Terms and Conditions

Our customers are entitled to a high level of service; unfortunately, from time to time things can and do go wrong. When they do, we will make every effort to resolve and handle your complaint as quickly and amicably as possible.

Whether your complaint is about any of the services relating to David Spear Commercials, our website, general customer service or pre and post-delivery of a vehicle either through David Spear Commercials or our appointed agent or supplying dealer, we would like you to tell us the full details of your complaint so we can put things right.

Help us to understand your complaint

Understanding the nature of your complaint that can be made by, or on behalf of an eligible complainant; that may refer to what the complainant has suffered, or may suffer, for example could be financial loss, material distress, material inconvenience or advice given

• Please provide clear details of the nature of your complaint
• Steps you have already taken to try to resolve the complaint that have not been addressed
• What steps would you like us to take to resolve your complaint.
• In your own interest, you should keep copies of the information submitted for your records.

Initial Process

The complaint is first considered by the Sales Representative handling your order or your initial enquiry (unless the complaint relates to that individual). We aim to resolve your complaint straight away or within 3 working days to your full satisfaction. If you send us a complaint by email, we will usually respond to you by your email.

Should the complaint relate to the individual please contact the General Manager Geraint Yeo on 01495 309098 or email: geraint@david-spear.com who will aim to resolve your complaint straight away or within 3 working days to your full satisfaction.

Complaint Procedure

Our General Manager Geraint Yeo will always assist you to resolve your grievance where possible and can be contacted by writing letter/email and send to David Spear Commercials Ltd, Crown Business Park, Dukestown, Tredegar. NP22 4EF or by Email: geraint@david-spear.com. Alternatively you can call him on 01495 309098

How will we handle your complaint

Depending up on the complexity and nature of your complaint we aim to resolve your complaint straight away, if we are unable to do so we will ensure you receive an acknowledgement of progress in writing within 5 working days, and why we have not been able to do so, along with information on who is dealing with your complaint. We will contact your regularly until your complaint has been resolved.

If you are still not satisfied

If we cannot agree an acceptable resolution to your complaint within 8 weeks, we will write to you giving our reasons for the delay or provide a letter detailing our final response to your complaint.

Final Response

The outcome of your complaint investigation will be communicated to you outlining and explaining our final position in writing in respect of your complaint. You also have the legal right to refer our final response decision to the Financial ombudsman./complaints within 6 months from the date of the final decision.

The FOS provides free service along with a mechanism for resolving disputes which is a simple, informal and accessible alternative to the courts. Their address is: The Financial Ombudsman Service (FOS), Exchange Tower. LONDON E14 9SR ombudsman./complaints Tel: 0800 023 4567 (free), or 0300 123 9123 (costs no more than calls to 01 and 02 numbers)

You may also refer your complaint to the bvrla conciliation service by completing their complaint form and submitting it via email to complaint@bvrla.co.uk or via post to

BVRLA
River Lodge
Badminton Court
Amersham
HP7 0DD

Tel: 01494 545711
Fax: 01494 434499

A conflict of interest means any financial decision that is made that could be deemed as not being fair due to a possible influence from a related party, that could significantly impair the objectivity of an individual or create an unfair competitive advantage for any person or organisation.

If the Company’s interests’ conflict with those of a Client there is potential for Client detriment.

For example, regarding recommendation or the supply to a Customer of a BMW via BMW London*, such potential conflicts should be declared by the Company representative in the following manner dependent upon the situation;

“I need to declare a conflict of interest - the Managing Director of BMW London is a friend of mine.” Or “Our Company has a shareholding interest in BMW London” or “Because our Company has an interest it may be deemed that we are advising you that due our close links with BMW London, this could have an adverse effect on the service we provide or recommend to our Customers.”

Our Company’s Conflict of Interest Policy is to disclose links with any group or organisation to our Clients that could possibly be seen to have an adverse effect when it comes to satisfying our Customers’ needs and/or the service David Spear Commercials provides.

Provider relationships that may influence where business is placed

Provider relationships that may influence where business is placed could apply to (albeit not exclusively) either of the following:

1. The payment of higher commission rates, gifts or other incentives, that may relate to or influence the Company in placing your business with one provider where another provider could be more suitable for our Clients’ needs.
2. Situations where two or more of our Customers are involved within a transaction which could also result in conflict against each other.

