Last updated 2nd May 2018
GE Working Capital Solutions LLC and its group affiliated entities (collectively, the “WCS Group”), respect your concerns about privacy. References in this Privacy Notice to “WCS”, “we”, “us”, and “our” are references to an entity within the WCS Group that is responsible for the processing of your personal information.
This notice (“Notice”) describes how we, as Data Controller, will handle, share and protect personal information that you provide, or which we obtain about you.
Click on one of the sections below to find more information:
What does this Notice Cover?
This Notice applies to the personal information we obtain from General Electric Company and its subsidiaries and affiliates in connection with the financial services we provide to such entities. We may collect personal information from third parties, such as credit reference agencies or publicly available sources, as required or permitted by local law.
This Notice describes the types of personal information we obtain, how we may use that personal information, with whom we may share it, and how you may exercise your rights regarding our processing of the information. The Notice also describes the measures we take to safeguard the personal information we obtain and how you can contact us about our privacy practices.
This Notice is limited to WCS and does not apply to personal information obtained through other GE channel websites such as our careers website, which is subject to the Candidate Privacy Notice available at www.GE.com.
What information does WCS collect about me?
We may obtain personal information through the various channels described above. The types of personal information we may obtain include:
• contact information (such as name, address, Tax ID number (Fiscal code and/or VAT code) for you;
• customer payment history;
• financial information (such as payment information, including name, billing address; financial statements; income, expenditure; and credit score).
Please note that providing personal information to General Electric company and its subsidiaries and affiliates is voluntary on your part.
By providing us with personal information you confirm that you have reviewed this Notice and agree to its processing as explained herein.
How does WCS use my personal data?
We may use the personal information we obtain to:
• provide and administer our products and services;
• assess creditworthiness;
• perform data analytics (trend analysis, financial analysis and customer segmentation);
• provide customer support, including relating to complaints and data access requests;
• operate, evaluate and improve our business (such as by administering, enhancing and improving our products and services; managing our communications and customer relationships; and performing accounting, auditing, billing, reconciliation and collection activities);
• verify your identity and protect against and prevent fraud and other unlawful activity, unauthorized transactions, claims and other liabilities, and manage risk exposure and quality;
• conduct investigations and comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our policies and terms; and
• maintain and enhance the safety and security of our products, services, network services, information resources and employees.
We may combine personal information we obtain through various channels for the purposes described above. We may anonymise or aggregate personal information and use it for the purposes described above and for other purposes to the extent permitted by applicable law. We also may use personal information for additional purposes that we identify at the time of collection. We will obtain your consent for these additional uses to the extent required by applicable law.
The legal basis for us processing your personal information, as described above, will typically be one of the following:
• for the performance of a contract with you or a relevant party;
• to fulfil our legitimate business interests;
• to comply with our legal obligations; or
• on the basis of your consent.
We will not use your personal information for marketing purposes; should this position change in the future we will contact you to obtain your consent to receive marketing information from us.
Who does WCS share data with, or transfer data to?
We do not sell or otherwise disclose personal information about you except as described here or at the time of collection.
• We may share personal information within the WCS Group and that of our parent companies within the GE Group for the purposes described in this Notice.
• We may share personal information with service providers we have retained to perform services on our behalf. These service providers are contractually required to safeguard the information and are restricted from using or disclosing the information provided to them except as necessary to perform services on our behalf or to comply with legal requirements.
• We may disclose your information for Capital Market activities for the purposes described in this Notice;
• We may disclose personal information about you (1) if we are required to do so by law or legal process (such as a court order or subpoena), (2) to law enforcement authorities or other government officials to comply with a legitimate legal request, (3) when we believe disclosure is necessary to prevent physical harm or financial loss, (4) to establish, exercise or defend our legal rights, (5) in connection with an investigation of suspected or actual fraud or illegal activity or (6) otherwise with your consent.
We reserve the right to transfer any information we have about you in the event of a potential or actual sale or transfer of all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganisation, divestiture, dissolution or liquidation). In such case, we will require the relevant third parties to provide comparable levels of protection as we provide with respect to the information we share.
