This website (the "Site") is owned and operated by William Ellis Sinclair. The Policy relates to this Site. It is set out to meet the requirements of the UK's Data Protection Act 2018 (the "Act") and it relates to the collection, protection, disclosure and use of personal data belonging only to living individuals.
This Policy, together with our Website Terms and Conditions, sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data. By visiting our Site or using any of our services you are accepting and consenting to the practices described here.
1.1. We may collect and process the following data about you:
1.1.1. information that you may provide by filling in online forms and registration forms (including registering for products, services or newsletters) on the Site. This includes information provided at the time when you complete an online Application Form on our Site, or request further services. We may also ask you for information in the event you report a problem with our Site;
1.1.2. correspondence, or a record of it if you should contact us, together with your contact details and our responses;
1.1.3. surveys that we use for research purposes, which we have asked you to complete, although you do not have to respond to them;
1.1.4. details of your visit to our Site, and the resources that you access. See also Clause 6.2.
2.1. We are a credit broker and in order to provide our service we share your information with our lenders, brokers and/or third parties (the "Partners") to assist you in finding a suitable financial services product.
2.2.1. When you complete our online Application Form on our Site we process this data on the basis that we have a legitimate interest in processing this data.
2.2.2. The legitimate interests basis is defined by Article 6(1)(f) of the GDPR as being where 'processing is necessary for our legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect your personal data which overrides those legitimate interests'.
2.3. As part of the service that we provide, we may contact you regarding your search for the product or service that you have asked us to help you with, unless you have requested that we do not do so.
2.4 In addition, we may also send you information regarding related products or services using the contact information that you supplied to us as part of your application. This is an essential part of the service that we provide to you.
2.5.1. The basis in which we are able to contact you is called 'soft opt in', which applies when you have previously entered information on our Site and provided your information to us. This is useful for the majority of customers as it enables us to share related products and services similar to which you had requested previously.
2.5.2. We offer a simple way for you to 'opt out' from us contacting you both when you submit an online Application Form on our site and in every message we send to you via this link optout.cc.
3.1. We use information held about you in the following ways:
3.1.1. to process and submit your Application Form to our Partners;
3.1.2. to provide you with the best possible service;
3.1.3. to ensure that content from our Site is presented in the most effective manner for you and for your computer; and
3.1.4. to notify you about changes to our products and services.
3.2. In addition to the above, we may disclose your personal information to third parties:
3.2.1. to prepare or send any communications to you, or to assist us in connection with any of our administrative or business functions, or in the provision of any of our services to you;
3.2.2. if the Company or substantially all of its assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
3.2.3. if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Website Terms and Conditions and other agreements; or to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
3.3. It is sometimes necessary for the Company to transfer information held about you to lenders and brokers based outside of the European Economic Area. The Eighth Data Protection Principle of the Act restricts the transfer of personal data to a country outside the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects. By submitting your Application Form you consent to this transfer. You may withdraw your consent at a later date by writing to us at [email protected] or William Ellis Sinclair, 8A Dunraven Place, Bridgend, CF31 1JD.
3.4. When you submit an Application Form you will be required to consent to the passing of your information to Partners who may use it to assess your creditworthiness and contact you directly in respect of your application for credit. If you do not wish to receive such communications, then do not submit an Application Form via this Site.
3.5. If you wish to opt-out of receipt of marketing communications from us at any time you may do so by emailing us at [email protected], writing to us at William Ellis Sinclair, 8A Dunraven Place, Bridgend, CF31 1JD or visiting optout.cc.
3.6. Any information or statistics relating to our business that we disclose to others shall not identify you personally. We may, for example, perform statistical analysis of the behavior of the users of our Site in order to measure interest in the various areas of our Site and to inform advertisers as to how many consumers have seen or "clicked" their advertising banners. This information, and any other general information about our users that we share with advertisers and other partners, will not disclose personal information about you.
4.1. We share your personal data with our Partners who require it so we can provide the credit broking service you have signed up for.
4.2. A list of the categories of recipients who might receive your personal data are listed below:
4.3. Lenders and credit brokers on our panel
4.3.1. By completing our secure online Application Form you have accessed our credit broking service and permitted us to use your details to search the market for a loan that meets your individual criteria.
4.3.2. Please be aware that Partners with whom your information is shared may use it for their legitimate business interests to match applications, carry out fraud checks, carry out research such as analysis of market trends and customer demographics and to customise and develop the product/service which they may offer to you or other individuals in the future. Most lenders might use this for up to twelve months.
4.4.1. Credit Reference Agencies (CRAs) and Fraud Prevention Agencies (FRAs)
4.4.2. By using our service you are also agreeing that our Partners can use Credit Reference Agencies (CRAs) and Fraud Prevention Agencies (FRAs) to assess your credit.
4.5.1. Alternative Product Providers
4.5.2. If we are unable to match you with a suitable lender we may share your personal data with providers of credit and financial products. These include, but are not limited to, credit reporting and credit scoring providers and online digital savings vouchers or discount cards.
4.6.1. Regulatory bodies
4.6.2. We may need to disclose your personal data to regulatory bodies such as the Financial Conduct Authority, Information Commissioner's Office or any other applicable regulatory, government, compliance or law enforcement agency. This may be to investigate complaints, for tax purposes or for the prevention and detection of crime.
4.7.1. Service Providers
4.7.2. We may share your personal data with companies who assist us in providing our service to you such as telecommunication services (for email and SMS communication) and technology services for the operation and maintenance of our Sites. Access to your personal data by these service providers is limited to the information reasonably required for them to perform their function. We take steps to help ensure that service providers keep your personal data confidential and comply with our privacy and security requirements.
