AA Financial Services privacy notice

This privacy notice tells you what happens to your personal data when you, your joint product holders and beneficiaries hold or use a financial services product with us.

You can also view the AA Group privacy notice.

If you provide us with personal information on behalf of another person, you must have their authorisation to do so, and it must be accurate and up to date. You'll need to give them a copy of this privacy notice, or tell them how to access this page. Where this privacy notice refers to 'you', this also includes personal data about anyone else named on the product or anyone whose data you provide us with.

The links below show how we use your personal information.

The AA and our Data Protection Officer

Personal data we hold and use

Sources of personal data

Reasons for using of your personal data

Sharing and disclosures of your personal data

Withdrawing your consent

Transfers outside of the UK or EEA

Sharing with credit reference agencies and fraud prevention agencies

Changes to your data

Monitoring communications

Use of automated decisions

Retention of your data

Your data protection rights

Your right to object

Changes to this privacy notice

The AA and our Data Protection Officer

We're the AA, Fanum House, Basing View, Basingstoke, Hampshire RG21 4EA.

The data controllers of our financial services products are AA Financial Services Limited and, separately, the provider of your financial services products. If there's a different data controller, this will be stated in the terms and conditions of the product or in a separate product privacy notice.

We have a Data Protection Officer (DPO), whose contact details are at the bottom of this page.

Personal data we hold and use

We hold and use different types of personal information about you, your joint applicants and beneficiaries.

The list below shows the data we process for our financial services products. If you hold breakdown cover or other products and services, you should read their privacy notice to know what other data we might hold.

Personal and contact details, your date of birth, gender and age.

Details of product beneficiaries or users, and applicants.

Records of your contacts with us and payment details.

Details of products and services you hold or have held, your use of them, any claims or breakdowns, and any expressions of interest in the AA or its business partners. These can include AA Breakdown Services, AA Driving School, AA Cars, AA Insurance Services and other AA branded services.

Pricing and risk data about you, your beneficiaries or product holders and applicants. This data is used, for example, to assess or make a decision about risk, decide or set pricing or risk levels, and decide whether we can offer or continue to offer you a product or service. The data includes details of your AA product or service holdings (including your usage, claims and breakdown history), credit data, marketing profiles and analysis of you we hold, instances of suspected fraud, data from third parties, property and location details, vehicle details, driving history and telematics details.

Marketing information, including records of marketing communications, details of what you may be interested in, analysis and profiles we build up about you and your interests, and whether you open or read communications or links.

Vehicle information, including usages, any breakdowns and faults.

Telematics and connected car information about your vehicle (including assessing and predicting faults or issues), your driving style (including recommending improvements and assessing risk associated with your driving style), and location and routes taken. This information applies when you hold Smart Insurance, Smart Breakdown, or a Car Genie device or one of our other telematics or connected car products.

Information which we obtain from credit reference agencies and fraud prevention agencies.

Fraud, debt and theft information related to any products you hold with the AA.

Criminal records information, including alleged offences.

Information about your health or if you're a vulnerable customer, where needed for your product.

Information about your property, such as location, value, number of rooms, property type and building work you've had done. Also, property and occupier status, such as whether you're a tenant, live with parents or are an owner occupier of the property where you live at the time of your application.

Information about your employment status, where needed for the product.

Your marital status, family, lifestyle or social circumstances, for example, the number of dependents you have or if you're a widow or widower.

Information from third parties, including vehicle details, details of outstanding finance, claims details, fraud prevention databases, property, geographic and demographic details and marketing data; publicly available information (for example electoral roll and court judgments); and information to help improve the relevance of our products and services or to help us manage our products and services, pricing or risk.

Details of your usage of our websites or apps, details of your phone and its software (for example browser and set up information), browsing history, and other details obtained via cookies or similar technologies. See our cookie policy for more details.

Third party transactions, such as where a person other than the account holder pays for or uses the service.

We may be unable to provide products or services if you don't give certain information to us. In cases where providing some personal information is optional, we'll make this clear.

