Your personal data privacy is very important to us which is why we have published this notice for your information purposes. This is designed to explain what, why and how we use your personal data as well as providing you with information regarding our regulatory authority.
Who is the Data Controller?
Harvey and Thompson Limited (www.handt.co.uk/) of Times House, Throwley Way, Sutton, Surrey SM1 4AF
We are registered with the Information Commissioner's Office with registration number Z5870831.Our Data Protection Officer can be contacted via the above postal address or via email at DPO@handt.co.uk
Why do we use your information?
We use your personal information for a variety of reasons related to providing you with our products and services, our business activities and administration, and compliance with our legal and regulatory obligations.
Where you have applied for a credit product (such as a personal loan or a pawnbroking agreement) our reasons also include processing and assessing your application for credit and the administration of your loan or pawn agreement. We refer to these as "credit products".
Where you are using one of our other services, such as a foreign exchange transaction, this is to provide you with services and to manage our risk. We refer to these as "money services"
Where you provide your consent we may use it to send you electronic marketing.
What is the legal basis for these uses?
In most cases our use of your information is necessary and carried out on the following legal grounds:
· for the performance of a contract with you (such as your credit product or money services).
· where necessary for our legitimate interests (such as the proper administration of our business and managing our legal risks); and
· where necessary in order to comply with a legal obligation (for example making reports to our regulatory authority or to law enforcement agencies).
Where our use of your data is not necessary for one of the purposes outlined above we may seek your consent to use it in a particular way, for example if we want to send you marketing information, ask you to provide feedback or you tell us about a change in circumstances relating to your health.
Where we ask for your consent you may refuse and can withdraw your consent at any time by contacting us using the details set out below.
What information about you do we use
We collect and use the following information about you:
· information about you including your contact and personal details and, if you are applying for a credit product, information about your financial circumstances;
· if you are taking out a credit product, information provided to us by any loan broker that introduced you to us;
· if you are taking out a credit product or using a money service, information about you from third party organisations to verify your identity and, in the case of credit products, assess your creditworthiness, such as Credit Reference Agencies (CRAs), Fraud Prevention Agencies (FPAs) and tracing agents;
· information obtained from other public data sources which might include data from the electoral roll, public records including county court judgments, and bankruptcy and insolvency data to the extent this is necessary and justified on one of the legal bases above;
· information about your use of our website (see the Privacy Notice on our website for details) and call recordings when you speak to us over the telephone; and
· information you (or your third-party representative(s)) provide us with or share publicly to the extent this is necessary and justified on one of the legal bases above.
When might we collect and use sensitive information about you?
We always seek to treat customers fairly and be responsive to their individual needs. Sometimes you may disclose some types of information which are classed as sensitive under the law. A common example of this is information about your mental or physical health. We will ask your consent to record this information. Not agreeing to us recording this information may impact on our ability to make adjustments for your circumstances. We collect this information with your consent only so that we can treat you fairly and according to your needs.
Who do we share your information with?
We may share your information with:
· the broker who introduced you (if applicable);
· third party service providers, such as tracing agents, debt collection agencies, our legal advisors, our auditors and professional service providers and our website support;
· if you have a credit product, CRAs and FPAs to which we may report positive, delinquent and default data about your account(s) on a regular (minimum monthly) basis;
· law enforcement agencies or regulatory bodies where we are required to do so;
· other members of our group of companies, and any purchaser or proposed purchaser of all or part of the same or their assets, together with their professional advisors;
· you or your third-party representatives (in line with your rights); or
· any person or persons seeking to acquire all or part of our business and/or assets and any potential assignees of your credit agreement, along with their third-party advisors;
· We believe, in good faith, that it is necessary to protect our rights, property, safety or reputation or the rights, property, safety or reputation of any of our clients or partners.
· Where we share your data we will always seek to implement reasonable safeguards to ensure it is safe.
Records remain on file with CRAs and FPAs for 6 years after they are closed, whether settled by you or defaulted. This information may be supplied to other organisations which search your credit record. More information about CRAs and how they use personal information is available in the Credit Reference Agency Information Notice (also known as the "CRAIN") at www.experian.co.uk/crain/index.html or you can contact the agencies below:
Where is your information stored?
The information we collect about you will be held on our secure servers within the European Economic Area (the EEA) and will not be transferred or stored outside the EEA.
How long will your information be kept on file?
We keep your information for as long as it is needed to provide you with the services you have requested and, to the extent it is necessary for the protection of our legitimate interests, for six years from the date it is provided to us. In some limited cases we are required to keep certain information by law. If you would like to know more, please contact us.
You can find out more or exercise the above rights by contacting us. Further information is also available from the ICO's website (www.ico.org.uk).
Contact and complaints
If you have question, want to exercise your rights or make a complaint about our use of your information, please contact us using the details above, or by email to DPO@handt.co.uk.
You can also make a complaint to the ICO, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, telephone 0303 123 1113. www.ico.org.uk.
Automated decision making
We use automated processing and decision-making (without human intervention) in relation to your personal information to help us to undertake initial assessments of applications for credit products. We will never decide to offer credit solely on an automated basis but will automatically decline applications where our assessment criteria deem that it would not be suitable for you. We design our assessments carefully and put appropriate safeguards in place. The purpose is always to assess whether the requested credit is likely to be affordable and sustainable for you. Automated assessments of your application may also impact on the terms of the credit we are prepared to offer you (such as the interest rate, amount we are prepared to lend and/or the term of the loan).
Updates to this policy are published on our website and, where appropriate, may be sent by email and/or post.
If you have any questions you should contact us. We have designed this notice to provide you with information in a concise and clear way, but if you have specific questions relating to your own circumstances, or you simply want to find out more, you can contact us.
Our website may use SessionCam for analysis. SessionCam is a product that has been developed by SessionCam LTD. SessionCam may record mouse clicks, mouse movements, page scrolling and any text keyed into website forms. The information collected does not include bank details or any sensitive personal data. Data collected by SessionCam from H&T website is for H&T internal use only. The information collected is used to improve our website usability and is stored and used for aggregated and statistical reporting.