Privacy policy

Fresh Start Car Leasing is a trading style of First Oak Capital Ltd, which is the data controller for everything described on this page.

When you use the website. Pages you visited, roughly where in the country you were, what device and browser you used, and how you found us. This comes from cookies and website analytics, and our cookies page explains how to turn the optional ones off.

When you apply. Your title, name, date of birth, marital status, address, phone numbers, email address, monthly income after tax, your employment situation, your own description of your credit history, and which vehicle you are interested in.

The documents you upload. Three months of bank statements and a copy of your driving licence.

If you contact us. Whatever you tell us by phone, email or through the website, and a record of the conversation.

This is the part most people want to read, so it has its own section.

Why we ask for them. The whole point of this service is that a person looks at what you can actually afford before anyone looks at your credit score. That is only possible with real statements. Without them you would be assessed the way everyone else has already assessed you, which is presumably why you are here.

Who reads them. Someone at Fresh Start, and someone at the lender. Nobody else. They are never passed to any other company, never used for marketing, and never sold.

How they are stored. Uploaded over an encrypted connection and stored encrypted, with access limited to the people who need it to assess your application.

One thing worth knowing. Bank statements sometimes reveal things that count as special category data, such as payments to a place of worship, a trade union or a healthcare provider. We do not look for any of that, we do not record it, and it plays no part in the decision. Please do not annotate your statements with anything of that kind before sending them.

If you would rather not upload them. Ring us on 01730 774450 and we will talk through the alternatives. There are fewer than we would like, because the assessment genuinely depends on them, but it is your decision to make.

We record incoming and outgoing calls. We do it to keep an accurate record of what was said, to train and monitor the people who take those calls, and to resolve any dispute about what was agreed. Recordings are kept for the same period as the rest of your file.

The law requires us to have a lawful basis for everything we do with your data. Ours are:

To take steps at your request before entering into a contract. Assessing your application, reading your documents and passing your details to the lender are all things you asked us to do by applying. This covers most of what we do.

Our legitimate interests. Keeping records of the business we arrange, preventing fraud, improving the website, and being able to defend ourselves if a complaint or a claim is made. We have weighed your interests against ours in each case, and you can object at any time.

Your consent. For optional cookies and for marketing. You can withdraw it whenever you like, and doing so does not affect anything that happened beforehand.

Our legal obligations. We are regulated by the FCA and there are records we must keep, along with anti money laundering and fraud prevention duties we have to meet.

The lender. Your application and your documents go to the leasing company that would provide the car. This is the point of the service, and it is what the consent box on the application form covers.

HighLevel Inc. Our website forms and our customer records run on HighLevel, the US software company also known as GoHighLevel. Your application and your uploaded documents are stored on their systems. They process the data on our instructions only and may not use it for their own purposes.

Google. Website analytics only. This does not include anything you type into the form and it does not include your documents.

Professional advisers, regulators and law enforcement. Where we are required to, or where we need advice about a complaint or a claim.

Nobody else. No affiliate networks, no lead brokers, no comparison sites, no data buyers. If we cannot help you, we say so. We do not pass you on.

HighLevel is based in the United States, so your data is transferred outside the UK. That transfer is covered by the UK International Data Transfer Addendum, which is the mechanism UK law provides for exactly this situation.

Everything else stays in the UK or the European Economic Area.

We keep your file for six years. Where an agreement completes, we keep it for six years from the end of that agreement.

That is longer than some people expect, so here is the reason. If you ever complain that you were treated unfairly, or that we assessed your affordability wrongly, those records are the only way either of us can show what actually happened. The Financial Ombudsman Service can look at a complaint up to six years after the event. Destroying the evidence early would protect nobody, least of all you.

The same period applies to your application, your documents, our decision and the reason for it, and any call recordings.

Website analytics data is kept for 14 months. Marketing preferences are kept until you change them, so that we can show you asked to hear from us, or asked not to.

We do not run a credit check. Nothing we do at the enquiry stage touches your credit file or is visible to any other lender.

If your application progresses, the lender runs their own credit check through a credit reference agency, after you have completed their application form and agreed to it. That is a hard search and it will appear on your credit file. They will give you their own privacy information at that point.

We only send marketing if you have asked for it. There is an optional box on the application form and ticking it is entirely up to you. Leaving it blank makes no difference to your application.

Every marketing message has an unsubscribe link, and you can email help@firstoakcapital.co.uk at any time and we will stop.

We do not make any decision about you by automated means. A person reads your application and a person at the lender reads your statements. The lender's own credit check involves automated scoring, and they will explain that when you reach that stage.

You can ask us to:

You can also withdraw consent for marketing or cookies at any time.

Two honest caveats on deletion. Where we are legally required to keep a record, we will keep it. And where we need the file to establish, exercise or defend a legal claim, which includes a complaint about how we handled your application, we may keep it until that period has passed. The law specifically allows this, and we would rather tell you now than surprise you later. Anything we do not need, we will delete.

Email help@firstoakcapital.co.uk or write to us at the address above. We will respond within one month and we will not charge you.

Your documents are uploaded over an encrypted connection and stored encrypted. Access is limited to the people who need it, and we remove that access when they no longer need it.

No system is perfect and anyone who tells you otherwise is overselling. If something goes wrong we will tell you and the Information Commissioner's Office, as the law requires.

Our cookies page explains what we set, what each one does, and how to turn off the optional ones.

If we change how we use your information we will update this page and change the date at the top. If the change is significant, we will tell you directly.

Please tell us first. Email help@firstoakcapital.co.uk or call 01730 774450 and we will look into it. Our complaints page explains what happens next.

If we cannot sort it out, you can complain to the Information Commissioner's Office, the UK regulator for data protection:

Complaining to the ICO does not affect any other right you have.