Privacy Policy
CUSTOMERS AND SUPPLIERS PRIVACY POLICY
1.
GENERAL
1.1
UK Commercial and Development Finance Limited are
a trading name of UK Development Finance Limited (“we” “us” “our”)
are committed to protecting and respecting your privacy. We are the data
controller and will process your personal data in accordance with the Data
Protection Act 2018, Regulation (EU) 2016/679 (the "UK GDPR") and
the Privacy and Electronic Communications (EC Directive) Regulations 2003 as
amended from time to time as well as any national laws which relate to the
processing of personal data (“data protection legislation”).
1.2
Please read the following carefully to
understand our views and practices regarding Your Data and how we will treat
it.
This policy applies to
information we collect about:
·
Visitors to our website(s)
·
Customers
·
Introducers
·
Suppliers
2.
VISITORS TO
OUR WEBSITEs
2.1
We may collect and process personal data about
you in the following circumstances:
2.1.1
when you complete the online contact forms on
our website (“Site”) providing us with your name, address, email address
and contact number;
2.1.2
whenever you provide information to us when
reporting a problem with our Site, making a complaint, making an enquiry or
contacting us for any other reason. If you contact us, we may keep a record of
that correspondence;
2.1.3
when you visit our Sites we will retain details
such as traffic data, location data, weblogs and other communication data, and
the resources that you access (see section 2.2.2 on Cookies below); and
2.1.4
whenever you disclose your information to us, or
we collect information from you in any other way, through our Sites.
2.2
We may also collect data in the following ways:
IP Address
2.2.1
We may collect information about your device,
including where available your Internet Protocol address, for reasons of fraud
protection. We may also collect information about your device’s operating
system and browser type, for system administration and to report aggregate
information to our advertisers. This is statistical data about our users’
browsing actions and patterns, and does not identify any individual.
2.2.2
Use of Cookies
A
cookie is a small text file which is placed onto your computer (or other
electronic device) when you access our website. We use cookies on this website
to:
a) recognise you whenever you visit this website (this speeds up your
access to the website as you do not have to log in each time);
b) obtain information about your preferences, online movements and use
of the internet;
c) carry out research and statistical analysis to help improve our
content, products and services and to help us better understand our customer
requirements and interests;
d) target our marketing and advertising campaigns more effectively by
providing interest-based advertisements that are personalised to your
interests; and
e) make your online experience more efficient and enjoyable.
2.2.3 Description of cookies
We may use the following categories of cookies on
our website:
- Strictly necessary: These are cookies which are essential for
certain features of our website to work. These cookies do not record
identifiable personal information and we do not need your consent to place
these cookies on your device. Without these cookies we will be unable to
provide all or part of our services to you. - Performance monitoring: We use these cookies to collect details
on an anonymous basis about how you use our websites. This information may
be used to help us improve our websites and understand how effective our
adverts are. In some cases we use trusted third parties to collect this
information for us but they only use the information for the purposes
explained. - Functionality: These cookies are used to provide services or
remember your settings. These cookies are aimed at enhancing your user
experience by remembering your preferences. The information these cookies
collect is anonymous and does not enable us to track your browsing
activity on other websites.
The table below explains what cookies we use and
why:
|
Cookie |
Name |
Purpose |
|
Google Analytics |
ga |
To collect |
|
Ukdevelopmentfinance-session |
ifs |
To collect |
|
|
wa |
To collect |
|
Cookie_consent-level |
Ccl |
To collect |
|
-gfduid |
Gfd |
To collect |
|
wix |
Wx |
To collect |
2.2.4 Consent
In most cases we will ask for your consent in order to use cookies
on this website. Please note that we do not require your consent where the
cookie is essential in order for us to provide you with a product or service you
have requested.
2.2.5 How to turn off cookies
If you do not want to accept cookies, you can change
your browser settings accordingly. If you do this, please be aware that you may
lose some of the functionality of this website. For further information about
cookies and how to disable them please go to the Information Commissioner’s
webpage on cookies: https://ico.org.uk/for-the-public/online/cookies/.
2.3
We may use your personal data for our legitimate
interests in order to:
2.3.1
provide you with information, or services that
you requested from us;
2.3.2
respond to an enquiry submitted via our online
contact forms;
2.3.3
allow you to participate in interactive features
of our Sites, when you choose to do so;
2.3.4
ensure that content from our Sites are presented
in the most effective manner for you and for your device;
2.3.5
improve our Sites and services;
2.3.6
process and deal with any complaints or
enquiries made by you; and
2.3.7
contact you for marketing purposes where you have
signed up for these (see section 5 for further details).
Website Links
2.4
Our Site may, from time to time, contain links
to and from the websites of third parties. Please note that if you follow a
link to any of these websites, such websites will apply different terms to the
collection and privacy of your personal data and we do not accept any
responsibility or liability for these policies. Please check before you submit your
information to these websites.