Sources of personal data

The information we hold comes from:

You directly, and family members, associates or beneficiaries of products and services – for example, if they're authorised to act for you or are allowed to use a service you have with us.

The AA Group if you already have a product with them, have applied for one or have held one previously.

A third party and their insurer, if they're making a claim.

Information generated about you when you use our products and services.

Business partners (for example financial services institutions, insurers), account beneficiaries, or others whom we work with to provide products, services or a quote to you.

Anyone who provides instructions or operates any of your accounts, products or services on your behalf (for example a power of attorney, solicitors and intermediaries).

From sources such as fraud prevention agencies, credit reference agencies, other lenders, HM Revenue & Customs, Claims Underwriting Exchange, publicly available directories and information (for example a telephone directory, social media, internet and news articles), debt recovery and tracing agents, regulators, government departments or agencies, organisations to assist in prevention and detection of crime, the police and law enforcement agencies.

Information we source about you or customers generally from commercial third parties, including demographic information, vehicle details, claims data, fraud information, marketing data, publicly available information, property and other information to help improve our products and services or our business.

Reasons for using of your personal data

The reasons why and how we use your information are given below. We've arranged them according to the lawful basis that allows us to use the data. The lists apply to us the AA.

1. To provide you with our products or services or decide whether to do so

a. Assessing an application for a product, including considering whether or not to offer you the product or service; the price; the risk of doing so; availability of payment method; and the terms of the product.

b. Providing your product and any other products or services held with the AA and under the AA brand.

c. Communicating with you, and holding records about our dealings and interactions with you, your fellow applicants and beneficiaries.

d. Making decisions about you or your product, including your continued suitability for it; the risk of providing you with the product; and assessing compliance with the product terms.

e. To manage the operation of our business and those of our respective financial services partners.

f. To carry out checks at credit reference agencies and fraud prevention agencies pre-application, at application, and periodically after that.

g. For analysing, assessing and profiling aspects of you, your vehicle (including assessing and predicting faults or issues), your driving style, your location and routes taken (for example, if you hold a telematics product), for quoting for and managing your product, and for the continued assessment of risk and compliance with product conditions.

h. For analysing and profiling aspects of you, your home or property, and for quoting for and managing your product, including the continued assessment of risk and compliance with product conditions.

i. Updating your records, tracing your whereabouts, recovering debt, or validating the information you've provided is correct.

j. To make automated decisions – including profiling – on whether to offer you a product, and the price, payment method, risk or terms of it.

k. To share information with business partners (for example Bank of Ireland (UK) Limited and credit card partners) for quoting, assessing your application, and managing your product; as needed with account beneficiaries, and service providers to us; and for providing, administering or developing our products and services or our business.

l. To enable the AA Group to provide you with products and services, quotes for products and services, and manage products and services you hold.

2. For our legitimate interests

a. To develop our financial services products and any other products or services.

b. To continually develop, improve and manage risk assessment, and pricing methods and models.

c. To provide personalised content, products and services to you, such as tailoring our products, services, digital customer experience and offerings, and deciding which offers or promotions to show you on our digital channels.

d. To link together your AA products and services, enabling you to view them in a single account or profile, and using this combined view for the purposes listed in this section.

e. To test the performance of our products, services, and processes and systems.

f. To improve the operation of our business, for example by improving customer service and operational performance and efficiency.

g. To develop new products and services, and to review and improve current products and services.

h. For managing and auditing our business operations.

i. To keep records of our communications with you.

j. For marketing analysis and related profiling, to help us decide whether or not to offer you certain products and services.

k. To understand our customers, and your use of our products and your preferences, and to develop profiles, algorithms and statistical models for these purposes.

l. To send marketing offers by SMS, email, phone, post, social media and digital channels (for example using Facebook Custom Audiences and Google Custom Match). The offers may relate to our products and services, such as cars, roadside assistance, financial services, insurance, travel and Member offers, as well as any other offers and advice we think may be of interest.

m. To carry out checks at credit reference agencies and fraud prevention agencies, to enable us to provide you with personalised offers. These checks will be soft searches that don't affect your credit rating.

n. To provide insight and analysis of our customers for ourselves and our business partners, based on your use of your policies, and possible future opportunities.

o. For market research, profiling, and analysis and developing statistics, to support any of the purposes listed in this notice.

p. For profiling and decision making for purposes listed.

q. To facilitate the sale of one or more parts of our business.

r. To share information with business partners as necessary for purposes listed.

s. To enable other AA Group companies to perform any of the above purposes.

