- 1.1 Verify you or where relevant your clients identity for security purposes
- 1.2 Sell products to you, or where relevant to your clients.
- 1.3 Provide you or where relevant to your clients with suggestions and potential options on products, services and how to obtain the most from using our company services.
- 1.4 To administer our good governance requirements such as internal reporting, compliance obligations or any administrative requirements.
- 1.5 To develop new products and services and to review and improve current products and services.
1.6 To share information, as needed, with business partners (for example, financial services institutions, including debt recovery agencies, loan processors and funding partners), account beneficiaries, service providers or as part of providing and administering our products and services or operating our business
- 1.7 For management and auditing of our business operations.
- 1.8 To carry out checks at Credit Reference and Fraud Prevention Agencies during the pre‐application and application stages, and periodically after that.
- 1.9 Where it is in our legitimate interests to do so.
- 1.10 Personal information that we will process in connection with our products and services includes for example:
- 4.1 Posting a message on our forum
- 4.2 Tagging an image
- 4.3 Clicking on an icon next to another visitor’s message to convey your agreement, disagreement, or thanks.
- 10.1 To track how you use our website
- 10.2 To record whether you have seen specific messages we display on our website
- 10.3 To keep you signed in our site
- 10.4 To record your answers to surveys and questionnaires on our site while you complete them
- 10.5 To record the conversation thread during a live chat with our support team.
- 22.1 To provide you with goods and/or services you have requested;
- 22.2 To comply with FCA Regulation, other law, including for the period demanded by our tax authorities;
- 22.3 To support a claim or defence in court.
- 22.4 For as long as we have reasonable business needs, such as managing our relationship with you and managing our operations
- 22.5 The information/data may be anonymised or encrypted (or both) at the Companies discretion.
- transfer is necessary for the organisation to carry out a legal contract with you, or one in your interests.
- the data relates to a limited, small number of individuals.
- they are necessary in the legitimate interests of the organisation and are not overridden by your interests.
OUR GDPR PRIVACY NOTICE
The EU General Data Protection Regulation (GDPR) replaces the Data Protection Directive 95/46/EC and was designed to harmonise data privacy laws across Europe, to protect and empower all EU citizens data privacy and to be instrumental the way entities/business across the community approach data privacy, GDPR came into force from 25 May 2018. More information on GDPR can be found on sites such as https://ico.org.uk
In the UK, the Data Protection Bill enshrines the law in the GDPR, making it applicable even if the UK leaves the European Union.
The security of your personal information is very important and Independent Financial Services GB and are committed to protecting the information we collect. We maintain in utmost good faith administrative, technical and physical safeguards designed to protect the personal information you provide or we collect against accidental, unlawful or unauthorised destruction, loss, alteration, access, disclosure or use.
Do you have to provide your personal information to us?
You do not have to provide your personal information to us should you not wish to do so. In the main we are unable to provide you with our products or services if you do not provide certain ‘personal’ information to us. In cases where providing some personal information is optional, we will attempt to make this clear.
Data Protection Officer (DPO)
For the purposes of the General Data Protection Regulation (‘GDPR’), Independent Financial Services GB is the data controller under the Regulation, which means that we determine the purposes and means of processing personal data. We are registered with the Information Commissioner’s Office with registration number: Z8277628.
This is a notice to inform you of our policy about all information that we record about you or your client. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you, or your client, (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.
If there are one or more points below with which you do not agree with or are not happy, you should not engage and to proceed with any transaction with us.
We undertake to preserve the confidentiality of all information you provide to us, and expect that you reciprocate.
Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of you and your clients personal data. We do this now, by requesting that you read the information provided at www.knowyourprivacyrights.org
Except as set out below, we do not share, or sell, or disclose to a third party, any information collected by us:
The basis upon which we process information about you.
The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.
If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process their information.
1. Information we process because we have a contractual obligation
When you/we create a transactional relationship via our website or direct, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us, and where relevant in turn between you and your client/s.
