Privacy Policy in MBV

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.

References in this Privacy Policy to "we", "us", "our" and "ourselves" are references to Together Financial Services Limited and its subsidiary companies as outlined above. References to “you” or “your” are references to any person, Broker (as defined below) and/or any individuals acting on behalf of a Broker reading this Privacy Policy.

We take the privacy of our Website users seriously and we are committed to protecting your privacy in compliance with data protection laws. This Privacy Policy explains what personal data (see below for details of what this means) is collected about you via the Website and what we do with that information. Please see our Cookies Policy below for information of how the Website uses cookies, and your choices regarding cookies use.
We encourage all of our Website users to familiarise themselves with this Privacy Policy to understand our views and practices regarding your personal data collected via the Website and how we will treat it.
We reserve the right in our sole discretion to amend this Privacy Policy from time to time. In this event, we will post the revised policy on the Website. We encourage you to periodically re-read this Privacy Policy so that you are aware of any updates and remain informed as to how we are using, disclosing and processing your personal data. We may, where necessary, notify users of any modified version of this Privacy Policy that might materially affect the way we use, disclose or otherwise process users’ personal data or otherwise affect their privacy rights. We may do this for example by posting an update on the Website which users will see at their next visit.
This Privacy Policy relates to the personal data we collect about you via the Website, and personal data we collect from you relating to your client that you may submit to us via the Website. Please contact us for more details (contact details are included at the end of this Privacy Policy).

YOU HAVE A RIGHT TO KNOW HOW WE WILL USE YOUR PERSONAL DATA.

We provide this Privacy Policy to make you aware of our practices in connection with your privacy and of the choices you can make about the way your personal data is collected via the Website and used.
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”?

For the purposes of this Privacy Policy, “personal data” is data which relates to a living individual who can be identified from the data or from that data and other information which is in the possession of, or likely to come into the possession of, Together.

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 respect of any personal data relating to your clients that you provide via the Website, you confirm that you have obtained and maintain consent from such clients for us to process their personal data as outlined in this Privacy Policy. You will indemnify us for any liability we may incur as a result of your failure to obtain necessary consent. Should any client withdraw such consent you must inform us immediately by contacting Together, Customer Care, Lake View, Lakeside, Cheadle, SK8 3GW. Alternatively you can email us at: customercare@togethermoney.com.

The Website also uses cookies, which may constitute your personal data in certain circumstances. Please see our Cookies Policy below for information about the cookies we use and your choices in relation to cookie use.

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.
We will only collect information about you where this is necessary in order for us to be able to provide you with our products/services (including contacting you to discuss our products/services) and as otherwise set out in this Privacy Policy.
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

In addition to collecting your personal data via your use of the Website, and as otherwise described above, we also collect personal data in relation to your clients which we obtain from you when you provide us with data over the telephone, correspond with us via email and post, when you send us documents, when you complete and send us a form via the Website or from any third parties you refer through the Website. This Privacy Policy details how we collect this personal data via the Website.

How we handle personal data

We will only use the personal data you provide to us as described in this Privacy Policy. 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.
We will put your name and contact details which we collect through this Website into (i) our Customer Relationship Management tool and (ii) our Broker administration database. We will only use this personal data for the purposes described in this Privacy Policy and as otherwise notified to you from time to time.

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.
We may also use your personal data where such use is in our (or a third party’s) legitimate business interests, providing this use does not cause you unwarranted prejudice, and as otherwise set out in this Privacy Policy.

Marketing communications

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: digitalteam@togethermoney.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: digitalteam@togethermoney.com. 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.
Other than set out in this Privacy Policy (and supplemental privacy information, notices and/or statements where relevant), we will not otherwise disclose, sell or distribute your personal data we collect via the Website to any third party without your permission unless we are required or permitted to do so by law. In addition to the disclosures described above, we may disclose your personal data to:

• 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?

This Privacy Policy describes above how users’ personal data collected via the Website may be disclosed outside of Together Financial Services Limited. Pursuant to this, including for instance where we engage providers of services and/or where companies within our corporate group provide services to it (for example, hosting databases containing users’ personal data), users’ personal data may be transferred to countries or territories located outside of the European Economic Area (EEA) which do not have data protection laws equivalent to those in the UK. Steps will be taken with a view to protecting your personal data in that instance consistent with applicable data protection law.

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: customercare@togethermoney.com.

Data Security

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.