Privacy Policy

1. Introduction

1.1 Who we are

The Signature Private Finance Limited website is brought to you by Signature Private Finance Limited (“Company”), a company incorporated and registered in England and Wales with company number 08106050 and registered office is at Avon House, 435 Stratford Road, Solihull, West Midlands, B90 4AA. Signature Private Finance Limited is part of a group which is made up of different legal entities, including:

  • Signature Private Finance Holdings Limited, a company incorporated and registered in England and Wales with company number 08707673 with registered office is at Avon House, 435 Stratford Road, Solihull, West Midlands, B90 4AA;
  • Signature Private Finance Finco Limited, a company incorporated and registered in England and Wales with company number 08708644 with registered office is at Avon House, 435 Stratford Road, Solihull, West Midlands, B90 4AA; and
  • SPF Bridging Limited, a company incorporated and registered in England and Wales with company number 08572664 with registered office is at Avon House, 435 Stratford Road, Solihull, West Midlands, B90 4AA;

(“Group”).

This Privacy Policy is issued on behalf of Signature Private Finance Holdings Limited Group. As such, any references to Signature Private Finance, “we”, “us” or “our” in this Privacy Policy are references to the relevant company (as named above) in the Group which is responsible for processing your data. We will let you know which entity will be the controller for your data when you purchase a product or service with us.

1.2 Purpose of this Privacy Policy

We take your privacy very seriously. As such, we ask that you read this Privacy Policy carefully as it contains important information about:

  • (a) what personal data we may collect from you;
  • (b) how we will use, store and protect your personal data;
  • (c) with whom we may share personal data; and
  • (d) your rights under relevant data protection laws.

It is important that you read this Privacy Policy 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 Policy supplements the other notices and is not intended to override them.

1.3 Third party links

The Signature Private Finance Limited website may contain links to and from other applications, plug-ins and websites of other networks, advertisers, and affiliates. If you follow a link to any of these websites, please note that they (and any services that may be accessible through them) have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these apps, websites or services. Please check these policies before you submit any personal data to these websites or use such services.

2. Lawful basis for processing

Under data protection laws, we must have a legal basis in order to process your personal data. The legal bases on which we may process your data are:

  • Consent: where you have consented for us to process your personal data for one or more specific reasons.
  • Performance of a contract: in order to perform a contract we may have with you.

3 What data we may collect from you

We may collect and process the following personal data about you:

  • Identity data: [first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender].
  • Contact data: [billing address, delivery address, email address and telephone numbers].
  • Financial data: [bank account and payment card details].
  • Transaction data: [details about payments to and from you and other details of products and services you have purchased from us].
  • Marketing and communications data: [your preferences in receiving marketing from us and our third parties and your communication preferences.

4. How we collect information from you

We collect your personal data in a number of ways:

  • Automatically: as you browse the Signature Private Finance Limited website certain information relating to your browsing patterns and technical data about the equipment you are using to access the website is automatically collected using cookies. Please see our Cookie Policy for further information.
  • Directly: contact, financial and identity data directly provided by you when you fill in online forms or correspond with us in any way, for example when:
    • applying for services;
    • submitting a query;
  • From third parties/public sources:
    • contact, financial and transaction data may be obtained from providers of technical, payment, credit referencing, and delivery services [such as Callcredit Limited, Veriphy Limited and Creditsafe Limited based [inside OR outside] the EU].]
    • identity and contact data from publicly availably sources [such as Companies House and the Electoral Register based inside the EU].

5. How we use your personal data

We may use your personal data for the following purposes:

  • to provide the requested services to you;
  • in accordance with our legitimate interests (in circumstances where your interests and fundamental rights do not override our interests);
  • to personalise your experience on the [COMPANY] website;
  • to provide customer service, including to respond to your enquiries and fulfil any of your requests for information;
  • to send you important information regarding our services and/or other technical notices, updates, security alerts, and support and administrative messages; and
  • as we believe to be necessary or appropriate:
    • in order to comply with a legal obligation. This applies where the processing is necessary for us to comply with the law;
    • to enforce or apply this Privacy Policy; and
    • to protect our legitimate rights, privacy, property or safety, and/or those of a third party and your rights do not override those interests.

6. Retention of your data

We will not retain your personal data for longer than is necessary for the purposes for which the personal data is processed. This means that your data will only be retained for as long as it is still required to provide you with services or is necessary for legal reasons. When calculating the appropriate retention period for your data, we consider the nature and sensitivity of the data, the purposes for which we are processing the data, and any applicable statutory retention periods. Using these criteria, we regularly review the personal data which we hold and the purposes for which it is held and processed.