3. To comply with our legal obligations

a. Such as financial services regulations and other regulatory obligations, including the Financial Conduct Authority, the Prudential Conduct Authority and the Financial Ombudsman Service.

4. With your consent or explicit consent

a. For direct marketing communications which aren't based on our legitimate interests.

b. For profiling and other automated decision making which aren't required for contractual or legal purposes.

c. For processing special categories of personal data if another legal basis does not apply, such as about your health; if you're a vulnerable customer; or criminal records information.

5. For public interest

a. Using special categories of personal data such as criminal records information (including alleged offences) to quote for or administer a financial product, including assessing the risk of providing you with the financial product.

b. Using special categories of personal data about your health or needs (if you are a vulnerable customer) to quote for or administer a financial product, including assessing the risk of providing you with the financial product.

Sharing and disclosures of your personal data

The categories of third parties we use are listed below. The reasons why we use them are described on this page, and third parties may have access to personal information we hold or use.

Within the AA Group.

Business partners (for example, financial services institutions, insurers), account beneficiaries, or others who are a part of providing your products and services or operating our business including Freedom Finance, Evolution Funding Ltd, the Bank of Ireland (UK) plc and Northridge NIIB Group Ltd, trading as Northridge Finance.

Account beneficiaries if they use a service you have with us.

Parties who provide products and services to you, or help us to operate our business.

Parties involved in a claim if they need to receive information to allow us to handle a claim made by you or against you, or if either insurer needs to investigate a case of fraud.

Police and law enforcement agencies if we need to support a criminal investigation.

Governmental and regulatory bodies such as HM Revenue & Customs, the Financial Conduct Authority, the Prudential Regulation Authority, the Financial Ombudsman Service, and the Information Commissioner's Office.

Organisations and businesses who provide services to us under our authority, such as service providers, debt recovery agencies, IT companies, and suppliers of business support services.

Credit reference agencies and fraud prevention agencies.

Third parties who help us identify, assess, or manage risk or pricing.

Market research organisations who help us to develop and improve our products and services.

Withdrawing your consent

If we rely on your consent, you can withdraw it at any time. Please use the contact details below.

Transfers outside of the UK or EEA

Your personal information may be transferred outside the UK or the European Economic Area, for example to service providers. If we do so, we'll make sure that suitable safeguards are in place where required, for example contractual or other legal arrangements unless certain exceptions apply.

Sharing with credit reference agencies and fraud prevention agencies

To process a quote or application for a product, we'll perform credit, risk and identity checks on you with one or more credit reference agencies (CRAs) and fraud prevention agencies (FPAs).

Where you do take insurance, financial products or credit from us, we may make periodic searches to manage your account. To do this we'll supply your personal information to CRAs and FPAs, and they'll provide information about you. This will include your credit applications, and about your financial situation and history.

CRAs and FPAs will also supply to us public information (including the electoral register), and shared credit, financial history information, and fraud prevention information.

We, and any proposed or appointed underwriters for your policy, will use this information to:

Assess your creditworthiness and whether you can afford to take the product.

Assess our ability to offer you our products and services.

Verify the accuracy of the data you've provided to us.

Prevent criminal activity, fraud and money laundering.

Manage your account(s).

Assess payment methods available to you.

Trace and recover debts.

Make sure any offers provided to you are appropriate to your circumstances.

We'll continue to exchange information about you with CRAs and FPAs while you have a relationship with us, and if necessary afterwards. We'll also notify the CRAs about your settled accounts.

