Legal Information

Company Name: Titan Vehicles Ltd
First Registered: England
Registered Number: 11032986
Registered Address: Unit 2A Upper Moor End, Mamble, Kidderminster, DY14 9JD
VAT Registration Number: GB282 8394 65

Titan Vehicles Ltd is authorised and regulated by the Financial Conduct Authority (812492 ). Not all types of business undertaken are authorised and regulated by the Financial Conduct Authority. Titan Vehicles Ltd is a credit broker and not a lender.

OUR POLICY

At Titan Vehicles Ltd we pride ourselves on being leading UK car leasing brokers whilst offering the best combination of advice, products, competitive pricing and outstanding service.

Our Aim is best set out in our missions statement:

“Our mission is to be the best leasing and fleet management company in the UK by developing our employees personally and professionally, reducing fleet costs and the carbon footprint of our clients, the result of which is ethical and sustainable growth.”

CONSUMER DUTY POLICY

Background

The Financial Conduct Authority (FCA) has published its Policy Statement and final rules (PS22/9) together with Finalised Guidance (FG22/5) for a new Consumer Duty (‘the Duty’). The Duty will set higher and clearer standards of consumer protection across financial services and require firms to act to deliver good outcomes for retail customers (“Consumers”).

The FCA have implemented the Duty in response to their view that financial markets do not always work effectively to provide adequate levels of protection for Consumers, increased complexity in the market has the potential to harm Consumers, and the current economic climate means that Consumers require greater protection.

The Duty is made up of an overarching principle and new rules regulated firms will have to follow. It will mean that Consumers should receive communications they can understand, products and services that meet their needs and offer fair value, and they get the support they need, when they need it.

The structure of the Consumer Duty:

• A new consumer principle that requires firms to act to deliver good outcomes for retails customers.

• Cross-cutting rules providing greater clarity on our expectations under the new principle and helping firms interpret the four outcomes.

• Rules relating to the four outcomes we want to see under the consumer duty. The represent key elements of the firm-consumer relationship which are instrumental in helping to drive good outcomes for customers. These outcomes relate to: products and services, price and value, consumer understanding, consumer support and how the duty links to the FCA objectives.

The Consumer Duty includes the addition of a new Principle for Business: “a firm must act to deliver good outcomes for retail customers”.

The Duty includes three cross-cutting rules which develop and amplify the standards of conduct expected from firms, requiring them to:

1. Act in good faith towards retail customers

2. Avoid causing foreseeable harm to retail customers

3. Enable and support retail customers to pursue their financial objectives

It also includes four outcomes, which provide rules and guidance in key areas:

Outcome 1: Products and services

Outcome 2: Price and value

Outcome 3: Consumer understanding

Outcome 4: Consumer support

Preparations within Titan Vehicles Ltd

Our Board approved our implementation plan in October 2022, appointed a Consumer Duty Champion and a dedicated project team was created.  We have since completed a gap analysis across each of the four outcomes and the entire customer journey. Work is underway and progressing well, and we are on track to comply fully with the Duty requirements by 31st July 2023.

Highlights of the work completed / underway are as follows:

Products and Services & Price and Value

• We have carried out fair value assessments on all products which include Consumers within the target market. These are available here on our website. Assessments of fair value and target markets will be completed at least once every 12 months.

• We have undertaken a review of the data we use to assess fair value and are seeking to enhance our analysis and process where we can.

• We are currently in the process of assessing our product governance framework and making improvements where required.

Consumer Understanding & Consumer Support

• A review of all ‘Consumer touchpoints’ has taken place, looking at business activity within Titan Vehicles Ltd that impact customer outcomes.

• Our policy wording and communications are being assessed for clarity to ensure we give our customers the information they need, at the right time, in ways they can understand.

• Other areas of focus include SLAs, customer vulnerability, complaints and customer feedback. Process improvements and adjustments are being made as required.

Other Key Activity

• We are reviewing the wording of relevant terms of business agreements and binders to ensure they support the requirements of the Duty.
• We are reaching out to our business partners (third party service providers and other key stakeholders) to address responsibilities and other Consumer Duty focus areas.

• Should you have any questions about our Consumer Duty activity, please speak with your Titan vehicles Ltd representative.

COMPLAINTS PROCEDURE

Our business is covered by the Financial Ombudsman Service. Any financial services complaints we cannot settle may be referred to the Financial Ombudsman Service. A copy of our complaints handling procedures can be supplied upon request.

