Last updated: 24th February 2026
1.1 The website www.davidsongray.co.uk (the Site) is operated by Davidson Gray (“we”, “us”, “our”), a company incorporated in England and Wales under company number 08003282. Our registered office is at Mentor House, Ainsworth Street, Blackburn, BB1 6AY.
1.2 We are committed to protecting your privacy and complying with our data protection obligations under the Data Protection Act 2018 (the DPA 2018), the General Data Protection Regulation 2016/679 (the GDPR) and any other applicable UK legislation (together, Data Protection Law).
1.3 When you interact with us or use the Site, we act as the data controller of your personal data. This means that we are responsible for processing your personal data and deciding how to use it. This privacy policy explains the types of personal data we may collect about you when you interact with us, why we collect it, what we use it for and what rights you have over that data. Personal data is any information about an identifiable person. Processing is anything we do with your personal data, including using, storing, sharing and deleting it.
1.4 This policy was last updated on the date shown at the top. We may change this policy at any time by posting an updated version on the Site and will make reasonable efforts to bring any material changes to your attention. You may wish to check it before using the Site as any changes will be effective from the date that they are made.
2.1 If you have any concerns or would like further information about our use of data or this policy in general, please contact our Data Protection Officer (DPO) Nicola Sands via enquiry@davidsongray.co.uk.
3.1 We collect, store and use the types of personal data set out in the table at the end of this policy as well as the below.
3.2 We may collect personal data about you from:
4.1 We will use your personal data for the purposes set out in the table at the end of this policy.
5.1 When we share personal data, we do so in accordance with Data Protection Law. We may share certain personal data, where necessary, with employees, contractors, consultants or advisers, to facilitate sales and for general commercial purposes.
In addition, where necessary, your personal data may be shared:
5.2 We may also provide third parties with aggregated but anonymised information and analytics about our customers. Before we do so we will make sure that it does not identify you.
5.3 Credit Reference and Affordability Checks
To help us assess applications, prevent fraud, and meet our legal and regulatory obligations, we may obtain information about you from credit reference agencies (CRAs). We obtain this information via Creditsafe, which uses its data partner TransUnion to supply consumer credit and identity data.
The information we receive may include data relating to your identity, credit commitments, payment history, and public record information. This data is used solely for legitimate business purposes, including creditworthiness assessment, identity verification, and fraud prevention, in accordance with applicable data protection laws.
Further information about how Creditsafe and TransUnion process your personal data can be found in their respective privacy notices:
5.4 We may transfer personal data to recipients or service providers located outside the UK and/or European Economic Area (EEA).
Where such transfers take place, we ensure appropriate safeguards are in place to protect personal data in accordance with applicable data protection laws. These safeguards may include the use of approved standard contractual clauses, international data transfer agreements, or transfers to countries that have been recognised as providing an adequate level of data protection.
Where such transfers take place, we ensure appropriate safeguards are in place to protect personal data in accordance with applicable data protection laws. These safeguards may include the use of approved standard contractual clauses, international data transfer agreements, or transfers to countries that have been recognised as providing an adequate level of data protection.
6.1 This Site contains links to other websites over which we have no control. We are not responsible for and do not review or endorse the privacy policies or practices of other sites which you choose to access from this Site. We encourage you to review the privacy policies of those other sites, so you can understand how they collect, use and share your personal information.
7.1 We respect your rights to privacy and will respond to requests for access or control over information about you in accordance with Data Protection Law. We may require you to verify your identity before we take any action.
7.2 Depending on the reason we have your personal data, you have a right to:
7.2.1 access the personal information we hold about you (commonly known as subject access);
7.2.2 request that we correct or complete personal information we hold about you that is inaccurate or incomplete;
7.2.3 request that we erase your personal information in some circumstances, or object to our processing it as detailed at paragraph 7.5;
7.2.4 restrict how we use your personal information, in certain circumstances;
7.2.5 request that we provide you with copies of your personal information in a machine-readable format or transfer it across different services; and
7.2.6 where we have asked for your consent to process your data, to withdraw this consent.
7.3 These rights are limited in some situations under Data Protection Law – for example, where we can demonstrate that we are under a legal obligation to process your data.
7.4 If you wish to exercise any of these rights, please contact us using the details in paragraph 2 above.
7.5 Your right to object
You have a right to object to our processing of your personal data and ask us to stop doing so. If we are processing your personal data for direct marketing purposes (which includes profiling to the extent that it is related to such direct marketing) and you object to this, we will stop processing your personal data immediately.
