender do this to assess your creditworthiness and product suitability, to check your identity, manage your account, trace and recover debts and prevent criminal activity.

The finance broker or lender will also continue to exchange personal data about you with CRAs on an ongoing basis, including about your settled accounts and any debts not fully repaid on time. CRAs will share your personal data with other organisations. Your personal data will also be linked to the data of your spouse, any joint applicants or other financial associates. The identities of the CRAs, and the ways in which they use and share personal information, are explained in more detail at Equifax, Experian and Transunion (please note that the Credit Reference Agency Information Notice or ‘CRAIN’ is the same for each of the CRAs).

Your lender will tell us your application ID number and will keep us up to date with the progress and outcome of your finance application so that we can enter into the contract of sale with you at the appropriate time.

Verifying your identity

If you choose to purchase a car using our finance option and your finance application is approved by Black Horse then before you can proceed with entering into the finance agreement, we are required to verify your identity on behalf of Black Horse. In order to do this, we will need to collect a “selfie” photograph of you and an image your identity document such as a driving licence. We will use a third party to carry out this identity check who will collect your photograph and document image as well as certain device and location identifiers such as an IP address in order to help correctly identify you and reduce fraud.  

Lawful basis: compliance with the legal obligations regarding verification of identity imposed by anti-corruption laws, our legitimate interest in reducing fraud and the performance of a contract (namely your finance agreement with Black Horse).

During the term of your finance agreement, we may contact you to discuss finance options we believe may be relevant to you, including renewal, voluntary termination, balloon payments, early settlement and the options available at the end of a finance agreement. This is based on personal data we receive from your lender, relating to your outstanding balance or early settlement requests, where there is a lawful basis for them to share this personal data with us.

If you do not wish us to contact you in this way, please see Managing your marketing preferences to unsubscribe.

Lawful basis: Permission to provide marketing materials to you, which may be based on consent or legitimate interests, depending on how and when we have collected your details

When we communicate with you about the purchase of your car, or if you contact us with a query or complaint, then we will collect and process your personal data and keep records of our interactions with you (e.g. calls, e-mails, chat sessions, letters), as needed to investigate and provide you an answer or resolution. You may also optionally provide your postcode or location of your nearest town, to enable us to advise on collection or delivery options, and the location of your nearest cinch Store. Please note we may record calls and keep records of them and the contents of e-mails.

Lawful basis: performance of a contract (namely, our Terms of Use Car Purchase Terms and Conditions, 90 Day Warranty Terms and Conditions and/or cinchCare agreement, as applicable)and our legitimate interests in ensuring that we are able to answer or resolve any queries or complaints properly and efficiently.

If you enter a promotion, contest, or prize draw then we will collect and process your personal data in order to manage your entry. We may at the same time give you the opportunity of signing up for an account or opting in to receiving marketing communications but will only use your personal data for that purpose if you choose to do so.

Depending on the nature of the promotion we may ask you for personal data in order for you to make a claim or participate, including your name, address, email address, bank account and sort code and other follow up information in case of any queries.  

Lawful basis: performance of a contract, namely our contractual obligations under the terms of the relevant promotion, contest or prize draw – we do this so that we can identify you, to correspond with you regarding the promotion, contest or prize draw, verify your claim is valid and to make any applicable payments or distribute prizes to you (if required).

We might contact you from time to time to provide feedback on our services.

Lawful basis: our legitimate interest in order to continually improve the products and services that we offer.

We may need to contact you in relation to service-related issues, e.g. forgotten account details, technical issues with the service, updates to our terms and conditions, or other non-promotional messages.

Lawful basis: our legitimate interests in ensuring that you can continue to use cinch and are aware of our current policies and procedures.

It’s important for us to understand how people use cinch so that we can improve and ensure our users receive a good service. We’ll analyse which pages or parts of the website get the most views or attention, and how our users arrive here, so that we can improve. This may include collecting details about your device and network, such as browser version, IP addresses, operating system details, and screen size.