If you have a complaint or would like a copy of these procedures please contact us:

Titan Vehicles Ltd, Unit 2A Upper Moor End, Mamble, Kidderminster, DY14 9JD
Email: Sales@Titanvehiclesltd.com

If you wish to make a complaint, please make contact by writing to us at the above details. We will send you a letter acknowledging receipt of your complaint within 7 days of us receiving the complaint.

We will then investigate your complaint. We will then either: Invite you to a meeting to discuss your complaint. We shall do this within 14 days of sending you the acknowledgment letter. Following the telephone conversation/meeting we will write to you to confirm what took place and any solutions we have agreed with you; or send you a detailed written response to you complaint to include suggestions for resolving the matter. We will do this within 21 days of sending you the acknowledgment letter.

We will aim to have a full resolution within an 8 week deadline providing third party supplies are obtained within said timeline.

If you are still not reasonably satisfied with the response after following the above steps you must contact us again and we will arrange for a review of the decision. We will contact you within 21 days of receiving you request for a review, confirming our final position on your complaint and explaining our reasons.

If after making a complaint to us you are still unhappy and feel the matter has not been resolved to your satisfaction, please contact the Financial Ombudsman Service “FOS” – http://www.financialombudsman.org.uk

Please note that FOS may not be able to deal with complaints from business customers. Further details about our complaints procedure and FOS are available on request.

WHO REGULATES US?

Titan Vehicles Ltd is authorised and regulated by the Financial Conduct Authority. Our firms reference number is 812492.

You can verify this on the Financial Conduct Authority’s Register by visiting the FCAs website: https://register.fca.org.uk/  or by contacting them on 0300 500 8082

Please note that Titan Vehicles Ltd is a credit broker and not a lender.

Other services we offer may not be regulated by the Financial Conduct Authority, however the Financial Ombudsman Services has now been extended to handle some complaints under the Consumer Credit Act.

The Financial Conduct Authority (FCA)
The FCA is the independent watchdog that regulates financial services. The document is designed to be given to consumers considering buying certain financial products. You need to read this important document. It explains the service you are being offered.

Credit Facilities
We are a credit broker and not a lender. We offer a variety of finance products from a limited panel of lenders. We will provide you with information on Credit Agreements-Hire Purchase / Conditional Sale & Lease Purchase / Contract Hire / Lease Agreements. A list of our lenders is available on request.
We will advise and make recommendations for you after we have assessed your financial needs and circumstances. You will then need to make your own choice about how to proceed. We are not an independent financial advisor.

Remuneration
You are entitled at any time to request information regarding any commission which we may receive as a result of arranging your finance.

VULNERABLE CUSTOMER POLICY

Introduction

The purpose of this policy is to ensure that the operations of Titan Vehicles Ltd do not have any negative impact upon vulnerable customers.

For the purposes of this policy vulnerable customers are customers and prospective customers whose ability or circumstances require us to take extra precautions in the way that we conduct business and provide our services to ensure that they are not disadvantaged in any way.

What is a vulnerable customer?

The Financial Conduct Authority (FCA) defines a vulnerable customer as “someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care.”

The FCA expects firms like ourselves to treat customers fairly when we are dealing with people with vulnerable circumstances.

Identifying a vulnerable customer

Our staff are trained to identify vulnerable customers so we can take extra steps to assist outside of our standard procedures. However, it is not always possible to recognise these characteristics. Therefore, if you believe you may fit the criteria for a vulnerable customer, please read this policy and notify us immediately of your particular needs.

Signs we look out for:

• Do they ask us to speak up or speak more slowly?
• Do they understand what we are saying, or do they miss important bits?
• Do they appear confused about what is being offered?
• Do they ask any unrelated questions?
• Do they keep wandering off the point in the discussion and talk about irrelevant things or things that do not make sense?
• Do they keep repeating themselves?
• Do they take a long time to answer questions or say that someone else deals with these things for me?
• Do they have a language barrier?
• Do they say they do not understand their statements, a previous phone conversation or recent written correspondence?

Vulnerability groups

We recognise that certain groups of customers may be vulnerable. Whilst not all customers in these groups may be vulnerable, we will consider a customer’s individual circumstances where a potential vulnerability is identified. These groups may include, but are not restricted to:

• Customers with communication difficulties (including learning difficulties and English not being their first language, dyslexia).
• A customer with a reduction in physical or mental capacity.
• Customer with health issues – illness, whether physical or mental illness, severe or long term.
• A sudden diagnosis of serious illness to the customer or close family member
• Personal circumstances of the customer — factors such as financial difficulties, bereavement, caring responsibilities, or redundancy.
• The customers age particularly older and younger people. For example, a younger person may be considered inexperienced and the older person may be less technologically able.