When we determine that personal data can no longer be retained (or where you request us to delete your data in accordance with your right to do so (please see section 11 below for more information)), we ensure that this data is securely deleted or destroyed.

For more details about our retention periods, please contact us at info@ignatureprivatefinance.co.uk.

7. Accuracy of your data

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.

8. Security of your data

In order to protect your personal data, Signature Private Finance Limited Group has appropriate organisational and technical security measures. These measures include ensuring our internal IT systems are suitably secure, and implementing procedures to deal with any suspected data breach.

In the unlikely event of a data breach, we will take steps to mitigate any loss or destruction of data and, if required, will notify you and any applicable authority of such a breach.

9. Transfer of your data

Transfers to members of our group

We may share your data with other members of the Signature Private Finance Holdings Limited Group.

Transfers to third parties

There may be circumstances in which we may also need to share your personal data with certain third parties, including third parties located outside of the EEA.

The third parties to which we may transfer your personal data include:

  • Credit Reference Agencies

The security of your data is important to us and we will, therefore, only transfer your data to such third parties if:

  • you have expressly consented to your data being shared with specific third parties;
  • the third party needs to access the personal data for the purposes of providing any contracted services to you;
  • the third party has agreed to comply with Signature Private Finance Limited’s instructions, required data security standards, policies, and procedures and put adequate security measures in place;
  • the transfer complies with any applicable cross border transfer restrictions and suitable safeguards have been put in place; and
  • a fully executed written contract that contains suitable obligations and protections has been entered into between the parties.

As mentioned above, we will only transfer your data where suitable safeguards have been put in place. These safeguards are intended to ensure a similar degree of protection is afforded to your data wherever it may be transferred and include:

  • only transferring your personal data to countries which have been deemed to provide an adequate level of protection for personal data by the European Commission;
  • where your data will be transferred outside of the EEA, entering into specific contractual terms which have been approved by the European Commission and which give personal data the same protection as within the EEA; or
  • where your data will be transferred to the US, ensuring that the third party to which we are transferring your data is part of the Privacy Shield.

For more information on the safeguards used by Signature Private Finance Limited when transfers of personal data to third parties, please contact us at david@signatureprivatefinance.co.uk.

10. Your rights

You have certain rights in relation to the personal data we process and hold about you. These include:

  • Right to rectification: you have the right to require us to correct any inaccuracies in your data.
  • Right to erasure: you have the right to require us to delete your data, subject to certain legal requirements.
  • Right to restriction of processing: you have the right to require us to restrict the way in which we process your personal data. You may wish to restrict processing if, for example:
    • You contest the accuracy of the data and wish to have it corrected;
    • You object to processing but we are require to retain the data for reasons of public interest; or
    • If you would prefer restriction to erasure.
  • Right to data portability: you have the right to obtain from us easily and securely the personal data we hold on you for any purpose you see fit.
  • Right to object to processing: you have the right to require us to stop processing your personal data should you wish the data to be retained but no longer processed.
  • Right of access: you have the right to request access to personal data that we may process about you.
  • Right to withdraw consent: you have the right at any time to withdraw consent allowing us to process your personal data.

If you would like to exercise any of the above rights, please:

  • put your request in writing;
  • include proof of your identity (such as a copy of your driving licence or passport) and address (such as a recent utility or credit card bill); and
  • specify the right you wish to exercise.

Response time

We will respond to requests made by you within one month.

Charge

We will not charge a fee for you to exercise any of the rights listed above.

11. Cookies

For more information about the cookies we use, please see our Cookies Policy.

12. Amendments to this Privacy Policy

No changes to this Privacy Policy are valid or have any effect unless agreed by us in writing. We reserve the right to vary this Privacy Policy from time to time. Our updated terms will be displayed on the Signature Private Finance Limited website. It is your responsibility to check this Privacy Policy from time to time to verify such variations.

13. Questions in relation to this Privacy Policy

You should also be aware that you have the right to raise any concerns in relation to how we process your personal data to the Information Commissioner’s Office (ICO).

We have appointed a data privacy lead (DPL) who is responsible for dealing with any such concerns, in addition to overseeing questions in relation to this Privacy Policy and handling requests in relation the exercise of your legal rights. If you have any concerns, questions, or requests, please contact the DPL using the details set out below.

Our full details are:

Full name of legal entity: Signature Private Finance Limited

Name or title of DPL : David Hughes

Email address: david@signatureprivatefinance.co.uk

Postal address: Avon House, 435 Stratford Road, Solihull, West Midlands, B90 4AA

Telephone number: 0121 7463130

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