4.8.2. We may also disclose your personal data if required or permitted to do so by law or in connection with legal proceedings or in connection with the sale or transfer of our business.
4.9. Lenders, credit brokers, and alternative product providers with whom we may disclose your information in order to assist you in choosing a suitable financial services product. These include, but are not limited to, the following:
4.10. You can obtain a complete list of third parties with whom we may disclose your data by contacting us at the address listed below.
5.1. All information you provide to us is, as far as reasonably practicable, stored on our secure servers. Any financial information, such as credit/debit card numbers will be encrypted using SSL and 3-D Secure technology. We ask you not to permit anyone to use your name.
5.2. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.
5.3. We will retain your information securely stored for a reasonable period or for as long as the law requires.
6.1. We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our Partners. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.
6.2. We use only "Session cookies" on this Site to enable it to function; we do not store cookies on your device. For more information about session cookies please click here.
6.4. You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to complete your Application Form on this Site. For more information click here.
6.5. The Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011 requires that cookies can be placed on a computer only where the user has given their express consent. Your use of this Site places only "Session Cookies" on your device. For more information click here.
7.1. Our Site may, from time to time, contain links to and from the websites of our Partners and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
7.2. We will store and process your information on our computers and in any other way we consider appropriate. By "your information" we mean personal and financial information that we obtain from you when you complete an Application Form for a loan.
7.3. We will use your information to provide our services, for research, assessment and analysis to develop and improve our services to you and other customers and to protect our interests.
7.4. You have the following rights regarding the processing of your personal data, given to you through legislation. You can contact us about any of them by emailing us at: [email protected] or by writing to us at: William Ellis Sinclair, 8A Dunraven Place, Bridgend, CF31 1JD. Any access request will be free of charge.
7.4.2. The right of access. You have the right to obtain confirmation that your data is being processed and to have access to that personal data.
7.4.3. The right to rectification. You have the right to have your personal data rectified if it is incorrect or incomplete.
7.4.4. The right to erasure. You have a right to be forgotten, or to have your personal data erased and to prevent processing. The right is not absolute and in certain circumstances this may not be possible.
7.4.5. The right to restrict processing. You have the right to block or suppress the processing of your personal data. This does not stop the storing of your personal data, as it may be required to restrict processing in the future.
7.4.6. The right to data portability. You have the right to obtain and reuse your personal data for your own purposes across different services in a safe and secure way, without hindrance to usability.
7.4.7. The right to object. You have the right to object to processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling); direct marketing (including profiling); and processing for purposes of scientific/historical research and statistics.
7.4.8. Rights in relation to automated decision making and profiling.You have a right to object to automated decision making, to express your point of view, ask for human intervention, and to be provided with an explanation of the decision with your option to challenge it. The right is not absolute and is not applicable for the entering into a consumer credit agreement.
7.4.9. The right to withdraw consent. If you have given us explicit consent to process your personal data you have a right to withdraw that consent at any time, including but not limited to the removal of consent to be contacted by third party marketers.
7.4.10. The right to lodge a complaint with a supervisory authority. You have the right to lodge a complaint with us directly and/or with a supervisory authority. In the UK the relevant authority is the Information Commissioner's Office (ICO). You can find their contact details at ico.org.uk/global/contact-us.
7.5. Calls between you and us may be recorded and/or monitored.
7.6. We may give information about you and how you manage your account to the following:
7.6.1. people who provide a service to us or are acting as our agents on the understanding that they will keep the information confidential. If they are located in another country, we will make sure that they agree to apply the same levels of protection as we are required to apply to information held in the UK and to use your information only for the purpose of providing the service to us;
7.6.2. anyone to whom we transfer or may transfer our rights and duties under this agreement;
7.6.3. we may also give out information about you if we have a duty to do so or if the law allows us to do so.
7.7. Otherwise we will keep information about you confidential.
8.1. When you submit an Application Form you confirm that all the information you have given is true and complete. When you submit an Application Form you authorise our Partners to check the following records about you and others:
8.1.1. our own;
8.1.2. those at credit reference agencies (CRAs); and
8.1.3. those at fraud prevention agencies (FPAs).
8.2. Our Partners will make checks such as are deemed necessary to assess your application for credit.
8.3. If you tell us that you have a spouse or financial associate, we will link your records together so you must be sure that you have their agreement to disclose information about them. CRAs also link your records together and these links will remain on your and their files until such time as you or your partner successfully files for a disassociation with the CRAs to break that link.
8.4. If false or inaccurate information is provided and fraud is identified, details will be passed to fraud prevention agencies.
8.5. Law enforcement agencies may access and use this information.
8.6. We and other organisations may also access and use this information to prevent fraud and money laundering, for example, when checking details on applications for credit and credit-related or other facilities.
8.7. We and other organisations may access and use from other countries the information recorded by fraud prevention agencies.
8.8. Your data may also be used for other purposes for which you give your specific permission or, in very limited circumstances, when required by law or where permitted under the terms of the Data Protection Act 2018.
8.9. Our lenders with whom we share your information may use it for their legitimate business interests to match applications, carry out fraud checks, carry out research such as analysis of market trends and customer demographics and to customise and develop the product/service which they offer to you or other individuals in the future. Most lenders might use this for up to 12 months.
9.2. If the Policy changes in the future, we will not use the personal information you have submitted to us under the Policy in a manner that is materially inconsistent with this Policy, without your prior consent.
10. Contacting us
10.1. If you wish to contact us, you can email us at: [email protected] or by write to us at: William Ellis Sinclair, 8A Dunraven Place, Bridgend, CF31 1JD.
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