Our Cookie Policy

Cookie Policy

Last updated: 19 February 2026

This Cookie Policy applies to the following First Response Finance Limited (“FRFL”, “we”, “our”, “us”) websites:

• www.firstresponsefinance.co.uk (Main website)
• app.firstresponsefinance.co.uk (Customer Account Portal)
• careers.firstresponsefinance.co.uk (Careers and recruitment platform via Teamtailor)
• dealer.firstresponsefinance.co.uk (Dealer Portal)

It replaces all earlier versions and reflects the requirements of the UK General Data Protection Regulation (UK GDPR) and the Privacy and Electronic Communications Regulations (PECR).

What are cookies?

A cookie is a small text file that is placed on your device when you visit a website. Cookies allow the site to remember your device, store preferences, maintain security, enable essential functions, and improve your browsing experience.

Cookies may be:

• Session cookies – deleted when you close your browser
• Persistent cookies – remain until they expire or are removed
• First party cookies – set by FRFL
• Third party cookies – set by external providers such as YouTube or Teamtailor

Other tracking technologies we use

Alongside cookies, we also use:

• Local storage
• Session storage
• IndexedDB (e.g., YouTube video storage)
• Service Worker caches
• Device identifiers

Under PECR, these technologies are treated the same as cookies.
We only use them when strictly necessary or with your consent.

Examples include:

• YouTube video playback storage
• Teamtailor chat window status (MESSENGER_STATE)
• 123FormBuilder partial form saving

How we use cookies

We use four categories of cookies:

Strictly Necessary Cookies
These are required for our websites to function and for you to use secure services.
Consent is not required.

Functional / Preference Cookies
These remember your settings and improve your experience.
Consent is required.

Statistics / Analytics Cookies
These help us improve site performance and understand how users navigate our pages.
Consent is required.

Marketing Cookies
These are used for advertising and embedded content (e.g., YouTube).
Consent is required.

Managing your cookie preferences

When you visit any FRFL website, you will see a cookie banner giving you the option to:

• Accept all cookies
• Reject all non essential cookies
• Choose specific preferences

Non essential cookies will not be set unless you give clear, affirmative consent.

You can update your choices anytime using the “Manage Cookies” link at the bottom of our websites.

Third-party cookies

Some website functions rely on third party services such as:

• YouTube (video playback)
• Google reCAPTCHA (security)
• Cloudflare (network protection)
• Teamtailor (Careers platform)
• 123FormBuilder (forms)

These providers may set cookies and other tracking technologies that process personal data outside the UK.

We ensure appropriate safeguards are in place, such as:

• The UK Extension to the EU–US Data Privacy Framework
• Standard Contractual Clauses (SCCs) with the UK Addendum
• The International Data Transfer Agreement (IDTA)

International Data Transfers

Some of our service providers process data in the United States, including:

• YouTube (Google LLC)
• Google reCAPTCHA
• Teamtailor
• 123FormBuilder

Where data is transferred outside the UK, we rely on:

• The UK Extension to the EU–US Data Privacy Framework,
• SCCs approved by the ICO,
• or the IDTA.

In line with the Schrems II ruling, we inform you that US authorities may lawfully request access to data processed by US service providers. We minimise what personal data is shared and ensure our providers commit to challenge unlawful requests

Legal basis for using cookies

• Strictly Necessary cookies — Legitimate Interests & PECR exemption
• Functional / Preferences cookies — Consent
• Statistics / Analytics cookies — Consent
• Marketing cookies — Consent

Cookie Table (Condensed, public friendly)

Below is a simplified table showing the cookies used across all FRFL websites.

A full technical register is available on request.

Strictly Necessary Cookies

Functional / Preferences Cookies

Statistics / Analytics Cookies

Marketing Cookies

Updates to this Policy

We may update this Cookie Policy to reflect changes in:

• technology
• legal requirements
• our service providers
• how our websites operate

The “Last updated” date will always reflect the most recent version.

Contact us

Operational Risk Team (Data Protection)
First Response Finance Limited
Phone: 0115 946 6368
Email: dataprotection@frfl.co.uk

First Response Finance is a responsible vehicle finance lender, and all decisions are made in the best interests of the customer; based on credit scores, status, and income at the time of application. We'll never approve an application if we believe you might struggle with repayments.

Get independent advice on money, finance products, debt management and budgeting through Citizens Advice and MoneyHelper.