If after reading the Policy you have any additional questions about how we use your information please write to the Data Protection Officer, Secure Track Marketing Ltd, 71 – 75 Shelton Street, Covent Garden, London, WC2H 9JQ
Our Promise about your personal information
• We will not sell your personal information;
• We will maintain our security systems to keep your information safe;
• We will make it easy for you to access and control your information;
• We will comply with all relevant Regulatory requirements governing the use of personal information
Our status with the Information Commissioner's Office (ICO)
Secure Track Marketing Ltd T/A Secure Track Finance is registered as a Data Controller with the ICO under registration reference Z729627. We review our registration status periodically to ensure it accurately reflects the information we collect and how we use it.
- What Personal Information Do We Collect?
The personal information we collect depends on how you interact with us, ranging from browsing our website to formally engaging us to source an appropriate financial solution to meet your requirements.
Personal information will be collected when you use our website, when you contact us by telephone (or when we contact you by telephone), and throughout the application process, from making an initial enquiry to drawing down funds and our aftercare service. Please note calls between us are recorded and securely retained for training and compliance purposes.
Information will usually be collected directly from you or someone you have authorised to provide information to us such as a joint applicant or perhaps where you are acting as a guarantor. Information may however be collected from an Introducer or a Broker. When we are approached by an Introducer or a Broker on your behalf we undertake checks to ensure that you have been made aware of how your information will be used.
The information usually collected can be categorised as:
- Identification data – including your name, title, date of birth, national insurance number;
2. Documentary information – including Passports, Driving Licences and any other documentary evidence we request to verify your identity, residency and source of any deposit;
3. Contact information – including your address (and previous address if relevant), your telephone number and email address;
4. Employment information – including your employment status, income, employer name, length of employment, details of previous employment;
5. Financial information – including your income and expenditure, assets and liabilities, financial status, financial history, bank details, bank/credit card/mortgage statements, and debit / credit card details;
6. Transactional information – including the type of finance you have applied for (or are guaranteeing), repayments, term, exit strategy;
7. Public domain information – including information held at Companies House, in electoral rolls, and widely available on the internet;
8. Behavioural information – including details about your usage of our products and services;
9. Marketing preference information – details of any preferences you have advised us of regarding receipt of marketing literature, details of how and when you gave us “consent” (where this is required) to contact you;
We do not collect information classified as Special Category data, such as racial or ethnic origin, religious beliefs or criminal convictions etc unless it is lawful to collect such information and it is relevant to the transaction.
If you are an introducer of business into Secure Track Marketing Ltd, we will collect some identification data, contact information and employment information. We will also ask you to confirm your/your firms’ status with the Information Commissioner's Office, and that the client you are introducing has been made aware of how you will process and share their data with us.
How Do We Use Your Personal Information?
Any personal information we collect will be retained by Secure Track Marketing Ltd for as long as you are a client of Secure Track Marketing Ltd.
After you cease being a client of Secure Track Marketing Ltd we may retain your information for up to 6 years in order to respond to complaints or questions you may have, to demonstrate we have observed our Treating Customers Fairly principles and to fulfil any legal or regulatory requirements. For instance it is a regulatory requirement to retain information we gathered about you regarding your identity and residency for a period of time after you cease being a client.
We may retain your information for longer than 6 years if we are required to do so by law, or for research and statistical purposes where we can prove a “legitimate interest”. Where we do retain your information for more than 6 years we will ensure your information is used only for these stated purposes.
What Lawful Bases Do We Have For Processing Your Information?
Where you approach us for a quote for a financial product or request us to make an approach to a lender on your behalf, our lawful basis for processing your data is “contract” i.e. we are processing your data because you have asked us to do something before you enter into a contract.
For some of the data we process, we also have a “legitimate interest”, and / or a “legal obligation”. For example we have both a “legitimate interest” and a “legal obligation” to process information to prevent financial crime. There will also be occasions where we rely on your “consent” to process your data, for example we would not undertake a credit search on you without your consent.
Where you have made an enquiry with us we have a “legitimate interest” to keep you informed about relevant products and solutions that may be of interest to you. When we first collect information from you, we will give you the option to restrict this processing i.e. prevent any marketing material being received. Where you do not exercise your right to restrict this processing, all marketing literature we send to you will have an option to unsubscribe. You can also exercise your right to restrict processing for marketing purposes, or withdraw any “consent” you have previously provided to us, at any time. Please see “how can you restrict us sending you marketing material?” below.
Who Do We Share Your Information With?
