Thank you for visiting www.mybrokervenue.co.uk (“the Website”). Please read the following information carefully as the following terms and conditions will apply to your use of the Website. The Website is operated by Together Financial Services Limited, a company registered in England and Wales under company registration number 02939389, on its behalf and on behalf of its subsidiary companies; Together Personal Finance Limited (company registration number 02613335) and Together Commercial Finance Limited (company registration number 02058813), together trading as Together, and each having its registered office address situated at Lakeview, Lakeside, Cheadle, Cheshire, SK8 3GW.
YOU HAVE A RIGHT TO KNOW HOW WE WILL USE YOUR PERSONAL DATA.
We are committed to ensuring the security of your personal data.
The Data Protection Act 1998 (“DPA”) places obligations on us to process your information fairly and lawfully and to keep it secure. For the purposes of the DPA, the data controller of Website users’ personal data which is collected through the Website when users make an online enquiry is Together Financial Services Limited of Lake View, Lakeside, Cheadle, SK8 3GW. As a data controller, Together Financial Services Limited maintains a notification of its data processing activities with the Information Commissioner’s Office (ICO) and its registration number is ZA067862.
Data may also be processed by Together Personal Finance Limited and/or Together Commercial Finance Limited.
What is “Personal Data”?
The type of personal data we will collect about you via the Website
The Website provides users whose clients are interested in our products/services with an opportunity to submit applications and/or referrals for loans on behalf of such clients which may contain referral data. When you use the Website in the capacity of a registered organisation submitting business to us (a “Broker”), or as an individual working on behalf of a Broker (for an example, an employee of a Broker) (all references to Broker shall include such individuals), you may provide us with personal data.
The personal data that you may provide to us when submitting an application and/or referral includes the following:
- your name and username;
- security information (passwords and answers to security questions) (please note that passwords and answers to security questions are encrypted and as such are not available for Together to view);
- your contact details (including postal address, email address and phone number);
- your Website registration number;
- the organisation you work for;
- names and email addresses of directors at your Broker firm;
- contact details of complaints handlers at your Broker firm (including name, telephone numbers, department of work, postal address and email address);
- any personal data you choose to include when typing additional comments in free text boxes; and referral data of your clients.
In addition, you may also provide us with your personal data by corresponding with us by phone, e-mail, post or otherwise. This includes personal data you submit when you register to use the Website, make a referral to us, make an enquiry and/or when you report a problem with the Website. The information you give us may include some of the personal data listed above and any other personal data you choose to provide to us.
When you register as a Broker, we will collect information about the individuals working at your firm to identify the key individuals of the firm.
When you register as an individual acting on behalf of a Broker, we will also collect information about you to verify your identify and your work address.
How we collect information about your clients
How we handle personal data
We will observe the rights granted to you and your clients under applicable privacy and data protection laws and will ensure that queries relating to privacy issues are promptly and transparently dealt with. See below for details about how to contact us and how to exercise your right to obtain copies of your personal data from us under data protection laws.
We will only collect and process personal data where we have lawful grounds to do so.
We will update our records if you inform us that your details have changed or (where such an update is not to be effected by yourself) that your client’s details have changed. Please tell us (see contact details below) as soon as possible about this. We will update our records promptly once we are satisfied that the new information (such as your new address or contact detail) is accurate.
Prevention of fraud
If false or inaccurate information is provided and fraud is identified, details will be passed to fraud prevention agencies. Law enforcement agencies may access and use this information.
We and other organisations may also access and use this information to prevent fraud and money laundering, for example, when:
- Checking details on applications for credit and credit related or other facilities;
- Managing credit and credit related accounts or facilities;
- Recovering debt;
- Checking details on proposals and claims for all types of insurance; and
- Checking details of job applicants and employees.
Please contact the Risk Department, Lake View, Lakeside, Cheadle SK8 3GW if you want to receive details of the relevant fraud prevention agencies. We and other organisations may access and use from other countries the information recorded by fraud prevention agencies.
How we will use the personal data we collect about you and your clients.
We will store and process your personal data on our computers and in our paper folders.
Please see the Data Security header below for details about how we keep your personal data secure, in line with our obligations under the DPA.
We will use your personal data collected (including from any third parties, where relevant and lawful) to:
- contact you about customer referrals you have made through the Website;
- comply with our legal obligations;
- assist with relationship management between Together, Brokers and individuals acting on behalf of Brokers; and
- identify patterns which we can use to help us develop, administer, support and improve our services.
This list is not intended to be exhaustive and may be updated from time to time as business needs and legal requirements dictate.
