|HOW WE PROTECT YOUR PERSONAL INFORMATION – PLEASE READ THIS CAREFULLY|
|Who we are|
|Strategy Finance (Project Finance | Property Finance | Insurance | Marine & Aviation)are a trading style of Strategy Finance London Limited which are Commercial Finance Brokers based in London. We act as an advisor/broker/intermediary for our customers. Strategy Finance London Limited are Authorised and Regulated by the Financial Conduct Authority. FRN 310143|
|1. What Data do we Collect and where do we get it from?|
|For the purposes set out in this notice, the Information Commissioner (ICO) requires us to advise you that, information, including personal information detailed below relating to you or anyone else to be covered by an insurance policy (“Personal Data and Special Categories of Data”) will be collected and processed by Strategy Finance London Limited and/or on its behalf by its third party service providers. This data will be provided by you, or any other person you may appoint to provide us with information. You will either be completing application forms or answering questions we ask you, in order to provide the required information. We may also obtain information from other sources that is readily available in the public domain such as the Internet of Things (IoT), Social Media, Press etc.|
|This is information we may gather from you that will directly or indirectly identify you as individual, and may also provide information about your cultural or social identity. This type of data must be processed strictly in accordance with our Basis at Law stated in the table below. This data will include but may not be limited to:-
Your title, name, postal address, risk address, email adress, civil status, gender, current and or previous occupation, personal income and expenditure, financial accounts, date of birth, contact details, registration number, mental health conditions, bank / credit card statements, proof of deposit, mortgage statements, bank details, credit / debit card details, credit searches, National Insurance Number, lease & tenancy agreements, property portfolio, Next of Kin information, children’s data where the child is under 16 (only for travel insurance policies)
|Special Categories of Data|
|This is information we may gather from you that might reveal your racial or ethnic origin, political opinions, religious or philosophical beliefs, your health, sex life or sexual orientation. This data will be processed strictly in accordance with the Basis at Law stated in the table below. This data will include but may not be limited to:-
Your title, gender, race, ethnic origin, political opinions, religious beliefs, physical or medical health conditions, driving licence origin, UK residency period, children’s data where the child is under 16 (only for travel insurance policies), criminal history. Data for criminal convictions and offences will only be collected as permitted by UK Law.
We will have asked for, and recorded either your verbal or documented consent to process any special categories of data that we may have collected from you.
The controller of this Personal Data is Strategy Finance London Limited (“we” and “us”), of 173 Balls Pond Road, London, N1 4BG. If you have any query, please contact Alp Ceylan & email@example.com of contact for GDPR. We process your Personal Data in accordance with this Privacy Notice, which is also available on www.strategyfinance.com.
|2. How and why do we Process Your Personal Data|
|The following tables detail :-
|Legal basis for processing|
|Why we collect your data||FINANCE
We obtain, collect and process your Personal Data and Special Categories of Data (which includes sharing your data with others) to enable us to quote for your finance needs, place you with a lender, make any payment arrangements requested, make any alterations to your loan/mortgage that you may request during the loan/mortgage term. We may also have regulatory and / or legal obligations for sharing data with others, but we will only share it for the purposes stated, or in a way you would reasonably expect us to, unless we inform you otherwise. If you do not provide the data requested it may not be possible to obtain a quote or provide you with a loan/mortgage.
We obtain, collect and process your Personal Data and Special Categories of Data (which includes sharing your data with others) to enable us to quote for your insurance needs, place you on cover, make any payment arrangements requested, make any alterations to your policy that you may request during the policy term, and in the unfortunate event that a claim occurs we will need to share your information to help you make your claim. We may also have regulatory and / or legal obligations for sharing data with others, but we will only share it for the purposes stated, or in a way you would reasonably expect us to, unless we inform you otherwise. If you do not provide the data requested it may not be possible to obtain a quote or provide you with a policy.
|Our legal basis for processing your data||In order to arrange your insurance we will be using one or more of the following legal bases:-
|Who we share your data with and the reason for processing||We are a Data Controller and in order to process your requests we may be sharing your data with one or more other Data Controllers. The Controllers we may share with and our reasons for sharing that information are listed but not limited to the following:-
|Lenders||To obtain agreement in principal & formal offer|
|Mortgage/loan packagers & brokers||To access some lender via their agreement|
|Accountants||To obtain financial information|
|Introducers||To update on progress|
|Estate Agent||To update on progress|
|Insurers||Quotation, cover, to manage and progress claims|
|Insurance Providers, (Placing Brokers, Delegated Authority Schemes, Wholesalers and the like)||Quotation, cover, to manage and progress claims|
|Loss Adjusters||To manage and progress claims|
|Insurance Fraud Bureau||Potential policy fraud|
|Loss Assessor||To manage and progress claims|
|Financial Conduct Authority||Regulatory obligations|
|Financial Services & Compensation Scheme||Compensation in the event of insurer failure, if eligible|
|Financial Ombudsman Service||Unresolved Complaints, if eligible|
|National Crime Agency||Suspected criminal / fraudulent activity|
|HM Treasury Sanctions||Checking clients are not on the banned list|
|Premium Finance Company||Payment of premiums|
|Possible Suppliers||Insurers replacement factilities – ie, white goods,
jewellers, cleaning companies, restoration companies,
approved repairers and garages, windscreen
replacement company, plumbers, builders, electricians
and the like.