If you borrow and don't repay in full and on time, CRAs will record the outstanding debt. This information may be given to other organisations by CRAs.

The identities of the CRAs and FPAs are available on request, and the data they hold, the ways in which they use and share personal information, data retention periods, and your data protection rights.

When CRAs receive a search from us, they'll place a search footprint on your credit file that may be seen by other lenders.

If you're making a joint application, or you tell us that you have a spouse or financial associate, we and our underwriters will link your records together. So make sure you discuss this with them before making the application. CRAs will also link your records together, and these links will remain on your and their files until such time as you or your partner successfully files for a disassociation with the CRAs to break that link.

We and our underwriters may use commercially available insurance fraud prevention services and claims services in order to prevent, detect and investigate potential fraudulent insurance policy applications and claims. We'll share information with the FPAs about your insurance policy application and policies in order to do this, and this information may be given to other organisations. You can find more details here and on the AA Group privacy notice.

Changes to your data

You should tell us about any changes to your personal data so we can update our records. The contact details for this purpose are in your product documents.

Monitoring communications

We may monitor communications with you where permitted by law. We do this for quality control and staff training purposes, to comply with regulatory rules, to prevent or detect crime, to protect the security of our communications and data, and to enforce compliance with business polices.

Use of automated decisions

We sometimes make decisions about you using only technology, where none of our employees or any other individual has been involved. The decisions include whether to offer you a product or service, the risk of doing so, the price we'll offer, whether to offer you credit, the terms and conditions, to assess lending, insurance and business risks, and to assess what payment methods we can offer you.

We may do this using data from the AA Group and underwriters. This includes product or services data (including usage of claims made), and telematics data captured on your vehicle, driving behaviour and location information.

These examples explain why we do this:

Assess your creditworthiness and ability – for example if you're applying for credit and have a history of late or non-payment of debts, we may not be able to offer you credit or else do so at a higher rate.

Assess our ability to offer our products and services and manage those accounts – for example if you or your beneficiaries have a history of making claims on insurance policies, or if we have concerns about the use of a policy (for example if you're in breach of its conditions) or your financial status, this may result in a higher risk being assigned to you, meaning you may be quoted a higher price or a policy being declined or cancelled.

Assess the risk of fraud – if we believe there's a significant risk of fraud, based on the information available to us, we may decline your application, quote a higher price, or cancel your policy or application.

It's necessary to do this when entering into or performing the relevant insurance or credit agreement with you. We only do so if it's authorised by law or is based on your explicit consent.

Retention of your data

Unless we explain otherwise to you, we'll hold your personal information on the following criteria:

For as long as we have reasonable business needs.

For as long as we provide products or services to you, and then for as long as someone could bring a claim against us.

To comply with legal and regulatory requirements or guidance.

Your data protection rights

Here is a list of the rights that individuals have under UK data protection laws. The rights don't apply in all circumstances, so your request may not always be granted, and we'll explain why at the time.

The right to be informed about the processing of your personal information.

The right to have your personal information corrected if it's inaccurate, and to have incomplete personal information completed.

The right to object to processing of your personal information.

The right to restrict processing of your personal information.

The right to have your personal information erased.

The right to request access to your personal information and how we process it.

The right to move, copy or transfer your personal information.

Rights in relation to automated decision making which has a legal effect, or otherwise significantly affects you.

You have the right to complain to the Information Commissioner's Office, which enforces data protection laws. Our DPO can provide you with more details on the above rights.

Your right to object

You have the right to object to certain purposes for processing your personal information, in particular direct marketing and for certain reasons based on our legitimate interests. You can contact our DPO to exercise your right.

Opting out of marketing

You can stop our marketing at any time by contacting us.

Changes to this privacy notice

We may update this privacy notice to reflect changes in the law or our privacy practices, or both. Accordingly, please check this page from time to time.

Contact us or our Data Protection Officer

You can use the contact details in your product documents or the contact us section of our website. Or please write to the Data Protection Officer at:

AA Limited, Fanum House, Basing View, Basingstoke, Hampshire RG21 4EA

[email protected]