Where you request we provide you with a quote for a financial product, we will share information with our panel of lenders. The information we share will be restricted to the information required to obtain a quote.
Where we approach a lender for a decision in principle, we will share information with the appropriate Lender. The information we share will be restricted to the information required to obtain a decision in principle.
In addition to the lenders as outlined above, we may share your personal information with:
- Professionals appointed by yourself, appointed by the lender or appointed by ourselves to negotiate and execute the transaction;
• Fraud Prevention Agencies in order to verify your identity and address, and for fraud prevention purposes;
• Credit Reference Agencies. Usually the Lender will either undertake a Credit Reference search themselves or request that you supply a Credit report, but on occasion Secure Track Marketing Ltd may undertake this search;
• Organisations that formally introduce you to us;
• Associated companies of Secure Track Marketing Ltd where we believe they can contribute to a competitive bespoke financial solution. Any approach we make to an associated company will be with your knowledge or on a no names basis;
• Organisations you ask us to share your information with;
• Third parties specifically contracted by Secure Track Marketing Ltd to deliver products and services to you as referred to in “our use of third parties” below.
How Do We Protect Your Information?
Information security is of great importance to Secure Track Marketing Ltd and to protect your information we have put in place suitable physical, electronic and managerial procedures. For example access to information is restricted internally within our business so that only colleagues with a legitimate need to access the information are permitted to access it.
We also have policies in place to ensure we do not collect excessive or special category information from you and systems to securely dispose of information in line with our retention policy.
Secure Track Marketing Ltd also employs the services of third parties to control and protect your information and regularly reviews the security controls in place.
How Can You Access And Control The Information We Hold About You?
You can access information we hold about you by writing to the Data Protection Officer at Secure Track Marketing Ltd, 71 – 75 Shelton Street, Covent Garden, London, WC2H 9JQ. To respond to your request we may need to contact you to ensure we fully understand your request and we will also need to verify your identity to ensure we do not disclose information to a third party (unless you specifically authorise us to do so). Information will usually be provided to you free of charge, unless defined as unfounded, excessive or repetitious in accordance with current regulations.
In certain circumstances you can request us to:
- rectify any inaccurate data we hold,
• complete any incomplete data,
• erase personal data (“the right to be forgotten”),
• restrict or object to the processing of your personal data.
Should you wish to request any of the above, please contact the Data Protection Officer at Secure Track Marketing Ltd, 71 – 75 Shelton Street, Covent Garden, London, WC2H 9JQ. In the event we do not believe your request meets the qualifying criteria or we are unable to comply with your request for any lawful reason, we will explain these reasons to you.
Your Right To Withhold Information
If you choose not to give us personal data which is required by ourselves or the lender as part of your application, it may delay or prevent your application from progressing.
For information about how you can delete and control cookies, visit www.aboutcookies.org or www.allaboutcookies.org. Please note deleting cookies may mean you lose any information that enables you to access the Web Site more quickly. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your browser if you are unsure as to how to adjust your privacy settings.
How Can You Restrict Us Sending You Marketing Material?
You will be given the option to restrict processing for marketing purposes when we first collect personal information from you. If you do not exercise this right to restrict processing, every subsequent marketing message you receive will give you the option to unsubscribe. However, you can also withdraw your consent at any time by emailing firstname.lastname@example.org, adding “STOP” to the email heading followed by the type of marketing you are seeking to stop i.e “STOP – email”, “STOP – telephone”, or “STOP – all”.
How Do You Make A Complaint About How We Have Used Your Personal Information?
If you are unhappy with how we have used your personal information you can submit a complaint to us by writing to the Complaints Manager, 9th Floor, 71 – 75 Shelton Street, Covent Garden, London, WC2H 9JQ, or contact us by phone on 0203 745 1080. You can also complain to the Information Commissioner's Office via their website https://www.ico.org.uk/
Our Use Of Third Parties
Secure Track Marketing Ltd may, from time to time, employ the services of other parties for dealing with matters that may include, but are not limited to, payment handling, delivery of purchased items, search engine facilities, advertising and marketing. We also use third parties to provide IT security solutions.
Changes To Our Business Ownership And Control
Secure Track Marketing Ltd may, from time to time, expand or reduce its business and this may involve the sale of certain divisions or the transfer of control of certain divisions to other parties. Information you have provided to us will, where it is relevant to any division so transferred, be transferred along with that division and the new owner or newly controlling party will, under the terms of this Policy, be permitted to use the information for the purposes for which it was supplied by you.
In the event that any information you have provided to us will be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your information deleted or withheld from the new owner or controller.
Our Review Of This Policy