|Staff||Administering the quotation and policy, claims or payments. Back Up Of Data|
|Claims Management Company||To manage and progress claims|
|Surveyor||Risk survey to analyse, report upon risk. Also in the event of a loss, the opportunity to survey post-loss|
|Debt Agency||To collect unpaid premium due|
|IT Providers – Software||Holds all collective management information, system testing when system not responding or errors occur|
|IT Providers – Hardware, Cloud & Systems Management||To detect issues, secure the system, and test the system. Also backup of data|
|Interested Parties (Mortgage Lender)||Proof of cover|
|Third Party Insurers||To manage and progress claims|
|Third Party Assessor||To manage and progress claims|
|Claims Management Company||To manage and progress claims|
|Credit Reference Agencies||To obtain competitive premiums via some
|Claims Exchange Underwriting||Sharing of previous claims information between insurers|
|Employers Liability Tracing Office||To provide confirmation of cover being in place|
|Our own Insurers||Where we need to provide information about you|
|Solicitor||Claims against clients or claims against us|
|Interpreter||For management of the policy and claims where
language is a barrier or they use sign language
|Group Offices||Other offices within the firm may need to use data centrally to deal with clients if another office is busy or not available|
|Other Data Controllers not detailed above||To be shared only for the purposes stated, or in a way you would reasonably expect us to, unless we inform you otherwise.|
|How long we retain your data||In principle, your personal data shouldn’t be held for longer than is required under the terms of our contract for services with you. However, we are subject to regulatory requirements to retain data for specified minimum periods. We reserve the right to retain data for longer than this due to the possibility that it may be required to defend a future claim against us.
You have the right to request deletion of your personal data. We will comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.
|3. Where do we hold Data?|
|At all times we will endeavour to hold your Data on servers within the UK, or within the European Economic Area (EEA). Where we share your information with other Data Controllers they must also agree to hold your Data within the EEA.
Your data is stored electronically on a local server which only we have access to. Our local and cloud backup’s are all encrypted and stored in secured storages.
However, in the unlikely event your data is to be held in any other geographical area we ensure that:-
|4. Your Acknowledgment of this Notice and Your Rights|
|Under General Data Protection Regulation you have rights and these are listed below.|
|The General Data Protection Regulation sets out the information we must provide to you about your Data. All of the information we are required to give you is contained within this Privacy Notice. If you do not understand any part of this, you should contact us immediately and we will be happy to explain it to you.|
|You have the right to access and obtain a copy of the Personal Data, and any supplementary information that we hold about you to enable you to verify the lawfulness of the processing carried out. This will be provided free of charge, unless your request is unfounded, excessive or repetitive, and the information will be sent to you within 30 days of your request being received. If we refuse your request, you have the right to complain to the ICO.|
|You have the right to request that we correct any inaccuracies in the Personal Data we hold about you. This will be corrected within one month. If we are unable to correct the inaccuracy you have the right to complain to the ICO.|
|You have the right to request that we erase your Personal Data. For example, you may exercise this right in the following circumstances:
We refuse the right to delete your information when it falls within our data retention period stated above, as this data may be required to exercise or defend litigation in the event of a claim whether covered or not by the insurance policy. If you do not agree with this you havethe right to complain to the ICO.
|You have the right to restrict our processing of your Personal Data where any of the following circumstances apply, although we will still be allowed to store it:
Where you exercise your right to restrict our processing of your Personal Data, we will only continue to process it in accordance with the requirements of this policy or our legal obligations.
|You have a right to receive and transfer the Personal Data that we hold about you. This only applies to:-
Where you make such a request, this will be provided in a structured, commonly used, machine readable format such as a CSV file. This will be completed within one month of us receiving your request.
Object to Processing
|In certain circumstances, you have a right to object to our processing of your Personal Data
We will still be able to process your Personal Data where
Object to automated decision making including profiling
|You have a right not to be subjected to decisions being made solely by automated means without any human involvement. This might be the case where quotations are obtained online. We will still be able to carry out this type of decision-making where:-
We will only process data in the way you would expect it to be used, and you will be entitled to have a person from our firm to review the decision so that you can query it and set out your point of view and circumstances to us.
|Where the legal basis of Consent has been used for Childrens’ data or special categories of data, you have the right to withdraw that consent at any time. Where you exercise your right to withdraw consent of the processing of any children’s data or special categories of data, any data processed prior to the withdrawal of consent will remain valid.|
If you would like to exercise any of your rights detailed above, please contact Alp Ceylan at firstname.lastname@example.org of contact for GDPR.You may raise any concerns about Strategy Finance London Limited processing of your Personal Data with the Information Commissioner Office on https://ico.org.uk/.
|5. Changes to this Notice|
|We may amend this notice on occasion, in whole or part, at our sole discretion. Any changes to this notice will be effective immediately upon sending the revised notice to you by e-mail or post. If at any time we decide to use your Personal Data in a manner significantly different from that stated in this notice, or otherwise disclosed to you at the time it was collected, we will notify you by e-mail or post and you will have a choice as to whether or not we use your information in the new manner. If you have questions or concerns about this notice, please contact Alp Ceylan at email@example.com of contact for GDPR.|
|6. Information about or provided by another person|
|Where your information for your policy has been provided to us by another person, we will send you a copy of this privacy notice directly to you, where we have your address, within one month of your policy being taken out. If we do not have / are unable hold your address for any reason, we will send a copy of this to the person arranging the finance or insurance with instructions to pass this to you within one month. Where you have taken out a formal offer or policy and provided us with information about another person.|
|8. How to contact us|
|Please contact us if you have any questions about our privacy notice or information we hold about you: by email at firstname.lastname@example.orgOr find details of where to write to us here: http://www.strategyfinance.com/contact-us|
Strategy Finance Insurance is directly authorized and regulated by the Financial Conduct Authority (FCA) with a track record of over 20 years. Start your journey to better For professional advice and personal service today.
Call us today: 0203 761 4111