The Company ensures that its services are fully independent and does not accept benefits that create ties to specific providers.

The Company documents any significant hospitality that may be received, and all Company staff refer any incentives to senior Directors or management for approval where significant.

Should the Company deem that any of supplier or Client relationships may cause a Conflict of Interest, this is declared to the Client.

Conflict of Interest Controls

The Company has regular audits and reviews with regard our providers that flag up any instances that may be cause for a conflict of interest. In this event, they are investigated along with any other anomalies.

The Company’s staff are fully trained and aware of our policies and will ensure that Customers’ interests are put before any other considerations.

Should the Company deem any instant where there could be a possible conflict between Clients or suppliers, the Company will act impartially and make Clients aware of facts and situation in order that they can decide if they wish to continue with the Company’s services.

Personal Contract Hire and PCP vehicle finance is rapidly expanding and becoming one of the most popular methods of acquiring new vehicles for personal consumers. Personal Contract Hire and PCP vehicle finance are classed as regulated consumer related products that are protected by the 1974 Consumer Credit Act including Personal Contract Hire, although it is essentially a fixed term hire agreement.

Before being able to enter into any form of agreement, whether it is regulated or not, you will require lenders (usually major finance companies and contract hire companies) to agree to offer you the relevant credit account before you are able to proceed with your vehicle order.

David Spear Commercials (acting in its broking capacity) specialise in ensuring our customers get the best available deals on all aspects of Personal Contract Hire and PCP finance.

In this guide, we set out to provide transparency to what is involved in obtaining credit and your rights with reference to the data provided by you under the Consumer Credit Act 1974, relating to personal details provided to obtain personal leasing and finance credit acceptance.

So, let’s take a generalised look at what is usually required in order to be eligible to obtain credit acceptance for regulated Personal Contract Hire and PCP (Personal Contract Purchase). It is important to remember that while there are guidelines lenders may follow, there are no guarantees to what the decision may be, and they may agree or refuse credit on terms they deem to be relevant, as responsible lenders.

Standard criteria for credit acceptance

Financers are responsible lenders that require financial information that demonstrates the customer’s affordability and ability to pay. To demonstrate this, standard information required for private individuals usually includes:

• Three years or more address history (proved through utility bills, etc)
• Three years or more employment history
• Applicants should be registered to vote at address given

In some instances, wage slips or bank statements from the last three months can be requested; this is in order to prove the ability to pay and the income levels of the applicant.

A standard credit check is carried out, usually through Experian or Equifax. County court, defaults or bankruptcy usually mean automatic account rejection, but may be considered by non-status finance funders.

Proofs of identity required

To avoid identity fraud, document signatories must provide proof of identity; this is a full UK driving licence with photo ID (an old-style licence must be accompanied with your passport).

Personal Contract Hire Eligibility

Personal Contract Hire is available to employees opting out of the company car scheme, or with company car allowance, and to employees who can demonstrate that they are able meet the relevant credit criteria requirements.

PCP (Personal Contract Purchase) Eligibility

PCP (Personal Contract Purchase), Lease Purchase and general Hire Purchase are usually offered by mainstream finance companies, and available to all employees who can demonstrate that they can meet their credit criteria requirements.

Credit account applications

David Spear Commercials (acting in its broking capacity) provide credit details to lenders (finance companies) provided by you to obtain credit acceptance for the vehicle/goods detailed on your pre-contract order.

Credit references

Lenders (finance companies) may use credit reference agencies to obtain further information about you.

You have the right to request any information we hold about you (acting in our broking capacity); these details can be obtained by writing to us and upon receipt, we will provide you with the relevant details within seven working days. We will also provide you with the details of any lender/credit reference agency which we have shared your details with during negotiations/applications for information about the financial standing of the customer, and information received from the lender.

Credit account cancellation

You have the right to obtain any information we hold about you (acting in our broking capacity) and can request we remove your details from our records by writing to us. Upon receipt, we will remove your records within 28 working days and provide you with the details of any lender/credit reference agency which we have shared your details with during negotiations/applications for information about the financial standing of the customer, and information received from the lender.

Consumer credit account acceptance

David Spear Commercials (acting in its broking capacity) provide credit details to lenders (finance companies) provided by you to obtain credit acceptance; vehicle pre-contract orders can only be processed after credit acceptance. Lenders (finance companies) may request further information to process an account application.

