Commercial Expert respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or when you submit an application form via one of our agents, or on the telephone, and tell you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how Commercial Expert collects and processes your personal data through your use of our website and when you sign up to our services in person, (submitting an application form via one of our agents or on the telephone) including any data you may provide through our website when you apply for a loan, or submit an enquiry.
Our website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Commercial Expert Ltd is the controller and responsible for your personal data (collectively referred to as ‘Commercial Expert’ ‘we’, ‘us’ or ‘our’ in this privacy notice).
We have appointed a Data Privacy Manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Data Privacy Manager using the details set out below.
Data Privacy Manager: Michael Coates
Email address: firstname.lastname@example.org
Company Name: Commercial Expert Ltd
Postal address: Unit 24a Parsons Court Welbury Way Aycliffe Business Park Newton Aycliffe DL5 6ZE
Telephone number: 01325 359 800
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated in April 2018.
The data protection law in the UK will change on 25 May 2018. Although this privacy notice sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) until May 2018 as we are still working towards getting our systems ready for some of these changes.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
When you use our website, it may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
a. Identity Data includes first name, maiden name, last name, marital status, title, date of birth and gender. In addition this Data includes your business’ status, name, company number and registered address.
b. Contact Data includes billing address, delivery address, email address and telephone numbers.
c. Financial Data includes bank account and payment card details, information about the funding you require, the security address (including landlord status, current loan arrangements and market value of the property), company address and existing lender details.
d. Serviceability Data.
e. Introducer Data, includes their Identity Data and Contact Data.
f. Transaction Data includes details about payments to and from you and other details of services you have purchased from us. In addition, when you have been referred to us by a third party, this may include your instructions to them.
g. Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
h. Usage Data includes information about how you use our website and services.
i. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms, asking for our financial advice, or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our loan/ broker services be it via the website, by telephone or by appointment;
- speak to us
- submit an enquiry on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- give us some feedback.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
When you use our website, Technical Data from the following parties:
(a) analytics providers
(b) search information providers
When you use our website, or when you submit an application form via one of our agents in person:
Contact, Financial and Transaction Data from providers of technical, payment and delivery services
Identity and Contact details from third parties that refer you to us for our services.
Identity and Contact Data from data brokers or aggregators
Identity, Financial and Contact Data from publicly availably sources such as Companies House, HM Land Registry and Credit Agencies.
4. How we use your personal data
We will only use your personal data, when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where you have explicitly consented to us doing so when completing your online application and/or with one of our agents.
- Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data (with the exception of any special categories of data we collect in accordance with our Data Protection and Use of Data consent form), other than in relation to sending third party direct marketing communications to you via email or text message, or when we are required to process Sensitive Categories of Data.
You have the right to withdraw consent to marketing at any time by contacting us at email@example.com by writing to our Data Protection Manager, Michael Coates, at Commercial Expert Ltd Unit 24a Parsons Court, Welbury Way, Aycliffe Business Park, Newton Aycliffe DL5 6ZE
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data and sensitive data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
|Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new client and prepare and witness appropriate loan documentation on behalf of a Funder||(a) Identity (b) Contact (d) Serviceability Data (e) Introducer Data (f) Sensitive||(a) Performance of a contract with you (b) (c) When you have explicitly consented to us doing so in our Data Protection and Use of Data consent form|
|To process and deliver our service including:||(a) Identity||(a) Performance of a contract with you, including providing you with your indicative terms and letter of|