Credit Reference Agencies
In order to provide financial services, we will perform credit and identity checks on you with one or more credit reference agencies (“CRAs”). We may also make periodic searches at CRAs to comply with our financial crime compliance program.
To do this, we will supply your personal information to CRAs and they will give us information about you. This will include information about your financial situation and financial history. CRAs will supply to us both public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information.
We will use this information to:
• Assess your creditworthiness in connection with the financial services provided;
• Verify the accuracy of the data you have provided to us;
• comply with our obligations under AML, CTF and other FCC laws, which include:
- to identify and verify identity
- to detect and prevent criminal activity
- to screen and monitor against watchlists including sanctions
• Trace and recover debts.
How does WCS protect my data?
We maintain administrative, technical and physical safeguards, consistent with legal requirements, designed to protect against unlawful or unauthorized destruction, loss, alteration, use or disclosure of, or access to, the personal information provided to us.
Wherever we share personal information we will exercise measures to safeguard it and ensure it is only processed as strictly necessary to fulfil a contractual task or legal obligation.
We may transfer the personal information we collect to, and store such data in, other countries, including the U.S., which may have different data protection laws than the country in which the information was provided. If we do so, we will transfer the personal information only for the purposes described in this Notice. To the extent required by applicable law, when we transfer your personal information to recipients in other countries, we will take measures to protect that information. The GE Group has entered into Binding Corporate Rules governing our handling of personal information of residents of the European Union. For further information about the GE Group’s Binding Corporate Rules, please click here, or visit https://www.ge.com/bcr
How long is my data retained for?
Your personal data is retained in accordance with our Data Retention Policy, which is designed to make sure data is kept for no longer than necessary, and is disposed of where there is no longer a valid reason for the data to be retained.
Data retention periods are determined by taking into account legal limitation of liability periods, agreed contractual provisions, applicable regulatory requirements and industry standards.
What are my rights?
You have a number of rights available to you when it comes to the processing of your personal data.
You have the right to request a copy of the information that we hold about you. If you would like a copy of some, or all, of your personal information, please email [email protected].
We will not charge you for this service. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information.
We want to make sure that your personal information is accurate and up to date. If you believe the personal data we hold about you is inaccurate you have the right to challenge it. You may ask us to update, correct or erase information you think is inaccurate.
Data Erasure / Objection to processing
You have the right to request your personal data to be deleted or alternatively object to your personal data being processed in certain circumstances. You may ask us to delete or cease to process your data and we will assess your request.
The data held by us is important to ensure compliance with our legal and regulatory obligations or our legitimate interests as a responsible lender, preventing fraud and money laundering, compliance with contractual provisions, and legal liability limitation periods. It will be rare that we do not have compelling, overriding grounds to carry on using the personal data following an objection or request for erasure.
Restriction of Processing
You have the right to request we restrict how we use your personal data. The right is not absolute and we may still continue to process your personal data where certain grounds are established:
• With your consent;
• For the establishment, exercise, or defence of legal claims
• For the protection of the rights of another natural or legal person;
• For reasons of important public interest.
You have the right to receive a copy of your personal data in a structured, commonly used format, and to have your data transmitted to another controller where we are processing such data for the purposes of performance of a contract, or with your consent.
This right does not apply where we are processing data for other purposes, such as for compliance with a legal obligation or for another legitimate interest.
How do I make a complaint?
If you have a complaint regarding our processing of your personal data, please email [email protected].
We will respond to your complaint within 30 days. If you are not satisfied with our response you may have the right to file a complaint with a supervisory authority or other governmental regulator.
How do I withdraw consent?
If your provided your consent to us processing your personal data, you may withdraw consent you previously provided to us or object at any time to the processing of your personal information on legitimate grounds relating to your particular situation, and we will apply your preferences going forward as appropriate.
It is important to note that data provided to us by you is largely processed for the performance of a contract, for adherence to legal requirements and for other legitimate interests. There may be limited instances where we process data based solely on your consent and as such we may not be able to comply with any request to cease to process this data.
You may submit an application to withdraw consent by email at [email protected].
Does WCS use automated decision making?
We do not use personal data provided by you for automated decision making or profiling activities.
How do I contact WCS?