Further information examples

Requests for further information may include bank statements, payslips, proofs of address/previous addresses. Lenders (finance companies) may also agree account acceptance to profiles that add further security to their asset, such as an increased down payment and/or shorter finance term. David Spear Commercials (acting in our broking capacity) will use our best endeavours to obtain account acceptance to suit your requirements and to that specified on your pre-contract order.

Consumer credit account refusal

David Spear Commercials (acting in its broking capacity) provide credit details to lenders (finance companies) provided by you to obtain credit acceptance and use our best endeavours to obtain credit acceptance to suit your requirements, and to that specified on your pre-contract order.

Lenders (finance companies) may refuse account acceptance based on information that cannot be made available to David Spear Commercials within our broking capacity.

To obtain these details, please write to us, and upon receipt, we will provide you with the relevant details within seven working days. This includes details of the lender/credit reference agency which we have shared your details with during negotiations/applications relating to obtaining credit acceptance on behalf of the customer. You may contact the lender (finance company) directly to obtain the reasons relating to the details of their credit decision.

Terms:

David Spear Commercials Limited may also be referred to herein as ‘We’ ‘Company’ ‘Us’ ‘Our’ and ‘David Spear Commercials.

Customers and potential Customers may also be referred to herein as ’You’ and ‘Clients’.

Customer Risk Assessment

Customer Risk Assessment

Problem:

Risk Client Product Knowledge

Not understanding how experienced and knowledgeable clients are in terms of financial products and services We offer, and if they have adequate assessment of affordability and clarity in their understanding of the contract.

David Spear Commercials solution - how we will deal with this:

Having identified areas where we consider that problems may arise by each of the potential situations, we have set out and implemented controls to monitor our sales process, and gather feedback from our clients and from ourselves, which will be considered at regular intervals our controls consist in providing adequate information, so clients can make an informed decision as follows.

With Initial contact quotation we provide a full and detailed (IDD) Initial Disclosure Document that provides links to key information that relate to problem areas. We also ensure that clients are provided with all the relevant key information on the products relevant to the client’s quotation.

Misleading leasing promotions

The risks misleading leasing promotions could pose to consumers in our opinion are that the general low pricing in some instances are not in consumers best interests. The risk in our opinion is that the consumer can presume that the advertised price as the total price they pay without giving full consideration to the total affordability and their contractual obligations.

Our solution - how we will deal with this:

David Spear Commercials promote a clear and transparent method of offering vehicle promotions that are 'clear, fair and not misleading' and not miss lead consumers by price offering alone. For further information please view our Financial Promotions Policy.

Vulnerable Persons Policy

The aim of this policy is to outline the practice and procedures for staff who work for the company to contribute to the prevention of detriment to clients who find themselves in vulnerable circumstances. The policy covers all staff areas of work when dealing directly with the customer.

Definition of Vulnerable

We consider a vulnerable consumer to be someone who, due to their personal circumstances, is especially susceptible to detriment, with the most significant detriment occurring when “through the use of consumer credit [they may] get into unmanageable or problem debt.”

The nature of our business makes it unlikely that new customers will be in vulnerable circumstances or that the nature of their circumstance may limit or remove the availability of facilities to the extent that the company might be unable to accommodate their requirements.

However, we remain mindful of the potential for enquiry by such Clients and the potential for any change of circumstance in respect of existing Customers.

Identification of clients in Vulnerable Circumstances

• Mental capacity deficiencies – The FCA provides clear guidance on the identification of mental capacity issues in their Handbook under CONC 2.10.8.
• Underbanked, Financially Unsophisticated –can be identified through interview and credit profile
• Low income – can be identified through interview and credit profile
• In financial distress - can be identified through interview and credit profile

Assessment and Management Risks

David Spear Commercials Limited will not discriminate against clients in vulnerable circumstances by way of adjustment to fees or any refusal to assist purely on the grounds of the client’s circumstance (unless that circumstance creates a situation which is likely to lead to detriment or a risk that removes the availability of any finance or funding facility).