Steps we take if we believe a consumer may be vulnerable:

• We speak slowly, clearly and explain fully.
• We are patient and empathise where appropriate.
• We don’t rush as it may sometimes take the consumer time to get relevant information together such as account details.
• We keep on the subject under discussion.
• We do not make assumptions about a consumer’s needs.
• We clarify understanding at every point and always ask if there is anything else, they would like us to explain.
• We ask the consumer to explain to us what they understand the agreement to be.
• We offer alternative types of communication — phone, post, email, in person.
• We do not make assumptions that the person we are dealing with is sighted as they may be unable to read or understand serial numbers or account numbers.
• We do not make assumptions that the person we are talking to can hear everything we say as they may have a hearing impairment.
• We always remember that the person we are speaking to may sometimes be forgetful or overly trusting and believe that a sales representative is always acting in their best interest.
• We understand that some people may be lonely and welcome the opportunity just to talk to someone.
• We give the consumer time to explain their circumstances fully and don’t interrupt or appear impatient.
• We also listen for what is NOT being said for example lack of questions about price, lack of commitment, timing of responses, extended silences.
• We always ask if there is a better time to discuss matters as some people may perform better at different times of the day.
• We ask if there is anyone else they may need to talk to before making the decision.

Prior to forming the contract:

• We ensure that yes is a real agreement not just a “giving in”.
• We ensure that the consumer demonstrates that they have an understanding of the decision they need to make, why they need to make it and that they understand the consequences of making, or not making that decision.
• We ask if they need to discuss the matter with anyone else, or if they would like us to explain anything else, or if there anything else we can do further to help.
• We are always prepared to repeat anything to clarify understanding.
• We do not assume that they fully understand all the implications of the agreement and explicitly and clearly confirm all the important points.
• We ensure that the consumer is not flustered, agitated or in an emotional state when they make a decision.
• We suggest that they talk it through with someone else and offer to contact them when they have had a chance to talk with the 3rd party. If appropriate we suggest that a third person could be present.

Post Contract:

• If we identify communication needs, we store that information so future communication is handled appropriately.
• We record that we are satisfied that the consumer completely understood everything that was discussed.
• We allow consumers to make a personal declaration about their capabilities or communication needs and store this information.
• Any records that are held are with the full knowledge and consent of the consumer and are deleted when the relationship no longer exists in accordance with the Data Protection Act 2018.

If we identify a person who may be in need of specialist advice which we are unable to offer:

• We will signpost to the Debt and Mental Health Evidence Form (DMHEF) where appropriate.

We will refer to or we will seek guidance from an appropriate organisation such as:

• Samaritans Carers Trust CAB
• Age UK Alzheimer’s Society Mind
• StepChange Money Advice Trust MALG
• Macmillan Cancer Support

Sources of guidance we refer to:

• Equality Act 2010
• Mental Capacity Act 2005
• CONC 7.9 Contact with customers (incorporating previous OFT Guidance): Mental Capacity Guidance
• Irresponsible Lending Guidance Debt Management Guidance
• MALG Consumers with mental health problems & debt MALG 12 steps to treating vulnerable consumers fairly.

Contact Us

To discuss this policy in more detail or to register yourself as a vulnerable customer, please contact us using the information below:

Email — sales@titanvehiclesltd.com

Phone — 01299 266901

In Writing — Titan Vehicles Ltd, Unit 2A, Upper Moor End, Mamble, Kidderminster, DY14 9JD

 

TERMS OF USE

Titan Vehicles Ltd and its affiliates provide this site to you subject to the following terms and conditions. Please read the terms and conditions carefully – if you visit our site you are deemed to have accepted them. Please leave the site if you do not.

VEHICLE DATA

The vehicle data displayed on the website is supplied by our manufacturer, finance and dealer partners. Whilst every effort is made to verify and ensure the accuracy of the data, the information should only be used as a guide and no decision should be made to purchase, hire or lease a specific vehicle without verification of the latest data from either the manufacturer or franchised dealer.

All images on the website are for illustration purposes only.

DELIVERY TIMEFRAMES

Delivery timeframes quoted are subject to credit clearance, deposit payments being received along with all signed order forms and contracts being received by Titan Vehicles Ltd.

PRICING

Contract Hire payments are subject to VAT at the prevailing rate. Personal Contract Hire rates are inclusive of VAT. All quotations include Road Fund Licence for the contractual period. The servicing element (if applicable) includes all routine maintenance, servicing, tyres, batteries, exhausts and necessary repair cost with the exception of accident damage. All pricing is correct at the time of print, unless changes in vehicle prices announced by the manufacturer or any fluctuations in FHBR. These figures do not constitute an offer. All applications subject to credit approval. Errors and Omissions excluded.