3.
CUSTOMERS
3.1
We will collect details such as name, address, email address, contact number, date of birth, national
insurance number and financial information (including bank statements) in order
to provide services to customers. We may also receive
details of credit checks undertaken where you have supplied these to us.
3.2
We will share customer personal information with
our employees to manage our relationship with you and we will retain customer
personal data for a retention period of no longer than is required by
applicable data protection laws.
3.3
We will use your personal data provided to
comply with our contractual obligations arising from the agreements we enter
into with our Customers and share the data with financial institutions who can
assist in the provision of non-regulated financial services to customers including
product providers, lenders, banks, insurers, platform providers and third party
administrators.
3.4
We will use customer
personal data for our legitimate interests including:
3.4.1
sharing personal data with Optimum Elite, our network
and product solution sourcing system. Further details regarding how Optimum Elite
will use customer personal data can be found on it’s website at https://optimumcs.co.uk/;
3.4.2
to administer, manage, market and operate our
business, including filing and reporting for accounting purposes;
3.4.3
with your consent, marketing our other products
and services by mail and email; and
3.4.4
with your consent, obtaining your sensitive
personal data from third parties including your health, ethnic origin, or
criminal prosecutions from third parties such as employers and credit reference
agencies, fraud prevention agencies and other similar organisations.
3.5
We will not transfer any customer personal data
outside the United Kingdom unless permitted to do so by data protection legislation
(see section 8 of this Privacy Policy).
4.
SUPPLIERS
We will collect details such as contact names, address, email
address and telephone number in order to contact you about goods and/or services
we have ordered from you, to comply with our contractual obligations and to
place further orders. We may share your personal data with our employees to manage
our relationship with you and we will keep your personal data for as long as we
require your goods and/or services subject to a maximum of seven years from the
date of our last contact with you or expiry of our contract. We will not
transfer your personal data outside the United Kingdom unless permitted to do
so by data protection legislation (see section 8 of this Privacy Policy).
5.
MARKETING
5.1
We may use customer personal data to provide you
with details about our services, products, business updates and events which we
think may be of interest. We will only send you marketing correspondence where
you have given us your consent to do so.
5.2
You have the right to opt-out of receiving the information
detailed in section 5.1 at any time. To opt-out of receiving such information
you can:
5.2.1
tick the relevant box situated in the form on which
we collect your information;
5.2.2
clicking the unsubscribe button contained in any
such communication received; or
5.2.3
email us at yourproject@df-uk.co.uk or call 0117 251 0563, providing us with your name and
contact details. It may take up to 7 days for this to take place.
5.3
Where you have subscribed to
receive marketing correspondence from us we will keep your personal data for six
years from when you subscribed to receiving marketing information from us or
until you unsubscribe from receiving such correspondence from us (whichever is
earlier).
6.
LEGAL BASIS FOR PROCESSING YOUR
PERSONAL DATA
6.1
In accordance with data protection
legislation we are required to notify you of the legal basis upon which we
process your personal data. We process your personal data for the following
reasons:
6.1.1
for performance of a contract we
enter into with you;
6.1.2
where necessary for compliance
with a legal obligation we are subject to; and
6.1.3
for our legitimate interests (as
described within this policy).
6.2
We will also process your personal
data including personal sensitive data where we have obtained your explicit
consent.
7.
DISCLOSURE OF YOUR DATA to third parties
7.1
In addition to the third parties mentioned previously
in this policy, we may disclose your personal data to third parties for the following legitimate business purposes:
7.1.1
staff members in order to facilitate the
provision of services to you;
7.1.2
IT software providers that host our website and
store data on our behalf;
7.1.3
Service providers who provide us with software
solutions and platforms in order to carry out our business and provide services
(including, without limitation, open banking services); and
7.1.4
to a prospective buyer of some or all of our business
or assets, in which case personal data including Your Data will also be one of
the transferred assets. The recipient of the information will be bound by
confidentiality obligations.
7.2
We only allow our service providers to handle
your personal information if we are satisfied they take appropriate measures to
protect your personal information. We also impose contractual obligations on
service providers to ensure they can only use your personal information to
provide services to us and to you. We may also share personal information with
external auditors, e.g. in relation to ISO accreditation and the audit of our
accounts.
7.3
We may disclose your personal data to the
police, regulatory bodies, legal advisors or similar third parties where we are
under a legal duty to disclose or share your personal data in order to comply
with any legal obligation, or in order to enforce or apply our agreements; or
to protect our rights, property, or safety of our customers, or others. This
includes exchanging information with other companies and organisations for the
purposes of fraud protection and credit risk reduction.
7.4
We will not sell or distribute your personal
data to other organisations without your approval.
8.