Capacity Issue Risk Mitigation

This section illustrates mitigation actions for Clients with mental capacity deficiencies (for the avoidance of confusion, “competent person” means an individual without the limitation presented by the Client):

• Problem: Language - Client cannot fully understand important features of their agreement with David Spear Commercials Limited, their recommendation or the consequences of that recommendation.

o Solution: Client to instruct a competent person to act as interpreter.

• Problem: Other communication problem created by the disability as detailed above from a client to instruct a competent person to act as interpreter.

- Solution: Client to nominate a reasonable communication medium suitable for their disability.

• Problem: Mental incapacity (temporary) such as intoxication, mental illness, and/or both, plus the potential for reckless disregard for consequence.

- Solution: Client to instruct a competent person to communicate on their behalf. Legal agreement must be reached outside of any period of incapacity. The client should be encouraged to seek independent professional advice.

• Problem: If legal agreement cannot be reached outside of any incapacity.

- Solution: Client must provide “Power of Attorney” for a competent individual to act on their behalf.

• Problem: Mental incapacity (Permanent) as detailed in temporary mental incapacity section plus the possibility that any agreement might be unenforceable as a result of known.

- Solution: Client must provide “Power of Attorney” to a competent individual to act on their behalf.

Responsibilities of David Spear Commercials Limited

1. To ensure staff are aware of this policy and are adequately trained.
2. To support individuals in relation to identified risk and vulnerability.
3. To provide means of reporting any instance where they believe that a client might be in vulnerable circumstance.

The following data privacy policy explains the circumstances in which AVC will collect personal data from you, why it is being collected, how we will use it and to whom we might disclose it to if necessary.

The Data Controller

David Spear Commercials Limited is committed to complying with the UK’s Data Protection law and the EU General Data Protection Regulation (GDPR) for the protection of personal data, as well as the principles of data security in the configuration of our services. If you have any questions about this privacy policy or how we use your personal data, please contact our Data Protection Officer Geraint Yeo

In writing:

David Spear Commercials Limited
Crown Business Park
Dukestown
Tredegar
Gwent
NP22 4EF

By Phone: 01495 309098
By Email: geraint@david-spear.com

What data is being collected and processed?

In order to enter into a brokerage agreement with us, we will collect store and use elements of your personal data. The processing of this personal data is a contractual requirement and is necessary by David Spear Commercials in order to administer your account and to provide the products and services you have requested from us.

When you approach us to engage in our brokerage services, we will ask your consent to collect and process your personal data. Failure to provide this consent and/or personal data may mean we will be unable to execute the contract and will result in termination of our services.

When engaging our brokerage services, you will usually need to disclose to us the following:

• Title
• First name(s), surname or company name (including representation as the case may be)
• Address (street, street number, postal code, city and country/region)
• Email address
• Date of birth
• Telephone and mobile number
• Employment details (employer name, employer address, employment history)
• Monthly income and expenditure
• Bank details (account number, account holder and card number)
• VAT ID number (For Business Contracts)

We will also monitor, record, store and use any telephone, email or other electronic communications with you for training purposes so that we can check any instructions given to us and to improve the quality of our customer service.

Any personal data we collect from you will not be transferred outside the European Economic Area.

Website Cookies

We collect information directly from you in several ways. One way is through our use of “cookies”. Most websites use cookies in order to make them work, or to work more efficiently, as well as to provide information to the owners of the website. They help us to understand how our customers and potential customers use our website so we can develop and improve the design, layout, content and function of the site. Cookies are small text files that are placed on your computer’s hard drive by websites that you visit. They save and retrieve pieces of information about your visit to the website – for example, how you entered the site, how you navigated through the site and what information and documentation was of interest to you. This means that when you go back to a website, it can give you tailored options based on the information it has stored about you on your last visit.

We use cookies generated by WordPress in order to manage user logins and other core administrative features. These are considered essential for the operation of our website.

We also use Google Analytics to track visitor data trends and general usage statistics. We do not collect any personal information via these cookies other than your IP address. This information is automatically deleted after 14 months following your last visit to our website. These are non-essential cookies.

The rules about cookies on websites have changed. If you are uncomfortable with the use of cookies, you can disable cookies on your computer by changing the settings in the preferences or options menu in your browser. You can set your browser to reject or block cookies or to tell you when a website tries to put a cookie on your computer. You can also delete any cookies that are already stored on your computer’s hard drive. However, please be aware that if you do delete and block all cookies from our website, parts of the site may not work. Likewise, you may not be able to use some products and services on other websites without cookies.