From time to time and where we have collected appropriate consents under data protection laws to permit this, we, and other companies within our corporate group, would like to send you and your clients information about our/their other credit related and financial goods and services which may be of interest to you or your clients and which are similar to our own. If you and/or your clients have consented to receive these marketing communications, you/they may be contacted in each case by post, fax, telephone, recorded message, email, SMS or by any other method made clear to you at the time you gave your consent, or such at such time your client gave their consent.
If you or your clients have consented to receive marketing communications but no longer want to receive details of these goods and services please write to us at Together, Marketing Department, Lake View, Lakeside, Cheadle, SK8 3GW or email us at: email@example.com. You will be reminded of how to unsubscribe in each electronic marketing communication too.
Where you or your clients have provided consent, we may also pass personal data to selected businesses outside of our corporate group who may contact you or your client directly about their services and products that may be of interest to you.
If you or your clients have consented to us passing your personal data to companies outside of our corporate group but no longer want us to do this, please write to us at Together, Marketing Department, Lake View, Lakeside, Cheadle, SK8 3GW or email us at: firstname.lastname@example.org. Please note this does not mean we can obtain data back from those other companies. You would need to contact them directly to stop their marketing to you – their contact details should be in the marketing communications they send to you.
Sharing or disclosing information with third parties
We may share your personal data and the personal data of your clients with third parties, for the purposes of assessing your clients’ suitability for our products/services (for example, through credit searches, home valuations and Land Registry searches). Their use of personal data is governed by their privacy policies. We are not responsible for the privacy policies and practices of any other websites, even if you access them using links from the Website or if you can access the Website or use our services from them. We therefore recommend that you check the policy of each website that you visit and make sure that you are comfortable with the terms of such policies before providing any personal information.
We may also use third parties to provide services on our behalf which may include processing (but not using themselves for their own purposes) your personal data and this means we will disclose your personal data to them. For example (amongst others), to complete partial addresses, or to provide IT services such as data hosting. In either case, we will in accordance with our obligations under data protection law put in place appropriate written protections for your personal data including in our contract with them.
- Together Financial Service Limited group companies for the purpose of providing our products/services;
- our auditors, solicitors, professional advisors, sub-contractors or any person providing services to Together Financial Services Limited group companies and, who have agreed to treat your personal details as confidential;
- anybody having a legal right to your personal information, including the police and any other legal and regulatory authorities and government bodies;
- to any third party who acquires all, or substantially all, of the assets or shares in Together Financial Services Limited, any of our corporate group, and/or the Website, whether by sale, merger, acquisition or otherwise; and
- any other third party, where you have consented (where consent is required by law).
Recording of telephone calls
We may monitor and record incoming and outgoing telephone calls and text messages for staff training, quality control purposes and to help to identify crime.
How long we keep your personal data.
We take steps with a view to deleting, destroying or permanently anonymising your personal data (which means that we are no longer able to identify you from it) when it is no longer necessary for its purpose and we are not required by law to keep it.
How long we keep your personal data depends upon the purpose for which your personal data was collected was provided. Generally however:
- we will keep the information no longer than is necessary;
- we will keep your contact details for the duration for which you are a registered user of the Website and for a reasonable period thereafter (but we will not retain these details indefinitely); and
- we will keep other information about you if it is necessary for us to do so to comply with our legal obligations.
Will my personal data be transferred outside of the European Economic Area?
Your right to see your records
You have a right, upon payment of the appropriate fee (currently £10) to obtain a copy of the personal data we hold about you. If you wish to request a copy of the information we hold about you please write to: Together, Customer Care, Lake View, Lakeside, Cheadle, SK8 3GW. Alternatively you can email us at: email@example.com.
In accordance with our obligations under the DPA, to prevent unauthorised access to or disclosure of your personal data, maintain data accuracy, and ensure the appropriate use of your personal data, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the personal data we collect online.
However, you acknowledge that, unfortunately, the transmission of information via the internet, including forms you submit to us, is not completely secure. We cannot guarantee the security of your data transmitted to the Website: any transmission (i.e. your sending of the personal data to us) is at your own risk. Once we have received your personal data, we will use the steps detailed above to protect it.
You should be aware that there are inherent risks in transferring personal data over the Internet. For example, if you send us an e-mail from your private mailbox, we cannot guarantee the security of the content during its transmission to us. For that reason, please do not send to us an unsecured e-mail with confidential information such as your employee number or bank account numbers, or any sensitive personal data.
Customer feedback and complaints
If you have any questions about our Privacy Notice please contact Broker Relations at Together, Lake View, Lakeside, Cheadle, SK8 3GW.
Last updated: [ ] 2017.