1. Important information and who we are
Purpose of this privacy notice
Reparo Finance Limited ("We") are committed to protecting and respecting your privacy.
Data Protection Officer/Manager
We have appointed a data protection officer (DPO) or a data protection manager (DPM) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Our full contact details are:
Reparo Finance Limited
28 Eaton Avenue, Matrix Office Park,
Buckshaw Village, Chorley,
Lancashire PR7 7NA
Telephone number: 0161 451 5712
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified and, given the nature of our work, the types of data which we may process can be quite varied. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, passport and/or other official identification details or documents, or CCTV images. We will use a third- party provider to conduct AML checks and will obtain your written consent for this purpose. The results of such checks will be included with this category.
• Contact Data includes home or business address, email address and telephone numbers.
• Financial Data includes bank account details and any other financial information provided such as management accounts. We may also investigate your creditworthiness either for our benefit or to decide whether to enter into an agreement with you.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Usage Data includes information about how you use our website, marketing emails (if applicable) and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
• Performance or Relationship Data including your relationship with our staff, assessments of your performance when working with or for us in relation to any matter.
• Other Personal Data or History includes your hobbies, family, lifestyle and social circumstances, education and employment background (such as positions, roles and responsibilities in your current or previous roles).
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
In certain circumstances, we may collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, political opinions, trade union membership, information about your health data, or any dietary requirements (for example if you attend a meeting or event with us)). We will not specifically collect any information about criminal convictions and offences. However, in the event that such information comes into our possession, we will process such data in accordance with the legal parameters of UK law. Any such data will be processed insofar as it is relevant to our client’s instructions to us or for the purpose for which the data was provided to us (for example, if your dietary requirements are provided to ensure they are met during an event at which you are our guest).
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel an arrangement you have with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
• Our Website With regard to each of your visits to our site we may automatically collect the following information:
1) Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
2) Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
3) Direct interactions. You may give us your Identity, Contact and Financial Data including when you provide anti-money laundering documents, provide information to enable us to carry out professional services to you as a client, provide bank account details to enable a payment to be made to us, provide contact details to us to enable you to attend an event, give us your business card, make a complaint, or contact us by post, phone, email, through our website ‘Contact Us’ form or otherwise.
4) Indirect interactions. In the performance of our professional services to our clients, we may obtain your data indirectly through our client or a third party.
5) Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources such as Companies House, Land Registry, Linkedin and other web-based platforms, as well as third parties involved in matters in which we act for our client, or from work referrers.
4. How we use your personal data We use information held about you in the following ways:
1) to process your enquiries relating to, and applications to obtain, our products and services (including without limitation our processing of such information and (if appropriate) the disclosure of relevant information to certain third parties, for example, credit reference agencies);
2) to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
3) to provide you with information about other products and services we offer that are similar to those that you have already purchased or enquired about;
4) to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data;
5) to notify you about changes to our services;
6) to ensure that content from our site is presented in the most effective manner for you and for your computer.
7) to process enquiries and applications (as appropriate) from you in relation to our products and services;
8) to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
9) to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
10) to allow you to participate in interactive features of our service, when you choose to do so;
11) as part of our efforts to keep our site safe and secure;
12) to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
13) to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
We may use your Identity, Contact, Marketing and Communications Data to send you marketing materials, to the extent that we are permitted to do so by law. Direct marketing may include invitations to seminars and/or networking events, financial updates, newsletters (by email), and other news or information about us. You will receive marketing communications from us if you have requested information from us or used our services and, in each case, you have not opted out of receiving that marketing. You always have the right to unsubscribe from any marketing, as set out below.
You can ask us to stop sending you marketing messages at any time by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of the financial services we provide to you or other transactions.
5. DISCLOSURE OF YOUR PERSONAL DATA
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We may share your information with selected third parties including:
• Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
• Analytics and search engine providers that assist us in the improvement and optimisation of our site.
• Credit reference agencies for the purpose of assessing your application for our products and services (including but not limited to assessing your credit score). For further information see Use of Your Personal Data by Reparo Finance Limited and Credit Reference and Fraud Protection Agencies
• National Fraud Database managed by Cifas.
We may also disclose your personal information to third parties:
• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
• If Reparo Finance Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
6. WHERE WE STORE YOUR PERSONAL DATA/INTERNATIONAL TRANSFERS
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using TLS technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
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 information, we will use strict procedures and security features to try to prevent unauthorised access.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information we cannot guarantee the security of your personal information transmitted to our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
8. Data retention - How long will you use my personal data for?
We will only retain your personal data 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. We therefore will keep your personal information for a minimum of six years or so long as is reasonably necessary for the purposes for which it was obtained.
To determine the appropriate retention period for personal data, we consider 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 some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. YOUR RIGHTS
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting Sharon Bryden, Operations Director us at 28 Eaton Avenue, Matrix Office Park, Buckshaw Village, Chorley, Lancashire PR7 7NA or by emailing firstname.lastname@example.org.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers 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.
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
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 your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
ACCESS TO INFORMATION
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. of a number of access requests are made there may be a fee payable no more than £25.00 to meet our costs in providing you with details of the information we hold about you.