To find out more about cookies, including seeing what cookies have been set and how to manage and delete them, visit http://www.allaboutcookies.org/

Direct Marketing Communications

The only data we use for direct marketing communications will be the email address used for your initial enquiry and any subsequent communications. We may from time to time use this information to email you any vehicle special offers we may be promoting. You will be asked if you wish to opt into these promotions during you initial enquiry if you decide not to opt in you will never receive any direct marketing emails from us. We will also never sell or disclose your email address to any third parties without your prior consent.

Links to websites of other providers/third parties

There are no links to third party websites or providers on our website.

How long will the data be stored for?

Where possible, David Spear Commercials will take steps to erase any personal data that is no longer necessary for the purposes for which it is collected or otherwise processed, or if you have withdrawn consent for its processing and retention.

As a rule, if you enter into or took steps to enter into a contract with us, we will store the data for period of six years for compliance with our general legal obligations and for the exercise or defence of any legal claims.

Under the GDPR, you have the right to ‘block’ or request the deletion or removal of personal data to prevent further processing. This right to erasure is also known as ‘the right to be forgotten’. Specific circumstances in which you can request the deletion or removal of personal data includes:

• Where the personal data is no longer necessary for the purposes for which it is collected or otherwise processed
• Where you withdraw consent
• When you object to the processing and there is no overriding legitimate interest for continuing the processing
• Where the personal data was unlawfully processed (i.e. otherwise in breach of the GDPR)
• Where the personal data must be erased in order to comply with a legal obligation
• In case a deletion is not possible due to legal, statutory or contractual retention periods, or if it requires disproportionate efforts or prejudices your legitimate interests, the data will be blocked instead of deleted.
• Sharing of data with other data controllers.

David Spear Commercials takes your privacy seriously and the information we hold about you is confidential. We will only disclose it outside David Spear Commercials when:

• You have given us your consent to do so
• It is necessary for the performance of an agreement of which you will be made aware
• In order to obtain professional advice (e.g. legal advice)
• We or others need to investigate or prevent crime (e.g. to fraud prevention agencies)
• The law permits or requires it
• Regulatory or governmental body requests or requires it, even without your consent
• There is a duty to the public to reveal the information

In order to administer your contract, we may need to share some of your personal information with other data controllers. This processing is necessary for the purposes of delivering specific services to you. You agree that we can share or use your personal data with any of our appointed agents or suppliers to allow us to provide you services and products you have asked us to provide you under this agreement, such as to facilitate delivery of your vehicle, to collect the vehicle from you or notify you of a vehicle safety recall. Other data controllers which we may share this information with may include:

• Credit reference agencies (to propose you for vehicle finance)
• The finance provider (to generate the finance agreement)
• The supplying dealer group (to order and deliver the vehicle)
• Claims handling and fraud prevention agencies (to investigate or prevent crime)
• Credit Reference Agencies

In considering your application, we will search your record at credit reference agencies. They will add to your record details of our search and your application and this will be seen by other organisations that make similar searches. On occasion, we may request a credit check with more than one finance provider.

Information held about you by the credit reference agencies may already be linked to records relating to other people with whom you have a financial association. In connection with your application you may be treated as financially linked with them and assessed with reference to any such associated records. Searches may also be made in respect of directors and partners of firms applying for credit.

If you are a joint applicant or if you have told us of some other financial association with another person, or a director of a firm which is applying for a facility you are declaring that you are entitled to:

Disclose information about your joint applicant, fellow directors and anyone else referred to by you.
Authorise us to search, link or record information at credit reference agencies about you and anyone else referred to by you.
The credit reference agency will use a credit scoring system when assessing your application. They will also add to your record details of your agreement with us, specifically the payments you make under it, any default or failure to keep to its terms and any change of address you fail to tell us about where a repayment is overdue.

These records will be shared with other organisations and will be used by us and them to help make decisions about credit and credit related services such as insurance for you and members of your household, trace debtors, recover debt and to manage your accounts. We and the credit reference agencies will also use the records for statistical analysis about credit.

You have a legal right to know the details of credit reference and fraud prevention agencies we use and to whom we pass information about you. To obtain this information, please contact our Data Protection Officer on 01495 309098.

