You can visit our website without telling us who you are or revealing any information about yourself. However, if you give us any personal information about yourself or others we promise to treat it securely, fairly and lawfully. We are committed to protecting your privacy.
When we ask you for personal information online it will only be in response to you actively applying for or using one of our online products or services.
If you are giving us information for the first time we shall explain the purposes for which we shall use it at that time. If you are a customer already, this explanation will be in your account terms and conditions.
We may use personal information you provide for the purpose of providing more relevant content to you.
What are cookies?
A “cookie” is a small text file that’s stored on your computer, tablet or phone when you visit a website.
Some cookies are deleted when you close down your browser. These are known as session cookies. Others remain on your device until they expire or you delete them from your cache. These are known as persistent cookies and enable us to remember things about you as a returning visitor.
To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org. Alternatively, you can search the internet for other independent advice on cookies.
If you delete cookies relating to this website we will not remember things about you, including your cookie preferences, and you will be treated as a first-time visitor the next time you visit the site.
• Provide products and services that you request
• Provide a secure online environment
• Manage our marketing relationships
• Give you a better online experience and track website performance
• Help us make our website more relevant to you.
Here we explain a bit more about each of these types and how you can control their use.
Cookies are essential for us to provide a product or service you have requested and to provide a secure online environment
Without cookies we are unable to provide some products or services that you might request. Other ‘essential’ cookies keep our website secure. Even if you say “No” to cookies on this website we’ll continue to use these ‘essential’ cookies.
Essential cookies are used to:
• Deliver interactive services, such as:
o Product applications
o Quote tools
o Contact systems
• Maintain online security and protect against online fraud
Managing our marketing relationships
Our third party marketing partners may set cookies before you reach our site. If you wish to prevent this type of cookie (sometimes known as a ‘third party’ or ‘analytical’ cookie), you may do so through your device’s browser security settings.
You’ll sometimes see our advertising or special offers on other websites. Cookies provided by the other website or advertising network can tell us how effective this is. For example, if you click on one of our advertisements, the website owner might use a cookie to tell us that you came from their site.
Giving you a better online experience and tracking website performance
You’ll still be able to use most of our online services, but some things might not work as you may expect if you do not allow us to store and access cookies on your device.
These cookies make our online services easier to use and help us to understand how people use our websites. For example, amongst other things they will:
• Remember relevant information as you browse from page to page to save you re-entering the same information repeatedly
We also use this type of cookie to understand how visitors use our online services and look for ways to improve them. For example, a cookie might tell us that lots of people give up on an application process at a particular step – so we can try to make that step easier to use.
Helping us make our website more relevant to you
Enabling us to customise your online experience based upon your individual circumstances, existing product holdings or activities during previous visits to this website. If you select “No”, we won’t be able to tailor your experience.
Customer Privacy Notice
Why should you read this document?
During the course of dealing with us, we will ask you to provide us with detailed personal information relating to your existing circumstances, your financial situation (Your Personal Data). This document is important as it allows us to explain to you what we will need to do with Your Personal Data, and the various rights you have in relation to Your Personal Data.
What do we mean by “Your Personal Data”?
Your Personal Data means any information that describes or relates to your personal circumstances. Your Personal Data may identify you directly, for example your name, address, date or birth, National Insurance number, bank details. Your Personal Data may also identify you indirectly, for example, your employment situation, or any other information that could be associated with your cultural or social identity.
In the context of providing you with assistance in relation to your business finance requirements Your Personal Data may include:
- Title, names, date of birth, gender, nationality, civil/marital status, contact details, addresses and documents that are necessary to verify your identity
- Employment and remuneration information, (including salary/bonus schemes/overtime/sick pay/other benefits), employment history
- Bank account details, tax information, loans and credit commitments, personal credit history, sources of income and expenditure, family circumstances and details of dependents
- Any pre-existing mortgage/credit products and the terms and conditions relating to these
The basis upon which our Firm will deal with Your Personal Data
When we speak with you about your credit/finance requirements we do so on the basis that both parties are entering a contract for the supply of services.
In order to perform that contract, and to arrange the products you require, we have the right to use Your Personal Data for the purposes detailed below.
Alternatively, either in the course of initial discussions with you or when the contract between us has come to an end for whatever reason, we have the right to use Your Personal Data provided it is in our legitimate business interest to do so and your rights are not affected. For example, we may need to respond to requests from lenders, insurance providers and our Compliance Service Provider relating to the advice we have given to you, or to make contact with you to seek feedback on the service you received.
