Your privacy is very important to us. This policy sets out certain information about what personal data we process about you, why we process it and how we handle it.
We are Century 10 Real Estate Finance Limited (company number: 10780162) (“we”, “us”, “our” and “ours”). We act as data controller in respect of the personal data you provide to us.
The personal data we collect and how we collect it
We process various items of personal data in order to provide our finance consultancy and brokerage services to clients (and, where our clients are companies, this includes personal data in relation to their directors, shareholders and personnel). This typically includes names, addresses, email and telephone contact details (including personal and/or, where the name of the recipient is specified, business contact details), and other client information pertinent to the application for a loan or such other services as we are engaged to provide. We may also process your personal identification information (such as your passport or other photographic identification), date of birth, national insurance number, details of your employment, financial affairs and your use of our website.
The personal data we collect about you will generally be provided to us directly by you (whether over the phone, in person, by email, your completion of any questionnaires or contact forms or otherwise), but may also be provided to us by a client or their representative (for example their lender, professional advisor or broker) in the course of our provision of services and in other cases may be collected from our business contacts and referrers or from publicly available resources and other third parties (such as Companies House, local authority planning portals, and credit reference and fraud prevention agencies).
You may also provide your personal data to us when submitting an enquiry through our contact form on our website.
Why we process your personal data
We collect and process personal data about our clients, prospective clients, referrers, other professionals, suppliers and other third parties and, if applicable, their personnel and other representatives, for the following purposes:
- the performance of our contractual engagements (or potential contractual engagements) with and services for clients (whether written or verbal and including taking initial steps to deal with enquiries);
- compliance with legal obligations (for example exchanging information with third parties for the purposes of fraud protection and credit risk reduction);
- to pursue our legitimate interests of the development of our business (for example retaining contact information for referrers and other professionals for carrying out client services or the mutual development of business opportunities);
- the establishment, exercise, resolution and/or defence of legal claims; or
- for direct marketing, which will generally be in pursuance of our legitimate interests or on the basis of your consent (further details are set out below).
If you are an individual or have confirmed to us that your/your employer’s business is a sole trader or partnership and you have opted in to receiving marketing communications and provided your name and email address for this purpose, we may process this personal data to contact you with news and information about our services and/or future transaction opportunities (as applicable) on the basis of your consent. You are able to withdraw your consent to such processing at any time by either contacting us at firstname.lastname@example.org or by following the “opt-out/unsubscribe” option in any email marketing communication we send to you.
If you are (or your employer is) a corporate entity (which generally means a limited company or an LLP), we will process this personal data to send you marketing emails containing news, information about our services and/or future transaction opportunities (as applicable) on the basis of our legitimate interests of the development of our business. We will send you these marketing communications by email unless you tell us that you do not want to continue receiving these marketing communications by contacting us at email@example.com or by following the “opt-out/unsubscribe” option in any marketing communication we send to you.
Who we share your personal data with
We may share your personal data, where necessary, with:
- our carefully selected service providers who provide IT and system administration services to enable us to communicate effectively with you (details of which can be provided upon request);
- credit reference agencies and fraud prevention agencies in order to carry out necessary searches;
- our insurers and insurance brokers, auditors and other professional advisors;
- any marketing agencies we may engage from time to time;
- regulators, government agencies, accreditation bodies and other authorities;
- other parties involved in any transaction or prospective transaction in respect of which we carry out our services, such as counterparties, prospective lenders, banks and/or investors, valuers and brokers;
- in the event that we sell or buy any business or assets, with the prospective seller or buyer of such business or assets and their advisors;
- if we or substantially all of our assets are acquired by a third party, with such third party and their advisors (as the personal data held by us about our clients will be one of the transferred assets).
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Where any of the above third parties are located outside of the European Economic Area (EEA), we will only disclose your personal data to such party provided that the transfer of such data outside of the EEA is undertaken in compliance with the data protection legislation to which we are subject.
Credit checks, fraud prevention and criminal convictions
We, and potential lenders or investors, may search records relating to you at credit reference agencies where applicable as part of our services to you or our client. They will add details of our search and the applicable application to your records and this will be seen by other organisations that make searches. We may also check at fraud prevention agencies to prevent or detect 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.
We and other organisations may access and use, from other countries, the information recorded by fraud prevention agencies.
If you have made a joint application or tell us that you have a spouse or financial associate, we will link your records together so you must be sure that you have their agreement to disclose information about them. Credit reference agencies also link your records together and these links will remain on your and their files until such time as you or your partner successfully files for a disassociation with the credit reference agencies to break that link.
We may also process personal data about you relating to criminal conviction or offences where this information has been provided by you. We will require your explicit consent to process such personal data.
What we do to protect your personal data
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk.
Retention of your personal data
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
The time periods vary depending on the particular circumstances, but one of the following specific periods are most likely to apply to you:
- If you (or your employer) are a client or third party whose personal data we are holding in relation to a specific transaction in respect of which we have provided our services, we will hold your information in relation to such matter for up to 6 years following the conclusion of the relevant transaction;
- If you are receiving marketing communications from us (either on the basis of your consent or our legitimate interests – see above), we will retain your personal data for this purpose unless you withdraw your consent (or, for corporate entities, tell us you no longer wish to receive these communications) or you do not open any of our emails for a period of more than 24 months.
- If you have made an enquiry through our website contact form and you do not become a client of ours, we will delete your information after 6 years.
If you would like any further specific information regarding how long we hold your personal data, please contact us using the details below.
Calls to and from our business land line numbers and mobile phone numbers may be recorded for training, monitoring and security purposes and to improve the quality of services that we provide to you.
Please be aware that other terms may apply to you.
Our website may, from time to time, contain links to and from other websites or applications. If you follow a link to any of these websites or applications, please note that these websites or applications may have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites or applications.
You have the right to withdraw your consent to us using your personal data at any time where you have provided any criminal conviction data to us by contacting us using the details below (although we may not be able to fully provide our services to you if you ask us to stop processing any criminal conviction data which is relevant to your transaction).
You also have the right to withdraw your consent (where provided) to email marketing as set out above.
You have the following rights in respect of your personal data:
- a right to access a copy of the personal data we hold about you;
- a right in certain circumstances to request a transfer of your personal data to you or a third party;
- a right in certain circumstances to have inaccurate personal data rectified, blocked, erased or destroyed;
- a right to object to our processing of your personal data in certain circumstances where we are relying on our legitimate interests as our lawful basis for processing your personal data;
- a right to object to processing for direct marketing.
You can exercise any of these rights by contacting us using the details below.
We may update this policy from time to time by updating the version on our website at www.century10finance.com/privacy-policy.
It is important that the personal data we hold about you is accurate and up to date and so please keep us informed of any changes to your personal data during our relationship with you.
Your right to make a complaint in respect of our use of your personal data.
You have the right to complain in respect of our use of your personal data. If you are a UK resident, your complaint should be addressed to the Information Commissioner’s Office (ICO) (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us first before you escalate your complaint.
You can contact us in respect of your personal data.
Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to firstname.lastname@example.org or sent by post to Century 10 Real Estate Finance Limited, 493-495 Chester Road, Manchester, M16 9HF.