Fraud Prevention

If you give us false or inaccurate information and fraud (in any form) is identified, details will be passed to the fraud prevention agencies. We and other organisations may also share, access and use this information to prevent fraud and money laundering, for example when:

• Checking details on applications for credit and credit related or other facilities
• Managing credit and credit related accounts or facilities
• Recovering debt
• Checking details on proposals and claims for all types of insurance
• Checking details of job applicants and employees
• In addition, law enforcement agencies may access and use this information.

Protecting Your Privacy

In order to protect the personal data collected from you by David Spear Commercials against accidental or deliberate manipulation, loss, destruction or the access of unauthorised persons, technical and organisational security measures are constantly improved as part of our technological development. In addition, our employees, subcontractors and other support staff are obligated to observe confidentiality and data privacy.

Any access to your data that is stored at our company only takes place through an encrypted connection. By using the most up-to-date firewall systems, we provide the best possible protection for your data. Our website, as well as our internal Customer Management System (CMS) is encrypted using a SSL/TSL (Secure Sockets Layer/ Transport Layer Security) connection. SSL is an industry standard and is used by millions of websites in the protection of their online transactions with their customers.

Wherever possible, we have tried to create a secure and reliable website for our users. However, you recognise that your use of the Internet and our website is entirely at your own risk and we have no responsibility or liability for the security of personal information transmitted via the Internet.
We will monitor network traffic from time to time for the purposes of backup and problem solving and in order to ensure that you are not misusing any of the services provided to you.

Breaches

If at any time we become aware that your data has been compromised, or that a breach of our systems and controls has occurred, which has an impact on the security of your data, we will notify the Information Commissioner’s Office, and you, without undue delay.

Subject Access Requests

You have the right to request access to a copy of the personal information that we hold about you. This is also known as a ‘Subject Access Request’. This information is provided to you free of charge however, we can refuse to respond or charge a ‘reasonable fee’ of £10.00 including VAT when a request is manifestly unfounded, excessive or repetitive.

We will provide this information in a structured, commonly used and machine-readable form such as a CSV file. This allows you to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without hindrance to usability.

If you would like to submit a Subject Access Request, please contact our Data Protection Officer in writing to:

Data Protection Officer

David Spear Commercials Limited
Crown Business Park
Dukestown
Tredegar
Gwent
NP22 4EF

By Phone: 01495 309098
By Email: geraint@david-spear.com

We will respond to your request without delay and at the latest, within one month of receipt of your request.

Rectifying or Updating Personal Data

If you believe the personal data, we hold about you is inaccurate or incomplete, you have the right to rectification. You can let us know about any changes to. Where possible, we will also inform any third parties to whom we have disclosed the personal data in question to so they can rectify their records.

We will typically respond to your request within one month, although this can be extended by two months if your request for rectification is complex, such as a Novation or Transfer of Lease.

Withdrawing Consent

You have the right to withdraw your consent for us to collect, process and store your data at any time. If you wish to withdraw your consent, please confirm this in writing to our Data Protection Officer:

By Post:

David Spear Commercials Limited
Crown Business Park
Dukestown
Tredegar
Gwent
NP22 4EF

By Phone: 01495 309098
By Email: geraint@david-spear.com

Please note, by withdrawing consent, AVC may be unable to execute the contract that you have entered into with us and will result in termination of our services. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

Right To Complain

If you have a complaint about any aspect of data protection or if you feel your privacy has been breached by us, we would like to hear from you. To help us investigate and resolve your concerns as quickly as possible, please contact our Data Protection Officer:

David Spear Commercials Limited
Crown Business Park
Dukestown
Tredegar
Gwent
NP22 4EF

By Phone: 01495 309098
By Email: geraint@david-spear.com

If you are unhappy with the final response you have received from us, you have the right to complain to the supervisory authority, the Information Commissioner’s Office (ICO) within three months of your last meaningful contact with us. You can call the ICO on 0303 123 1113 or by visiting their website: https://ico.org.uk/

Our ICO Membership Number is

Changes to The Privacy Policy

Due to the further development of our website, government regulations or the implementations of new technologies, this policy will be reviewed, and may change, from time to time. David Spear Commercials reserves the right to change this data protection information at any time with effect for the future. The revised policy will be posted tour website so that you are always aware of the information we collect, how we use it and under what circumstances we disclose it. We therefore recommend you read the current data protection information again from time to time.

