Privacy Statement

Please Note: This privacy notice describes how First Call Group Limited, and ALL of its trading styles (also referred to as “we” or “us”) process Personal Data relating to our customers, service users and related individuals, and other enquirers and users of our website (“you”). Pursuant to the definition provided by the EU regulation General Data Protection Rule, we are acting as Data Controller and Processor. We are accountable of any usage of your Personal Data made by us or on our behalf. We may update this notice from time to time and will publish the new version on our website. This notice was last updated on 1st April 2025. This notice is set out in 9 sections:

1. Who we are.
2. What information we collect (including where we collect it from) and how we use it.
3. Sharing your information, and our relationship with other parties.
4. Legal basis for use of your information.
5. International data transfers.
6. Retaining your information.
7. Security of your information.
8. Your legal rights, including your right to access a copy of data we hold.
9. Our contact details.

1. Who we are: First Call Group Limited.

The following list are examples of our business interests. We are a Consumer Credit / Finance Broker. In carrying out these activities, we act as Data Controller, meaning we determine the way in which your data is used (as described in this privacy notice). We have appointed a Data Protection Officer, who is responsible for overseeing use of Personal Data by us. You may contact the Data Protection Officer with any queries relating to the processing of your Personal Data by us, and to exercise your data protection rights (see section 8 below). Contact details for the Data Protection Officer are set out at section 9 below.

2. Information we collect and how we use it.

2.1 Taking out a loan from our business partners or lenders. You may also purchase a policy which is underwritten by our business partner, but for which we process and service your claims (see section 2.2). In these circumstances, our business partner will collect and share some of your Personal Data with us for us to underwrite and administer your loan (where we arrange the lender) and to provide you with relevant services if you make a complaint. These details may include but may not be limited to:

– Name (of customer and any related individuals under the agreement) – Address and contact details – Date of Birth – Lenth of loan and amount you borrowed

2.2 Making a complaint or requesting a service You may contact us by telephone or email:
– Make a complaint about your finance agreement or product purchased on finance; or
– Request a specific service under an existing service-only contract; or – Request a pay-on-use service (and enter into a new service-only contract under section 2.1 above).

First Call Group Limited is a specialist UK based consumer credit broker authorised by the Financial Conduct Authority: FCA Number 753324. First Call Group Limited trades using any of the following names, Finance Works, Tap The App, Tap The App For Finance, StayWarm, StayWarmUK, All Members Benefit, Autocomply, The MBC, The Members Benefits Club.

First Call Group Limited Co Number 09538137 Tel:- 0191 249 8188

2.3 Other use of our website and social media We may collect other personal details from users of our website or our social media accounts, for example users who send us queries, enter our competitions, or are involved in other activities run by us within this context. We may use such details in order to deal with your enquiry, and to administer the relevant competitions or activities. Note that information provided over social media may also be used and stored by the social media provider, in accordance with its own terms and policies. We may also use cookies or similar technologies to collect website usage information, including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths. We do not, however, seek to relate this information to you as an individual nor combine it with other data relating to you. For further information, please refer to the Cookies Policy. Our website may include hyperlinks to, and details of, third party websites. Subject to our data sharing responsibilities (see section 3 below); we have no control over, and are not responsible for, the privacy policies and practices of third parties.

2.4 Other collection and uses of your Personal Data We may also collect and use your Personal Data as follows:
– We may record calls made to us for the purposes of record keeping, compliance training, quality control.
– We may conduct surveys or ask you for feedback on our products and services and may invite you to take part in focus groups. We use your responses and contributions to these for the purposes of quality control and improvement of our products and services.
– We carry out sanctions checking including to safeguard against fraud and money laundering, and in accordance with Government requirements.
– If you contact us, for example over email, by telephone, by post, or over our website or social media, we may retain your contact details and your communication in order to handle (see Part. 6 – for retention period information) your query and maintain records of communications.
– We maintain records of our activities and services, which may include communications exchanged with you or concerning you.
– We may use your Personal Data in order to handle complaints about our activities, and to assess and manage any potential or actual legal action arising from such complaints.
– We may use some Personal Data for analytical purposes and to assist us in improving our processes, products and services, for example root cause analysis of complaints. We seek to use anonymous data sets for these purposes.
– We may review and enforce your compliance with our policy terms, website terms or other terms relevant to our relationship with you or deal with related enquiries.
– We may use your Personal Data in order to comply with our legal and regulatory obligations (including those imposed by the Financial Conduct Authority), or to protect and enforce our legal rights and those of other individuals.

2.5. Children’s data We do not intentionally offer loans or collect any personal information from children under 18 years of age. We shall seek to cancel a policy or service-only contract, refund the premium or payment and delete the details of such individuals when a parent or guardian notifies us that any personal details have been obtained from their child in this context.

3. Sharing your information and our relationship with other parties

3.1 Providers of services to you
We share your Personal Data with lenders. We will share details such as your name, address or location. These details may include Sensitive Data relevant to the service they are providing, such as the health and vulnerabilities of individuals. We remain responsible for how our providers use your Personal Data for these purposes.

3.2 Business partners Information about your loan and other correspondence with you may be disclosed to our business partners from whom you borrowed money (see section 2.2 above) for their audit purposes.

3.3 Other companies We may share some of your Personal Data with other companies who assist us with certain services, including telephone sales of our broker services and products, call recordings and sanctions checking. These group entities will act on our behalf, and we remain responsible for how they use your Personal Data for these purposes. When a transfer out of the European Economic Area and Switzerland is involved, we will ensure appropriate measures are put in place to safeguard your data. We may also share your details with other companies for the purposes of claims cost management, product improvement, personalization of product offerings and for the prevention and detection of fraud. We may also use the Personal Data for statistical purposes. Those companies will not be able to identify any individual user from the information we provide them. Such transfers shall be covered by the companies BCR (Binding Corporate Rules).

