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 and, in some cases, your health and family health history (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.

 

Who we are

 

Flexible Finance (UK) Ltd are a trading style of Flexible Finance (UK) which are a credit brokerage based in Newport, South Wales. We act as a broker for our customers. Flexible Finance (UK) are authorised and regulated by the Financial Conduct Authority. FRN 725544 and members of the National Association of Commercial Finance Brokers number M/0075/15.

 

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. Your Personal Data may also identify you indirectly, for example, your employment situation, your physical and mental health history, 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 commercial finance / bridging finance / second charge mortgage / development finance / buy to let mortgage / residential mortgage or business finance requirements, your personal data may include:

 

• Title, names, date of birth, gender, nationality, civil/marital status, contact details, dependants, national insurance number, 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

• Health status and physical and mental health history.

• Any pre-existing investment mortgages / residential mortgages /second charge mortgages / bridging loans / finance agreements and / or insurance products and the terms and conditions relating to these

• Property information regarding properties you own or have an interest in Flexible Finance (UK) will be what is know as the controller and the processer of the personal data you provide to us.

 

How we will use the information about you

 

In order to arrange the products you require, we have the right to use your personal data for the purposes detailed below:

 

1. making lender sourcing decisions

2. for fraud prevention

3. for audit purposes

4. for statistical analysis

5. for credit reference checks

6. for obtaining consent and references from your mortgage company if necessary

7. for obtaining employment and income references if necessary from employers or accountants

8. enabling us to carry out our duties as a credit broker in processing your request for finance

 

Alternatively, either in the course of initial discussions with you or when dealings between us have 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 mortgage 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.

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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.

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We may share your information with and obtain information about you from credit reference agencies or fraud prevention agencies. We will not disclose your information to any company outside of our panel of lenders or affiliated brokers without your consent to do so except to help prevent fraud or if required by law to do so.

 

For further information on how your information is used, how we maintain the security of your information and your rights to access / alter or change information we hold on you then please contact info@flexiblefinanceuk.co.uk.

 

Why we need it

 

We need to know your personal data so we can provide you with an accurate recommendation for your personal circumstances. We will not collect any personal data from you that we do not require in order to provide and oversee our service to you.

 

For processing of data to be lawful under the general data protection regulations Flexible Finance (UK) use

 

1. Consent: the individual has given clear consent for you to process their personal data for a specific purpose.

 

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 conversations with you to establish your circumstances and needs and preferences in relation to commercial finance / bridging finance / second charge mortgage / development finance / buy to let mortgage / residential mortgage or business 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, information from your employer, 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 and ID checks then we will only do this if we have consent from you for us or our nominated processor to access your information in this manner.

 

What we do with it

 

All the personal data we use is controlled by Flexible Finance (UK) in the UK however, for the purposes of IT hosting and maintenance, this information will be located on servers within the European Union. No 3rd parties have access to your personal data unless the law allows them to do so. Your data will be stored on paper-based files in secure cabinets and electronically on our secure database as well as mobile devices and computer systems which are password protected.

 

We will share your details with the lenders on our panel and affiliated companies so that they can process your information allowing Flexible Finance UK to offer suitable and sustainable products they provide to meet your requirements. We may also share your information to obtain your current mortgage information, income / job verification, credit reports any other relevant information required in order to process your application. Information may be passed both in paper form and online 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.

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Flexible Finance (UK) Ltd will pass your data to lenders whom may use automated decision making in respect of your application for finance. We will only collect the minimum amount of data needed and have a clear retention policy for the profiles we create. You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or any significant affects. You can request human intervention and challenge a decision made this way by contacting Flexible Finance (UK) Ltd at dataprotectionofficer@flexiblefinanceuk.co.uk

 

We will use Your Personal Data for the purposes of responding to any queries you may have in relation to any 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.

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From time to time Your Personal Data will be shared with:

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• Mortgage lenders / Finance lenders / Commercial lenders / Bridging finance lenders / Peer to Peer companies and insurance providers.

• Third parties who we believe will be able to assist us with your enquiry or application, or who are able to support your needs as identified. These third parties will include but may not be limited to, our Compliance Advisers, Product specialists, estate agents, providers of legal services such as estate planners, conveyancing, surveyors and valuers (in each case where we believe this to be required due to your particular circumstances).

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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 enquiry and to provide you with our professional services.

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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.

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We do not envisage that the performance by us of our service will involve Your Personal Data being transferred outside of the European Economic Area.

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We have a Data Protection regime in place to oversee the effective and secure processing of your personal data.

 

How long will we keep it?

 

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.

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Your Personal Data will be retained by us either electronically and/ or in paper format. The FCA require us to retain such records for a minimum of 6 years however, Flexible Finance (uk) have taken the decision to retain all customer records on an indefinite basis to be able to respond to or support customer or regulator enquiries.

 

What are your rights?

 

If at any point you believe retained information is incorrect you can request to see this information and have it corrected and possibly deleted. Providing you with this information is free of charge but charges may apply for excessive requests.

 

Where relevant you have the right to withdraw consent at any time and this means that we cannot process your data provided without your consent.

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• You have the right to ask us to restrict what processing of data we do for example, you could ask us not to market to you any more but still allow us to hold personal data.

• You have the right to ask us to provide you with a copy of the data we hold in a format that will be compatible with other third-party firm systems.

• You have the right to ask us to further explain how we use your personal data

• You have the right to ask us to send an electronic copy of your personal data to another organisation should you wish

• You have the right to ask that your data is erased however, as we have a regulatory requirement to retain client files where advice has been provided or a transaction brokered then we will review your request once the regulatory obligation is no longer in force.

 

How to make contact with us 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 our data protection officer who will investigate the matter. Our Data Protection Officer can be contacted at dataprotectionofficer@flexiblefinanceuk.co.uk or by post to Flexible Finance (UK), Office 26, The Orion Suites, Newport, NP20 2AQ.

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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.

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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.

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If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law then you can complain to the Information Commissioners Office (ICO) by emailing casework@ico.org.uk or by post to Information Commissioners Office, Wycliffe House, Wycliffe Lane, Wilmslow, Cheshire, SK9 5AF.