David Spear Commercials Limited is authorised and regulated by the Financial Conduct Authority (FCA) and comply with the guidance set in its handbook.

This handbook sets out business standards we must comply to and how we must deal with any complaints we receive.

The FCA handbook is available for you to view or download from the FCA website, and can be accessed from the following link:
http://fshandbook.info/FS/index.jsp

David Spear Commercials Ltd are fully authorised by the Financial Conduct Authority (www.fca.org.uk). Our registration number is 688883. You can verify this on the FCA’s website or by telephone on 0800 111 6768.

At David Spear Commercials Limited, we are committed to giving you excellent customer service and treating our customers fairly. We are fully dedicated to providing you with the highest standards of client service and advice; We never forget that you have a choice of supplier and are grateful that you have chosen us.

Treating Customers Fairly (TCF) is one of the key principles set by the Financial Conduct Authority to ensure fair treatment of customers, by improving standards across the financial industry.

This Policy provides guidance on how we intend to meet our objectives in ensuring that we look after the best interests of our customers by treating them fairly. It is our intention to offer clear, fair and not misleading information and to handle all matters with integrity, due care, skill and diligence. We will manage fairly any conflict of interest that may arise and provide suitable products at the best value prices for our customers.

David Spear Commercials follow the relevant aspects of the Financial Conduct Authority's six guiding principles on how to engage with our customers, as well as those we like to achieve for ourselves. The six principles are known as the 'Treating Customers Fairly Principles’ and govern how we communicate with customers, the level of service we provide and the fairness of our products and procedures.

The six principles for Treating Customers Fairly

Outcome 1: Consumers can be confident that they are dealing with firms where the fair treatment of customers is central to the corporate culture.

Customer care with David Spear starts from first point of contact, by the correct qualification of their requirements. Our initial disclosure document must be enclosed from first point of contact.

Outcome 2: Products and services marketed and sold in the retail market are designed to meet the needs of identified consumer groups and are targeted accordingly.

David Spear offer a full range of services that must be explained, at point of contact and in writing by way of offering quotation, with all the required key facts examples.

Outcome 3: Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale.

Our commitment to providing clear and precise information is demonstrated in our Order Procedure, from first point of contact we insure we understand the core values of what we are offering to our clients.

Outcome 4: Where consumers receive advice, the advice is suitable and takes account of their circumstances.

Customer circumstances should have been made clear upon initial qualification, if you deem that they may be in Vulnerable Circumstances, you must understand how we deal with this under Risk Assessment.

Outcome 5: Consumers are provided with products that perform as firms have led them to expect, and the associated service is of an acceptable standard and as they have been led to expect.

Again, this falls under our Order Procedure and the steps we take to qualify professionally from initial contact to delivery and beyond.

Outcome 6: Consumers do not face unreasonable post-sale barriers imposed by firms to change product, switch provider, submit a claim or make a complaint.

We have re written the Complaint Procedure to make it easier to understand and communicate how we would handle any complaints, complaint handling is an important part of our compliance procedures and must be dealt with accordingly, of course we will try our utmost to avoid any complaints throughout the sales process.

Our Order Process does not allow us to switch provider of finance, unless we start the sales process over with a new order. Because of the nature of our business this would be an unlikely occurrence, and as so it should not constitute a post-sale barrier.

Requirements in the day to day running of our business

• We continually aim to understand the needs of our clients
• We ensure that the marketing of our products is appropriately targeted, clear, not misleading and highlight the risks/conditions as well as the key features/benefits of a product.
• We make certain our clients understand the risks associated with our services at the outset of an instruction.
• We keep our clients fully informed in a clear and fair manner that is unambiguous and not misleading.
• We ensure our services are delivered with clarity and transparency and do not contain hidden conditions or rely on complex technical definitions.
• Any advice provided will be appropriate and consider the customer's individual needs and circumstances.
• We take our clients' privacy seriously and ensure that our staff are aware of and follow rules in relation to data protection to ensure that clients' details are kept secure and confidential. Our staff undertake regular training to ensure that they remain compliant and are kept up to date with changes in procedures.
• We take any complaint seriously and will deal with any complaints promptly and make improvements to our operations where required.