In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.
We may use it in order to:
• Personal contact details (e.g. title, full name, current address, email address and address history)
• Your date of birth and age
• Your nationality (for borrowers)
• Details of beneficiaries or anyone legally authorised to act on your behalf, where applicable
• Records of your contact with us (including telephone number, e‐mail address and IP address)
• Products and services that you hold with us, as well as products and services you have been interested in and consented to ongoing marketing communications
• Information about your employment status (for borrowers)
• Where required, information about your source of income and source of wealth (to comply with anti‐money laundering requirements)
• Payment related information, such as sort code and bank account number and debit card information (to comply with anti‐money laundering requirements)
• In relation to borrowers, personal information obtained from Credit Reference Agencies and Fraud Prevention Agencies including public (e.g. defaults, CCJs) and shared credit history, financial situation and financial history
• Fraud debt and theft information (e.g. details of money you owe, suspected instances of fraud or theft, and details of any devices used for fraud).
We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a service we provide.
If we use it for this purpose, you or your client, as an individual/s will not be personally identifiable
We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
2. Information we process with your consent
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including job opportunities and our products and services, you provide your consent to us to process information, and where relevant that of your client, that may be personal information.
Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.
Except where you have consented to our use of your, and where relevant your clients, information for a specific purpose, we do not use your, or your clients information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.
If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.
We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing us at email@example.com However, if you do so, you may not be able to use our website or our services further and reserve the right to cancel existing policies and contractual obligations in place.
3. Information we process because we have a legal obligation.
We are subject to the law like everyone else. Sometimes, as a company we must process your or your clients' information in order to comply with a statutory obligations.
For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.
This may include you or where relevant your clients’ personal information.
However, ultimately it is your choice as to whether you wish to use our website or company services. Errors and omissions excepted.
4. Information provided on the understanding that it will be shared with a third party
4.1 Our website allows you to post information with a view to that information being read, copied, downloaded, or used by other people.
In posting personal information, it is up to you to satisfy yourself about the privacy level of every person who might use it.
We do not specifically use this information except to allow it to be displayed or shared.
We do store it, and we reserve a right to use it in the future in any way we decide.
Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time.
Provided your request is reasonable and there is no Legal or Regulatory basis for us to retain it, then at our discretion we may agree to your request to delete personal information that you have posted. You can make a request by contacting firstname.lastname@example.org
4.4 We may share information with the following third parties for the purposes listed above:
• Business partners (for example, other financial services institutions and debt recovery specialists)
• Governmental and regulatory bodies such as The Financial Conduct Authority, HM Revenue & Customs, the Prudential Regulation Authority, the Financial Ombudsman Service, the Information Commissioner’s Office and the Financial Services Compensation Scheme
• Other organisations and business who provide services to us such as debt recovery agencies, back up and server hosting providers, IT software and maintenance providers, document storage providers and other suppliers
• Credit Reference and Fraud Prevention Agencies
4.3 We may monitor where permitted by law and we’ll do this where the law requires it, or to comply with regulatory rules, to prevent or detect crime, in the interests of protecting the security of our communications systems and procedures and for quality control and staff training purposes. This information may be shared for the purposes described above.
5. Complaints regarding content on our website or our company services
If you complain about any of the content on our website or in relation to our company services we shall investigate your complaint .
When we receive a complaint, we record all the information you have given to us.
We use that information to resolve your complaint.
We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.
AGENT will follow their formal complaint handling process.
If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.
If we consider reasonable your complaint is vexatious or without any basis, we shall not correspond with you about it, or reseve the right to report you to the police or take counsel on any legal action the company sees suitable.
6. Information relating to your method of payment
We store information about your clients’ debit or credit card or other means of payment when you first provide it to us - with the express consent of you or where relevant your client.
