Privacy notice

Our approach to privacy

This Privacy Notice sets out how the personal information which you supply to ActivTrades plc directly or through StreamBridging, a trading name in relation to property lending, is used. ActivTrades plc is registered in England under company number 05367727. ActivTrades plc and its trading names are together referred to as “our”, “us” or “we”. It also describes how we use cookies on our website.

We reserve the right to change this Privacy Notice from time to time and revised terms will be posted on our website.

This notice, along with the Cookie notice is part of our Website terms and conditions and applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.

If you want to understand how your personal information is collected via other means, separate from our website, please see the supplemental terms and conditions under which we provide our services to you.

If you have any questions about this Privacy Notice please contact our privacy officer at [email protected].

 

What information do we hold about you and how do we collect It?

We collect your personal information in a number of ways related to the use of our lending products which we will store and process. The information we collect about you (either directly or through your financial advisor) includes your name, company names, date of birth, address, e-mail address, telephone number, profession and employment details, financial details, other contact details and any other details you provide in line with us providing products and services to you. This information is collected in the following ways:

• when you submit your contact details on the web site related to an enquiry;
• when we obtain personal data about you from qualified third parties in the process of signing you up to our services, for example for credit checks, document verification and background checks;
• when you provide your details to us in hardcopy versions of these forms or in letters related to our services;
• when you apply for or purchase any of our other products or services; and
• when you give your details to a member of our team directly (for example on the telephone) or your financial advisor.

We may also use cookies or similar technologies to collect website usage information - please see the section on cookies below.

We will only ask you to supply personal information and only such information where we believe that it is necessary to provide a service you have applied (or are in the process of applying for), or if it relates to a legal or regulator requirement and only if it is in our clients’ interest to do so. For example, we may ask you to provide us with your location prior to entering into a business relationship, if we think that by doing so we can give you a customised product or service, which is compliant with the local legislation or in our opinion better serves the needs of customers from that country, or to provide us your nationality when you apply for an account as this is a regulatory requirement.

 

What do we do with your personal information?

We will use your personal information, and may share your personal information with other third parties acting on our behalf, for one or more of the following purposes:

• to administer the service or provide you the product that you signed up to, for example to send you account statements, to manage your personal account page or to process transactions;
• to respond to any enquiry or complaint you may make to us in relation to the use of our services, for example when contacting our customer support;
• to prevent or detect fraud or abuses of our website, for example, by requesting verification information in order to reset your account password (if required);
• for research purposes, where we may contact you to ask for your feedback;
• for statistical purposes to better understand our users’ needs, behaviour and preferences;
• for regulatory and legal compliance purposes;
• for our own administrative purposes, including training our staff, conducting internal audits or transferring assets as part of a sale, purchase or investment in the business; and
• to provide you with general information about our products and services, e.g. by our newsletter; or to provide you with personalised offers, or information about events or webinars organised by us in line with your contact preferences (only when you have given consent to do so).

If at any time you wish to withdraw your consent to the use of your personal information for marketing purposes, then please email us at [email protected]. You may be required to submit a proof of your identity and sufficient evidence of the information that you want us to change.

 

Grounds for processing your personal information

To process your personal information lawfully we need to rely on one or more valid legal grounds. The primary legal ground for our processing of your personal information is contractual. We will rely on this legal ground when, for example, you sign up for a product trial, sign up for any of our products and services or provide us your contact details in order for us to provide you more information on our products and services. Other legal grounds we may rely on include:

• our legitimate interests as a business (except where your interests or fundamental rights override these). For example, it is within our legitimate interests to use your personal information to prevent or detect fraud or abuses of our website and any other authentication purposes; or
• our compliance with a legal or regulatory obligation to which we are subject (for example to verify your identity, and any processing that is necessary for opening an account with us); or
• based on your consent to process your information (for example where we send you information for marketing purposes to send you on related goods and services we provide).