3.4 Other disclosures We may also disclose your Personal Data to the following parties: -Legal authorities or regulatory bodies; -Parties involved with current or prospective legal proceedings, or assisting us to establish, exercise or defend our legal rights. For example, we may share information with our legal or other professional advisers. – Parties with whom you have given us permission to speak about your complaint (including other relevant individuals under a loan).
– Providers of other products and services for them to send you direct marketing communications, to the extent that you have consented to us doing so (see section 2.5 above).
– Other service providers, for example those providing data backup or technology services.
– Other parties to the extent that you have consented to us doing so or where we are otherwise required or permitted to do so by law.

4. Legal basis for use of your information

We collect, use and disclose your Personal Data for the following reasons:
– Collection and use of Personal Data which is necessary for performance of our products or services with you, for example in order to administer, process or apply for a loan handle claims and provide relevant services.
– Collection and use of Personal Data, which is in our legitimate interests, for example to manage our business, handle complaints, provide services, respond to enquiries, maintain records of communications, enforce compliance with our terms and investigate fraud.
– Collection use and disclosure of Personal Data to conduct sanctions checking.
– Disclosure of data in the legitimate interests of the third party who receives it, for example our business partners who audit us or third parties who handle loan applications.
– Collection use or disclosure of data to comply with a legal obligation, for example where our regulator or law enforcement authorities require us to do so.

5. International general Personal Data transfers

In cases where we could be led to transfer your data to a location outside the UK and the European Economic Area, we will ensure your data is given a similar level of protection as required under UK data protection law. Any sensitive personal data shall not be transferred outside European Economic Area without you being informed prior to the transfer.

6. Retaining your information

Your Personal Data shall be retained as long as needed for the authorized purposes listed in the consent form you have signed, or accepted through our websites, or those of our partners, including the relevant purposes specified above. This includes retention of some Personal Data following the end of our relationship with you, especially in order to resolve any potential disputes and for ongoing or prospective legal proceedings, maintain records of our services, and otherwise comply with our legal obligations and defend our legal rights. We undertake to keep your Personal Data safe, confidential, accurate and efficient for the usage duration period hereby authorised. At the end of the retention period, your Personal Data will be anonymised or destroyed. (Please use the contact details at section 9 below if you need further information about our retention periods).

7. Security of your information

We regularly review the technical and organisational security measures we have in place on our information and communications systems in order to prevent the loss, misuse, or unauthorized alteration of your personal information. Communications sent over our website, or using email or social media, rely on the internet which is a publicly hosted network. First Call Group Limited has deployed an adequate procedure to identify and communicate any incident of data breach within a delay of 72 hours and to resolve it within a reasonable delay. Further information about security measures we apply to communications sent by email or over our website is available on request – please use the contact details at section 9 below. You are responsible for keeping the password you use for accessing our website confidential. We will not ask you for your password, except when you log in to our website.

8. Electronic Signature Disclosure

Disclosure Regarding Signing Documents Electronically, Conducting Business Electronically, and Receiving Electronic Documents, Notices and Disclosures.

By utilising the electronic signature product you consent to utilising electronic signatures in lieu of using handwritten or non-digital signatures or paper, to conduct business using electronic communications, and to receive notices, signatures, and disclosures electronically. You are not required by us or by law to consent to any of these things.

If you have consented to receive future electronic signature invitations or other notices, signatures, or disclosures electronically from us, and you want to withdraw that consent, you may email us at finance@autocomply.org

If you do not agree to utilise electronic signatures in lieu of using handwritten or non-digital signatures or paper, please email us regarding the matter.

9. Your legal rights in accordance with data protection laws

You have a right to: –

Obtain a copy of the Personal Data we hold about you, together with other information about how we process it; – Request rectification of inaccurate data, and, in some circumstances, to request us to erase or restrict our use of your data, or otherwise to object to our processing of your data for direct marketing purposes or for reasons relating to your situation; –

Oppose to a processing on your Personal Data; –

Request modification of your Personal Data; –

Request erasure of your Personal Data; –

Receive a copy or have a copy transmitted to another company (portability of data) (in a machine-readable format) of Personal Data which you have provided to us, where we process it electronically based on your consent or that it is necessary for performance of our contract with you (see section 4 above). Such data may be transmitted to another Data Controller (such as another insurance provider); –

Make a complaint about how we handle your data to the Information Commissioner’s Office. Please visit ico.org.uk for further information about how to do this. –

Withdraw any consent which you have given relating to use of your data, at any time. This includes consents to receiving direct marketing communications (see section 2.5 and section 4). Note that there are certain limitations and exemptions to these rights which we may apply depending on the circumstances. Please use the contact details under section 9 below to send us requests to exercise these rights (specifying what you are requesting), or if you would like further information about them.

Legitimate Interest:-

We reserve the right to contact you under our legitimate interest where you are required under the terms and conditions of a product or service sold to you by us or one of our partners, to carry out a service or maintenance in a timely manner and where failure to do so may result in the loss of said product or service, which may adversely affect you. We may earn commission from carrying out these duties, but they are always aimed at ensuring your best interests are central to the contact made.

10. Our contact details

Data Protection Officer, First Call Group Limited,
Address: Unit A James Carter Road, Mildenhall, Bury St. Edmunds, Suffolk, England, IP28 7DE
Email: admin@autocomply.org

First Call Group Limited is authorised by the Financial Conduct Authority: FCA Number 753324.
First Call Group a registered Limited Company No. 09538137

Registered with the Information Commissioners Office, to process personal data. ICO Number ZA535172