All contracts brokered by Titan Vehicles Ltd are subject to a £150 + VAT documentation/handling fee.

PRIVACY POLICY

Your privacy is important to us. Please review our Privacy Policy, which also governs your visit to our site, in order to understand our practices. See our Privacy policy.

DISCLAIMER

Whilst this site has been compiled in good faith, Titan Vehicles Ltd makes no warranty or representation that the use of this website will be uninterrupted or error free or that this site or the server that makes it available are free of viruses or bugs. To avoid any doubt, articles and other information are for general guidance only and should not be specifically relied on without taking advice.

LIMITATION OF LIABILITY

To the full extent permissible by law, Titan Vehicles Ltd assume no responsibility or liability for any information published on this website and further disclaim all liability in respect of such information. In particular, Titan Vehicles Ltd hereby excludes all liability for any claims, losses, demands or damages of any kind whatsoever in relation to any information, content or advertisements.

WHAT WE COLLECT AND WHAT WE USE IT FOR

We collect personal information when you use our services and the panels and any surveys on this site. We may also receive information about you from our business partners or marketing firms. We ask you for personal data only when it is needed for any services you have enquired about or asked us to provide or for participation in any panels, surveys or other activities in which you are taking part on the site or to respond to your requests for information.

We also receive and record information by tracking user traffic patterns throughout our pages to maintain a record of the movements of visitors to our site such as the page visited and the information, activity or service requested. If you send us e-mail, we will also retain the content of your e-mail and your e-mail address to respond to your message and handle any follow up.

WHAT INFORMATION DO WE SHARE?

There are times when we require to share the personal information we learn from you with other parties. However, the information we hold on our clients is an important part of our business and it is not our business to sell or rent this information to others. We may however share personally identifiable information about our clients in the following situations:

Agents
We may use other companies and individuals to perform functions in certain situations on our behalf such as moderating a discussion panel, running a survey, making enquires about you or your company or passing your information to a credit reference agency (see Data Protection). Other examples could include providing marketing assistance and data analysis and providing customer service. These agents only have access to information required for that purpose and may not use it for any other purpose.

Subsidiaries and Strategic Partners
We share certain information with subsidiaries under our control and also with our affiliated businesses but we only share client information relating to a transaction with that business.

Data Protection – Fair Processing Notice
In considering your application we or our financiers will search your record at credit reference agencies. They will add to your record details of our searches and this will be seen by other organisations that make searches. Searches will also be made in respect of directors and partners of firms applying for credit. 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.

If you are a joint applicant or if you have told us of some financial association with another person, you are declaring that you are entitled to:

• Disclose information about your joint applicant and anyone 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. It is important that you give us accurate information. We or our financiers will check your details with fraud prevention agencies and if you give us false or inaccurate information and we suspect fraud, we will record this. These records will be shared with other organisations and 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, prevent money laundering and fraud. Fraud prevention agency records will also be shared with other organisations to help make decisions on motor, household, credit, life and other insurance proposals and insurance claims, for you and members of your household.

SUBJECT ACCESS REQUEST

The Data Protection Act and Sixth Data Protection Principle gives individuals the right to access any personal information that a company may hold about them. Personal information refers to any data held by a company relating to a living individual, which would allow that individual to be identified from the data. If you would like to make a subject access request for any personal information we may hold about you, you can do so by writing to the following address: Data Protection Officer, Titan Vehicles Ltd, Unit 2A Upper Moor End, Mamble, Kidderminster, DY14 9JD. Please note there will be a £10 processing fee for this request that can be payable by cheque or bank transfer.

BUSINESS TRANSFERS

We are continually trying to expand and improve our business and we may sell or buy businesses or assets in these transactions. Client information is generally one of the transferred business assets in these situations and in the event that Titan Vehicles Ltd or substantially all of its assets are acquired, client information may be one of the transferred assets. Where we deal with other companies etc as above, we require those companies to comply with our privacy policy. We may also require to release information where required to do so by law. Other than in the above situations we will give notice on this site when your personal information might be shared with third parties and you will have the opportunity to decide not to share that information.

SECURITY

All information is received by us and retrieved using secure technology. In order to provide a safe and secure environment for your personal information we use up to date technology with a view to protecting that information against loss, misuse or unauthorised alteration. We only allow authorised personnel access to personal information you provide. Creating passwords that cannot be easily accessed, guessed or reproduced by unauthorised persons can enhance the effectiveness of our safety measures.