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Privacy Policy


Collecting, using and showing your information

We take the privacy of your information seriously and we ask that you read this Statement carefully as it contains important information on:

We won't disclose your information to anyone, other than as set out in this Statement.

The types of personal data we collect and use

We need to know basic personal data in order to provide you with our services under our standard terms of business. If you do not provide this information then we will be unable to provide the services you have requested. We will not collect any personal data from you that we do not need in order to provide and oversee the services we have agreed to provide to you. The personal data we use may include:

  1. Full name and personal details including contact information (e.g. home address and address history, email address, home and mobile telephone numbers), date of birth and National Insurance number.
  2. Photographic identification.
  3. Financial details (e.g. bank account details).
  4. Information from credit reference or fraud prevention agencies, electoral roll, court records of debt judgements and bankruptcies and other publicly available sources.

Monitoring of communications

Subject to applicable laws, we will monitor and record your telephone calls, emails, text messages and other communications in relation to our dealings with you. We will do this for regulatory compliance, self-regulatory practices, crime prevention and detection, to protect the security of our communications systems and procedures and when we need to see a record of what has been communicated. We may also monitor activities where necessary for these reasons and this is justified by our legitimate interests or our legal obligations.

Using your personal data: the legal basis and purposes

We will process your personal data:

  1. As necessary to provide you with our services:
    1. To take steps at your request prior to entering a the contract with you for our services;
    2. To manage and perform that contract; and
    3. To update our records.
  2. For our own legitimate interests as is necessary to provide you with our services and in doing so balancing a legitimate interest against your individual interests, rights and freedoms. It is likely to be most appropriate where we use your personal data in ways you would reasonably expect and which have a minimal privacy impact or where there is a compelling justification in the processing.
  3. As necessary to comply with a legal obligation, e.g. :
    1. When you exercise your rights under data protection law and make requests;
    2. For compliance with legal and regulatory requirements and related disclosures;
    3. For establishment and defence of legal rights;
    4. For activities relating to the prevention, detection and investigation of crime;
    5. To verify your identity, make credit, fraud prevention and anti-money laundering checks (we will make and keep copies of identification evidence you provide); and
    6. To monitor emails, telephone calls, other communications and activities in connection with our services.
  4. Based on your consent, e.g. when you request us to disclose your personal data to other people or organisations or otherwise agree to disclosures. You are free at any time to change your mind to withdraw your consent. The consequence might be that we cannot do certain things for you.

Storage and retention of your personal data

  1. We follow strict security procedures as to how your personal information is stored and used and by whom it is seen and try to prevent unauthorised access although this cannot be absolutely guaranteed as the transmission of information via the internet is not completely secure.
  2. We will generally keep your personal data for a minimum of 6 years, after which time it will be destroyed if it is no longer required for the lawful purpose for which it was obtained.

Sharing of your personal data

Subject to applicable data protection law we may share your personal data with:

  1. Sub-contractors and other persons who help us provide our services.
  2. Any authorities including government bodies and agencies where you have provided us with false or inaccurate information in response to their requests in connection with our compliance obligations or financial crime risk management activity or where we reasonably suspect financial crime.
  3. Courts, to comply with legal requirements, and for the administration of justice.
  4. In an emergency or to otherwise protect your vital interests; and
  5. To protect the security or integrity of our business operations.

Your rights under applicable data protection law

Your rights are as follows (it should be noted that these rights do not apply in all circumstances);

  1. The right to be informed about our processing of your personal data;
  2. The right to have your personal data corrected if it is inaccurate and to have incomplete personal data completed;
  3. The right to object to processing of your personal data;
  4. The right to restrict processing of your personal data;
  5. The right to have your personal data erased (the �right to be forgotten�);
  6. The right to request access to your personal data and information about how we process it; and
  7. The right to move, copy or transfer your personal data.

You have the right to complain to the Information Commissioner�s Office. It has enforcement powers and can investigate compliance with data protection law:


By continuing to provide any personal data to us you are consenting to our use of your personal data as set out in this Statement. Please do not send us any personal data if you do not want that information to be used by us in the manner set out in this Statement.