We automatically delete the payment information once all fees have been taken and the payment information is no longer required for the agreed service being provided. (You will be provided with details of any fees before you undertake to use Agent – it is your responsibility to be satisfied as per our terms and conditions of business and information disclosed as part of the transaction).
7. Information about your direct debit
When you agree to set up a direct debit arrangement, the information you give to us is passed to the Lending or Insurance organisation (or related transactional agents) for processing according to your instructions. We do keep a copy.
8. Job application and employment
If you send us information in connection with a job application, we may keep it for up to six years in case we decide to contact you at a later date.
If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for five years before destroying or deleting it.
9. Sending a message to our support team
When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.
We record your request and our reply in order to increase the efficiency of our business to prevent fraud and abuse of services.
We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.
USE OF INFORMATION WE COLLECT THROUGH AUTOMATED SYSTEMS WHEN YOU VISIT OUR WEBSITE
Cookies are small text files that are placed on your computer's hard drive by your web browser when you visit practically all websites. They allow information gathered on one web page to be stored until it is further needed, allowing a website to provide you with a personalised experience, and the website owner with statistics about how you use the website so that it can be improved or gauge interaction.
Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely
Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
11. Personal identifiers from your browsing activity
Requests by your web browser to our servers for web pages and other content on our website are recorded.
We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.
12. Our use of re-marketing
Re-marketing involves placing a cookie on your computer when you browse our website in order to be able to serve to you an advert for our products or services when you visit some other website.
DISCLOSURE AND SHARING OF YOUR INFORMATION
13. Information we obtain from third parties
Although we do not disclose your, or where relevant your clients’, personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use
14. Credit reference
To assist in combating fraud, we or our service providers share information with credit reference agencies.
15. Data may be processed outside the European Union
Our websites are hosted in the United Kingdom.
Accordingly data obtained within the UK or any other country could be processed outside the European Union. Due to the complexity and chain of providers best practice along with common sense safeguards will be put in place with respect to data transferred outside the European Union.
ACCESS TO YOUR OWN INFORMATION
16. Access to your personal information
16.1 At any time you may review or update personally identifiable information that we hold about you.
16.2 To obtain a copy of any information that is not provided on our website you may send us a request to DPO email@example.com
16.3 After receiving the request, we will tell you when we expect to provide you with the information, and (in certain situations) whether we require any fee for providing it to you.
17. Removal of your information
If you wish us to remove personally identifiable information disclosed to us, you may contact DPO at email: firstname.lastname@example.org, by phone or writing.
This may limit the service we can provide to you, or where relevant your client.
It may be necessary to retain certain information where it is required for Regulatory purposes (for example as required by the Financial Conduct Authority). We are Authorised by the Financial Conduct Authority (FCA), and as such may be required to process data to comply with the FCA’s rules. This may mean that we are unable to erase your data in certain circumstances, if to do so would result in a breach of the FCA’s record keeping requirements.
18. Verification of your information
When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information
19. Use of site by children
We do not sell products or provide services for purchase by children, nor do we market to children.
20. Encryption of data sent between us
Our company websites use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and for encryption. Look for a closed padlock symbol, https or other trust mark in your browser’s URL bar or toolbar.
21. How you can complain about our policy - Complaints
All individuals have the right to lodge a complaint with the Information Commissioner’s Office (ICO) if they have concerns about how we have handled their information. Any concerns can be reported via the ICO’s website https://ico.org.uk/concerns or over the telephone, by calling 0303 123 1113.
22. Retention period for personal data
Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:
24. Transferring your data outside the EU
We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website, or by means of our compliance documents namely Terms of Business. We advise you to print a copy for your records.
RISK WARNING: Think Carefully Before Securing Other Debts Against Your Home. Your Home May be Repossessed If You Do Not Keep Up Repayments on Your Mortgage Or any Other Debt Secured On It.
Independent Financial Services (GB) is authorised and regulated by the Financial Conduct Authority (FCA)
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