This may also involve the use of cookies or similar technologies as explained in our Cookie Policy

Lawful basis: our legitimate interests in maintaining and optimising our website and improving it where necessary or as identified by trends in the user personal data we analyse, including for security purposes and to protect your information.

We’ll use your personal data to assist any public authority or criminal investigation body, for activities relating to the prevention, detection and investigation of crime, for compliance with our legal and regulatory responsibilities, to identify you when you contact us, to comply with a request from you in connection with the exercise of your rights under data protection laws, and to verify the accuracy of personal data we hold about you.

Lawful basis: compliance with a legal obligation.

Under data protection laws, certain “special categories” of personal data are subject to additional protections – this includes data relating to health. We don’t ask you for this type of personal data or intentionally collect it, however if you disclose to us that you have a disability (physical or mental) we might disclose this personal data to our third party finance broker who may tell the relevant lender. This is to make sure we are complying with our legal and regulatory obligations and to evidence that we’ve taken appropriate steps to protect you in the case of a legal claim.

cinch does not intend to collect or process any other special categories of personal data e.g. those revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data or biometric data, or data concerning anyone’s sex life or sexual orientation.

When you purchase a car from cinch, a 90-day warranty for mechanical and electrical repairs to the Car is provided at no additional cost to you. This includes breakdown assistance (where the breakdown results from mechanical or electrical defect).

If you make a claim under our 90-day warranty, we’ll share your personal data and that of any other person you provide (as required to process your claim) with our authorised repairers and/or our breakdown agent, as is necessary to provide the benefits of the 90-day warranty to you, which may include:

- Name;

- contact number; and

- car registration number (where this is personal data).

Where it is necessary for you to provide someone else's personal data as part of a claim (for example a family member or other driver of the car) please ensure they are aware their information will be processed in accordance with this Privacy Notice, and have agreed you may share this information on their behalf (before you provide their personal data to us or our partners).

Please see the Data Protection section in the cinch 90 Day Warranty Terms and Conditions available here for more information.

Lawful basis: performance of a contract (namely our 90-Day Warranty Terms and Conditions)

We offer the following third party products and services, available for you to purchase through the cinch car purchase journey or your My Account function.

- cinchShield (provided by Altro Limited trading as Autoglym)

- cinchCharge (provided by Paua Tech Limited)

- cinchCover (provided by London General Insurance Company Limited (LGI) and administered by TWG Services Limited (TWG)). LGI and TWG provide their services under the name “Assurant”. LGI is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority, Financial Services Register No. 202689. TWG is authorised and regulated by the Financial Conduct Authority, Financial Services Register No. 312440.

The following cinchCover products and services are available for purchase:

- Extended warranty and breakdown assistance;

- Alloy wheel insurance; and

- Scratch and dent insurance.

How your personal data is used

If you opt to purchase any of the third party products and services described in this section, we may need to share the following personal data with these third parties in order to register your purchase and carry out administration tasks (such as re-directing complaints):

- Title;

- name;

- current address;

- contact phone number and email address; 

- car registration number (where this is personal data); and

- customer order ID (where this is personal data).

Lawful basis: performance of a contract (to provide you with cinchShield, cinchCare or cinchCover at your request).

The third party that provides the product or service will be a controller of any personal data you provide to them. This means that the third party, not cinch, decides on the purposes and ways that your personal data is processed (or, in other words, used). cinch is not responsible for the actions of these third parties when processing your personal data.

Where these third party products or services apply to you, please review the privacy notice of each controller (as linked below) to ensure you’re comfortable with how that controller will process your personal data independently of cinch.

- cinchShield - Privacy Policy | Autoglym LifeShine;

- cinchCharge - Paua | Privacy (pauatech.com); and

- cinchCover - as set out in your policy wording documentation and their privacy policy - Privacy Policy | Assurant.