1 What is the purpose of this document?
1.1 This privacy notice describes how we collect and use personal information about you in accordance with the applicable data protection legislation.
1.2 We recognise the importance of this data and the risks related to its possession of such data. We are committed to protecting the privacy and security of your personal information.
1.3 We are a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. To comply with data protection legislation and best practice we are required to notify you of the information contained in this privacy notice.
1.4 This notice sets out your rights under applicable data protection laws as well as our commitment to you regarding how we treat your data. We may update this notice at any time.
1.5 It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
3 Data protection principles
We will comply with applicable data protection law. We are committed to applying the highest standards, which means that the personal information we hold about you must be:
3.1 Used lawfully, fairly and in a transparent way.
3.2 Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3.3 Relevant to the purposes we have told you about and limited only to those purposes.
3.4 Accurate and kept up to date.
3.5 Kept only as long as necessary for the purposes we have told you about.
3.6 Kept securely.
4 The kind of information we hold about you
4.1 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
4.2 There are “special categories” of more sensitive personal data which require a higher level of protection (as detailed in paragraph 10).
4.3 We may collect, store, and use the following categories of personal information about you:
4.3.1 Full Name.
4.3.2 Date of Birth.
4.3.3 Place of Birth.
4.3.4 Passport information, including number, date of issuance and expiry.
4.3.5 Email Address.
4.3.6 Phone Number.
4.3.7 Full residential Address.
5 How is your personal information collected?
5.1 We collect personal information about you through your completion of the application form.
6 How we will use information about you
6.1 We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
6.1.1 Where we need to perform the contract we have entered into with you.
6.1.2 Where we need to comply with a legal obligation.
6.1.3 Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
6.1.4 When verifying the information supplied for the purposes of the application.
6.1.5 When completing and submitting the application.
6.2 We may also use your personal information in the following situations, which are likely to be rare:
6.2.1 Where we need to protect your interests (or someone else’s interests).
6.2.2 Where it is needed in the public interest.
7 Situations in which we will use your personal information
7.1 We need all the categories of information in the list above (see paragraph 4) primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases, we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests.
7.2 Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
7.3 The situations in which we will process your personal information are listed in Schedule 1, together with the purpose or purposes for which we are processing or will process your personal information.
8 If you fail to provide personal information
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as processing a transaction on your behalf of), or we may be prevented from complying with our legal obligations (such as to ensure you are properly identified for the progress of anti-money laundering legislation).
9 Change of purpose
9.1 We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
9.2 Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
10 How we use sensitive personal information
10.1 “Special categories” sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:
10.1.1 With your explicit written consent for the purposes of carrying out our contract with you as part of the application process
10.1.2 Where we need to carry out our legal obligations.
10.2 Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public. We may also process such information about you in the course of legitimate business activities with the appropriate safeguards.
11 Do we need your consent?
We do not need your consent if we use your personal information in accordance to carry out our legal obligations or exercise specific rights under the law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.
12 Automated decision-making
12.1 Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:
12.1.1 Where we have notified you of the decision and given you 21 days to request a reconsideration.
12.1.2 Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.
12.1.3 In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.
12.2 If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.
12.3 You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
12.4 We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
13 Data sharing
13.1 We may have to share your data with third parties, including third-party service providers.
13.2 We require third parties to respect the security of your data and to treat it in accordance with the law.
13.3 We may transfer your personal information outside the EU.
13.4 If we do, you can expect an equivalent degree of protection in respect of your personal information.
13.5 Why might you share my personal information with third parties?
We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so. This may involve us sharing your information with:
13.5.1 Third party service providers who help us operate our business;
13.5.2 Credit card companies and direct debit operators; and
13.5.3 The United Kingdom Government.
If the make-up of the our changes or such changes are proposed we may share your data with third parties to allow us to sell, merge or transfer aspects of our business or acquire or merge into other businesses. We will only do this if they agree to keep your data to the same standards we have set for holding your data. Following such a change other parties may use your data in line with these standards.
13.6 Which third-party service providers process my personal information?
“Third parties” includes third-party service providers (including contractors and designated agents). The following activities are carried out by third-party service providers:
a. credit card companies and direct debit operators process the payment information you have provided us with; and
b. the United Kingdom Government processes the personal information you provide us with in relation to the application, in order to determine whether your application should be approved.
13.7 How secure is my information with third-party service providers?
All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
13.8 Transferring information outside the EU
We will transfer the personal information we collect about you to the following countries outside the EU:
13.8.1 United Kingdom.
in order to perform our contract with you. There is not an adequacy decision by the European Commission in respect of all of those countries. This means that some countries to which we transfer your data are not deemed to provide an adequate level of protection for your personal information.
However, to ensure that your personal information does receive an adequate level of protection we have put in place binding contract clauses in line with international standards to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the applicable laws on data protection. If you require further information about these protective measures, you can request it from the Head of Data Protection.
14 Data security
14.1 We have put in place measures to protect the security of your information. Details of these measures are available upon request.
14.2 Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
14.3 We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from Head of Data Protection.
14.4 We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
15 Data retention
15.1 We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Retention periods for your personal information are decided by considering the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. In general terms for application information verification and applications we will retain your information indefinitely or for as long as the application and verification process requires.
15.2 In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
15.3 All information from filled in applications that did not result in payment will be deleted within 48 hours.
15.4 If you have any questions regarding data retention, please contact our Data Protection Officer.
We may use your personal information to let you know about those of our products and services we think may be of interest to you. Before doing so we may use your personal information to better understand what services or products you are likely to need or have use for.
If you ask us to stop using your personal information to market to you, we will do so, and you can change this choice at any time.
We use “cookies” on our website, these are small pieces of data that allow us to track which computers visit our website and how.
18 Rights of access, correction, erasure, and restriction
18.1 Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
18.2 Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
18.2.1 Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
18.2.2 Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
18.2.3 Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
18.2.4 Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
18.2.5 Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
18.2.6 Request the transfer of your personal information to another party.
18.3 If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Head of Data Protection in writing.
18.4 No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
18.5 What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
19 Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our Data Officer. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
20 Changes to this privacy notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information
We store personal data in digital format on secure cloud servers and systems hosted in the European Union (EU) and the United Kingdom (UK). Where data is stored on servers located in the US we rely on the Privacy Shield Framework to transfer this information. Access to personal data is highly restricted internally for approved business purposes only. Any personal data processed in paper form are securely filed at our office location in the UK.