1. Definitions and Interpretation In this Policy the following terms shall have the following meanings:
“Cookie”means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 12, below;
“Our Site”means this website, www.acrelanecapital.com;
“UK and EU Cookie Law”means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and
“We/Us/Our”means Acre Lane Capital Ltd, a limited company registered in England under 11518927 whose registered address is 2nd Floor, 4 Beaconsfield Road, St Albans,. Hertfordshire, AL1 3RD.
2. Information About Us
2.1 Our Site, www.Acrelanecapital.com, is owned and operated by Us.
2.2 Our Data Protection Register registration number is ZA457199
4. What Is Personal Data? Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.Personal data is, in simpler terms, any information about you that enables you to be identified.Personal data covers obvious information such as your name and contact details,but it also covers less obvious information such as identification numbers,electronic location data, and other online identifiers.
5. What Are My Rights? Under the GDPR, you have the following rights, which we will always work to uphold:
b) The right to access the personal data we hold about you. The information below will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details on our website to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have.Please contact us using the details on our website to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to data portability. This means that,if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
h) Rights relating to automated decision-making and profiling. For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details on our website.Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
6. What Data Do We Collect?Some data will be collected automatically by Our Site, other data will only be collected if you voluntarily submit it, for example, when signing up for an Account or making an enquiry. Depending upon your use of Our Site, We may collect some or all of the following data:
6.2 date of birth;
6.4 business/company name
6.5 job title;
6.7 contact information such as email addresses and telephone numbers;
6.8 demographic information such as post code,preferences and interests;
6.9 financial information
6.10 IP address (automatically collected);
6.11 web browser type and version (automaticallycollected);
6.12 operating system (automatically collected);
7. How Do You Use My Personal Data? Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data will be used for the following purposes:·
Providing and managing your Account - Providing and managing your access to Our Site - Personalizing and tailoring your experience on Our Site - Supplying our products and/or services to you. Your personal details are required in order for us to enter into a contract with you. - Personalizing and tailoring our products and/or services for you - Communicating with you. This may include responding to emails or calls from you - Supplying you with information by email (you may unsubscribe or opt-out at any time by emailing or writing to us using the contact details on our web page) - Analyzing your use of Our Site and gathering feedback to enable us to continually improve Our Site and your user experience. With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email AND/OR telephone AND/OR text message AND/OR post with information, news,and offers on our products AND/OR services. You will not be sent any unlawful marketing or spam. We will always work to fully protect yourrights and comply with our obligations under the GDPR and the Privacy andElectronic Communications (EC Directive) Regulations 2003, and you will alwayshave the opportunity to opt-out.
8. How do we process your application? We will perform credit and identity checks on youwith one or more Credit Reference Agencies (CRAs). We may also carry outfurther periodic searches at CRA’s to allow us to manage your account with us.
To do this, wewill supply your personal information to CRAs. This will include your name,date of birth and residential address. It may also include additionalinformation such as your salary, previous residential addresses and otherinformation you provide as part of your credit application.
The CRAs will match this information to the records they hold about you, and provide inreturn, both public information (including the electoral register) and shared credit information in relation to your financial situation and financial history.
CRA’s will supply to us both public (including the electoral register) and shared credit,financial situation and financial history information and fraud prevention information.
We will use this information to - Assess your creditworthiness and whether you can afford to take the product - Verify the accuracy of the data you have provided to us - Prevent criminal activity, e.g fraud and money laundering - Manage your account(s) - Trace and recover any debts - Ensure any offers provided to you are appropriate to your circumstances.
We will continue to exchange information about you withCRA’s while you have a relationship with us. We will also inform the CRA’sabout your settled accounts. If you borrow anddo not repay in full or on time, CRA’s will record the outstanding debt. Thisinformation may be supplied to other organisations by CRA’s
When CRA’s receive a search from us they will place a searchfootprint on your credit file that may be seen by other lenders.
If you are making a joint application, or tell us that youhave a spouse of a financial associate, we will link your records together, soyou should make sure you discuss this with them, and share with them thisinformation, before lodging the application. CRA’s will also link your recordstogether and these links will remain on your and their files untilsuch time as your partner successfully files for a disassociation with theCRA’s to break the link.
The identities of the CRA’s, their role also asfraud prevention agencies, the data they hold, the ways in which they use andshare personal information, data retention periods and your data protectionrights with the CRA’s are explained in more detail at www.equifax.co.uk/crain
9. How Long Will You Keep My Personal Data? We will not keep yourpersonal data for any longer than is necessary in light of the reason(s) forwhich it was first collected.
10. How and Where Do You Store or Transfer MyPersonal Data?We will usually store or transfer your personal datawithin the European Economic Area (the “EEA”). The EEA consists of all EUmember states, plus Norway, Iceland, and Liechtenstein. This means that yourpersonal data will be fully protected under the GDPR or to equivalent standardsby law.We may store or transfer some or all of your personal datain countries that are not part of the EEA. These are known as “third countries”and may not have data protection laws that are as strong as those in the UKand/or the EEA. This means that we will take steps with the person to whom weare transferring or storing data with to ensure that your personal data istreated just as safely and securely as it would be within the UK and under theGDPR.We may also transfer your data to a third party based inthe US, this may be protected if they are part of the EU-US Privacy Shield.This requires that third party to provide data protection to standards similarto those in Europe.Please contact us using the details on our website forfurther information about the particular data protection mechanism used by uswhen transferring your personal data to a third country.
11. Do You Share My Personal Data? We may share your personal data with other companies in our group. This includes subsidiaries and affiliated companies.We may sometimes contract with the third parties to supply certain products and services or for the transfer or sale of loans or a loan portfolio. These may also include payment processing, delivery,and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold.If any of your personal data is required by a third party,as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations,and the third party’s obligations under the law.If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as woul be within the UK and under the GDPR. In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
12. What Happens If Our Business Changes Hands?
12.2 In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.
13. How Can You Control Your Data?
13.1 In addition to your rights under the GDPR, when you submit personal data via Our Site,you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails).
13.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service(“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
14. Your Right to Withhold Information.
14.1 You may access certain areas of Our Site withoutproviding any data at all.
14.2 You may restrict your internet browser’s use ofCookies.
15. How Can You Access Your Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 16. There is not normally any charge for a subject access request.If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response,including a copy of your personal data within that time. In some cases,however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request.You will be kept fully informed of our progress.