On occasion, we will use Your Personal data for contractual responsibilities we may owe our regulator The Financial Conduct Authority, or for wider compliance with any legal or regulatory obligation to which we might be subject. In such circumstances, we would be processing Your Personal Data in order to meet a legal, compliance or other regulatory obligation to which we are subject.
The basis upon which we will process certain parts of Your Personal Data
Where you ask us to assist you with for example your credit/finance needs, we will record and use your data in order to make enquiries of finance providers in relation to finance products that may meet your needs and to provide you with advice regarding the suitability of any product that may be available to you.
How do we collect Your Personal Data?
We will collect and record Your Personal Data from a variety of sources, but mainly directly from you. You will usually provide information during the course of our initial meetings or telephone conversations with you to establish your circumstances and needs and preferences in relation to credit and finance requirements. You will provide information to us verbally and in writing, including email.
We may also obtain some information from third parties, for example, credit checks, and searches of information in the public domain such as the voters roll. If we use technology solutions to assist in the collection of Your Personal Data for example software that is able to verify your credit status. We will only do this if we have consent from you for us or our nominated processor to access your information in this manner. With regards to electronic ID checks we would not require your consent but will inform you of how such software operates and the purpose for which it is used.
What happens to Your Personal Data when it is disclosed to us?
In the course of handling Your Personal Data, we will:
- Record and store Your Personal Data in our paper files, mobile devices and on our computer systems (websites, email, hard drives, and cloud facilities). This information can only be accessed by employees within our Firm and only when it is necessary to provide our service to you and to perform any administration tasks associated with or incidental to that service
- Submit Your Personal Data to Finance Providers/Commercial Lenders both in paper form and on-line via a secure portal. The provision of this information to a third party is essential in allowing us to progress any enquiry or application made on your behalf and to deal with any additional questions or administrative issues that lenders and providers may raise.
- Use Your Personal Data for the purposes of responding to any queries you may have in relation to any credit/finance product you may take out, or to inform you of any developments in relation to those products and/or polices of which we might become aware
Sharing Your Personal Data
From time to time Your Personal Data will be shared with:
- Finance providers and Commercial lenders
In each case, your Personal Data will only be shared for the purposes set out in this customer privacy notice, i.e. to progress your credit/finance enquiry and to provide you with our professional services.
Please note that this sharing of Your Personal Data does not entitle such third parties to send you marketing or promotional messages: it is shared to ensure we can adequately fulfil our responsibilities to you, and as otherwise set out in this Customer Privacy Notice.
Some of our lenders may process Your Personal Data outside of the European Economic Area.
Security and retention of Your Personal Data
Your privacy is important to us and we will keep Your Personal Data secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard Your Personal Data against it being accessed unlawfully or maliciously by a third party.
We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us, such as not sending confidential information over unprotected email, ensuring email attachments are password protected or encrypted and only using secure methods of postage when original documentation is being sent to us.
Your Personal Data will be retained by us either electronically or in paper format for a minimum of seven years, or in instances whereby we have legal right to such information we will retain records indefinitely.
Your rights in relation to Your Personal Data
- request copies of Your Personal Data that is under our control
- ask us to further explain how we use Your Personal Data
- ask us to correct, delete or require us to restrict or stop using Your Personal Data (details as to the extent to which we can do this will be provided at the time of any such request)
- ask us to send an electronic copy of Your Personal Data to another organisation should you wish
- change the basis of any consent you may have provided to enable us to market to you in the future (including withdrawing any consent in its entirety)
How to make contact with our Firm in relation to the use of Your Personal Data
If you have any questions or comments about this document, or wish to make contact in order to exercise any of your rights set out within it please contact:
Stuart Austin, Director
If we feel we have a legal right not to deal with your request, or to action, it in different way to how you have requested, we will inform you of this at the time.
You should also make contact with us as soon as possible on you becoming aware of any unauthorised disclosure of Your Personal Data, so that we may investigate and fulfil our own regulatory obligations.
If you have any concerns or complaints as to how we have handled Your Personal Data you may lodge a complaint with the UK’s data protection regulator, the ICO, who can be contacted through their website at https://ico.org.uk/global/contact-us/ or by writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.