If our processing of your personal data is in the public interest or pursuant to our legitimate interests and you object to this, we will stop processing your personal data unless we have compelling reasons which override your interests, or our use of your personal data is for the establishment, exercise or defence of legal claims.
7.6 We hope that we can satisfy any queries you may have about the way we process your data. However, if there is a concern about how personal data has been handled, a complaint can be made directly to Davidson Gray.
A complaint may relate to how personal data has been collected, used, stored, shared, secured, retained, or otherwise handled. This includes concerns about privacy rights requests, the way personal data has been used, the organisation’s security measures, the handling of a personal data breach, or the contents of this privacy notice.
A complaint can be made using the contact details set out below:
• Email: enquiry@davidsongray.co.uk
• Contact Page form: https://www.davidsongray.co.uk/contact/
• Telephone: 0161 327 3279
Davidson Gray will acknowledge the complaint within 30 calendar days of receiving it and will investigate and respond without undue delay.
If the response is not satisfactory or you have unresolved concerns you also have the right to complain to data protection authorities (in the UK, the Information Commissioner’s Office) or another relevant data protection authority if you are dissatisfied with how we manage your personal data. You can call the ICO on 0303 123 1113 or go to their website: https://ico.org.uk/make-a-complaint/).
8.1 Your personal data will only be kept for as long as necessary for our purposes. Specific periods are set out in the table at the end of this policy.
9.1 We process your personal data in accordance with the following principles:
9.1.1 we process your personal data lawfully, fairly and in a transparent way;
9.1.2 we collect your personal data for specified, explicit and legitimate purposes; any further processing we do is compatible with the original purposes for which for which we collected it;
9.1.3 we only process personal data which is adequate, relevant and limited to what is necessary to achieve the purpose for which it is processed;
9.1.4 we take reasonable steps to ensure that all personal data is accurate and kept up to date where necessary;
9.1.5 we do not store personal data in a form which identifies you for any longer than is necessary for the purposes of processing; and
9.1.6 we process personal data securely and in a way that protects against unauthorised or unlawful processing, accidental loss, destruction or damage.
9.2 When we ask for your personal data we will tell you whether you are required by law or contract to provide it, and what will happen if you do not provide the data.
9.3 Any request for consent to the processing of your personal data will be made directly to you and will include information about why we require the personal data and what will be done with it.
10.1 We will only process personal data when we have a lawful basis for doing that processing. The table at the end of this policy sets out the lawful basis we rely on for each type of data we process.
10.2 We will choose one of the lawful bases in the GDPR to justify how we use your personal data. These are:
10.2.1 Consent: You have given consent to the processing of your personal data for one or more specific purposes.
10.2.2 Contract: The processing is necessary for the performance of a contract with you or in order to take steps at your request before entering into a contract.
10.2.3 Legal obligation: We need to process your personal data to comply with a legal obligation.
10.2.4 Vital interests: The processing is necessary to protect the vital interests of you or another person.
10.2.5 Public interest: Processing is necessary for the performance of a task carried out in the public interest or in the exercise of some official authority.
10.2.6 Legitimate interests: Processing is necessary for the purposes of legitimate interests pursued by us or someone else, except where such interests are overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data. Our legitimate interests include operating our business, fulfilling contractual obligations, ensuring system and data security, preventing fraud, supporting audit and compliance activities, and protecting TransUnion data. These interests are balanced against the rights and freedoms of individuals, with appropriate safeguards in place.
10.3 Provision of Personal Data – the provision of certain personal data is primarily contractual and, in some circumstances, required to meet legal and regulatory obligations.
Personal data is required to:
If you choose not to provide the personal data, we request:
Where personal data is requested for optional purposes, such as marketing communications, providing this data is not mandatory, and you may withdraw your consent at any time without affecting your ability to receive goods or services from us.
10.4 Non-Automated Decision Making and Profiling Making.
We may use automated systems and tools to support certain business processes, such as risk assessment, fraud prevention, affordability checks, identity verification, or record management. These tools may analyse personal data using predefined criteria or rules to generate indicators, scores, or recommendations. However, we do not make decisions that have a legal or similarly significant effect on individuals based solely on automated processing. Any such decisions are subject to meaningful human review. The use of these tools may influence the speed or level of review applied to an application or request, but individuals will not be subject to automatic rejection or adverse decisions without human involvement.
The table below sets out detailed information about our purposes for processing, the basis for processing and the retention period for the personal data.
| Category of personal data | Purpose of processing | Lawful basis for processing | Retention period |
| Browser, device and Site usage information | To improve the Site To protect the Site against fraud To set default options for you, such as language and currency |
Performance of contract Legitimate interest in maintaining our Site |
For three years since you last logged on to the Site |