CROSS-BORDER DATA
TRANSFERS
8.1
We share your personal data with external third
parties in order to provide our services to you. Some of these third parties
may transfer personal data outside the United Kingdom. We require such third
parties to ensure that such transfers take place in accordance with data
protection legislation.
8.2
Whenever we transfer your personal data out of
the United Kingdom, we ensure a similar degree of protection is afforded to it
by ensuring at least one of the following safeguards is implemented:
·
We will only transfer your
personal data to countries that have been deemed to provide an adequate level
of protection for personal data by the UK Information Commissioner’s Office or;
·
Where we have accessed the
risk to be at a suitable level, we may use standard contractual clauses approved
by the UK Information Commissioner’s Office which give personal data the same
protection it has in the United Kingdom or
·
Where we have assessed the
risk to be too high, we will not transfer your personal data to that third
party.
8.3 Please
contact us if you want further information on the specific mechanism used by us
when transferring your personal data out of the United Kingdom.
9.
DATA SECURITY
9.1
Information you provide to us is shared on our
secure servers. We have implemented appropriate physical, technical and organisational
measures designed to secure your information against accidental loss and unauthorised
access, use, alteration or disclosure. In addition, we limit access to personal
data to those employees, agents, contractors and other third parties that have
a legitimate business need for such access. We also have procedures in place to
deal with any suspected data security breach. We will notify you and any
applicable regulator of a suspected data security where we are legally required
to do so.
9.2
Where we have given you (or where you have
chosen) a password which enables you to access certain parts of our Sites, you
are responsible for keeping this password confidential. We ask you not to share
a password with anyone.
9.3
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
information transmitted to our Site; any transmission is at your own risk. If
you want detailed information from Get Safe Online on how to protect your information
and your computers and devices against fraud, identity theft, viruses and many
other online problems, please visit www.getsafeonline.org. Get Safe Online
is supported by HM Government and leading businesses.
10.
ACCESS TO, UPDATING, DELETING AND RESTRICTING USE OF YOUR
DATA
10.1
It is important that the personal data we hold
about you is accurate and current. Please keep us informed if the personal data
we hold about you changes.
10.2
Data protection legislation gives you certain
rights in relation to your personal data. You have the right to object to the
processing of your personal data in certain circumstances and to withdraw your
consent to the processing of your personal data where this has been provided.
10.3
You can also ask us to undertake the following:
10.3.1
update or amend your personal data if you feel
this is inaccurate;
10.3.2
remove your personal data from our database entirely;
10.3.3
send you copies of your personal data in a
commonly used format and transfer your information to another entity where you
have supplied this to us, and we process this electronically with your consent
or where necessary for the performance of a contract;
10.3.4
restrict the use of your personal data; and
10.3.5
provide you with access to information held
about you and for this to be provided in an intelligible form.
10.4
We may request specific information from you to
help us confirm your identity. Data protection legislation may allow or require
us to refuse to provide you with access to some or all the personal data that
we hold about you or to comply with any requests made in accordance with your
rights referred to above. If we cannot provide you with access to your personal
data, or process any other request we receive, we will inform you of the
reasons why, subject to any legal or regulatory restrictions.
10.5
Please send any requests relating to the above
to our Privacy Officers at yourproject@df-uk.co.uk, specifying
your name and the action you would like us to undertake.
11.
RIGHT TO WITHDRAW
CONSENT
Where you have
provided your consent to the collection, processing and transfer of your personal
data, you may withdraw that consent at any time. This will not affect the
lawfulness of data processing based on consent before it is withdrawn. To
withdraw your consent please contact us at yourproject@df-uk.co.uk or 0117 251 0563.
12.
CHANGES TO OUR PRIVACY POLICY
We
reserve the right to update this privacy policy at any time, and any changes we
make to our privacy policy will be posted on this page. We will notify you if there
are any changes to this policy that materially affect how we collect, store or
process your personal data. If we would like to use your previously collected
personal data for different purposes than those we notified you about at the
time of collection, we will provide you with notice and, where required by law,
seek your consent, before using your personal data for a new or unrelated
purpose. We may process your personal data without your knowledge or consent
where required by applicable law or regulation.
13.
CONTACT US
We have appointed two Privacy Officers to
oversee compliance with this privacy policy. If you have any questions,
comments or requests regarding this policy or how we use your personal data please
contact our Privacy Officers at yourproject@df-uk.co.uk
or 0117 251 0563. This is in addition to your right to contact the
Information Commissioners Office if you are unsatisfied with our response to any
issues you raise at https://ico.org.uk/global/contact-us/
Last
updated: August 2023.
Arrange a call with one of our advisers
We would love to hear from you and to discuss your enquiry. For a free introductory call to discuss your needs, call us 0117 251 0563 and ask for Ryan or Luke.
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