 

Disclosure of your personal information

There are circumstances where we may wish to disclose or are compelled to disclose your personal information to third parties. For example, we may pass on your data to:

• UK subsidiaries, branches or associated offices within the ActivTrades Group and its trading names;
• government institutions, authorities and courts (when legally obliged to do so);
• service providers who are processing the data on our behalf under contractual obligations of confidentiality;
• financial institutions and payment providers to facilitate transactions; and
• credit reporting or reference agencies.

These disclosures of personal information will only take place in accordance with the law and for the purposes listed above.

We will not sell or otherwise give access to your personal data to any third party for commercial interests or advertising except for the purpose of fulfilling our legal or contractual obligation or where we have your permission.

 

Recruitment process

In some cases, we may process your data regardless of whether you are a client, for example when you apply for vacant positions with us and you are contacted directly or through a third party, or you are a real owner or a member of a management / supervisory body of our client. In these cases, your personal data is processed in accordance with the principles in this policy notice.

We collect and process some or all of the following types of information from you:

• Information that you provide when you apply for a role. This includes information provided through an online job site, via email, in person at interviews and/or by any other method;
• In particular, we process personal details such as name, email address, address, date of birth qualifications, experience, information relating to your employment history, skills and experience that you provide to us;
• If you contact us, we may keep a record of that correspondence;
• A record of your progress through any hiring process that we may conduct; and
• Details of traffic data, location data, weblogs, and other communication data, the site that referred you to us and the resources that are accessed.

 

Security of your personal information

We will take all reasonable steps to ensure that any personal data that you provide via the website is kept secure. Although we endeavour to protect your personal data, because of the nature of the Internet, we cannot guarantee the security of any data that you transmit to the website. Furthermore, any inward transmission of data, such as email, is carried out at your own risk.

Third party information provided by you

Where you provide us with personal information relating to others, for example, your agents, clients or joint account holders for the purpose of opening and administering your account, you confirm that you have their consent or are otherwise entitled to provide this information to us and for us to use it in the ways described in this Privacy Notice.

International transfer of personal data

We may transfer your personal data to a third party in countries outside the UK for further processing in accordance with the purposes set out in this Privacy Notice. In these circumstances we will, as required by applicable law, ensure that your privacy rights are adequately protected by appropriate technical, organisational, contractual or other lawful means.

 

Retention of your personal information

Your personal information will be retained for as long as it is necessary to carry out the purposes set out in this Privacy Notice (unless longer retention is required by law). However, we will not retain any of your personal information beyond this period and the retention of your personal information will be subject to periodic review. For example, we intend to delete your contact details after two years after your initial request, if we don’t hear back from you, unless you have entered into a contract with us in the meantime. If you entered into a business relationship with us, your personal data will be kept for at least seven years after your relationship with us has ended. Call recordings, backed-up and archived data, though not processed anymore and kept in a secure way, may be kept longer than this for technical reasons. We may keep an anonymised form of your personal information, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.

 

Your legal rights under data protection law

Data protection law provides individuals with certain rights, including the right to access, rectify, withdraw consent, erase, restrict, transport, and object to the processing of their personal information.  Individuals also have the right to lodge a complaint with the relevant information protection authority if they believe that their personal information is not being processed in accordance with the law. Further information about your rights is set out below:

• Right of access to your personal information. You can verify some of the personal data that we hold by contacting us. Furthermore, you have the right to confirm that your personal information is being processed, to request our legal right to do so and obtain a complete copy of the personal information we hold about you. If you would like to obtain a copy of this information please contact our client services team or email us at [email protected]. You may be required to submit a proof of your identity.
• Right to rectification. You may request that we rectify any inaccurate and/or complete any incomplete personal information. If you do notice any inaccuracies in your personal information, please notify our client services team as soon as possible. We will then correct our records and notify any third parties to whom such personal information may have been transmitted as described above. If you are unable to contact our client services team, please email [email protected].
• Right to withdraw consent. Where you have provided us prior consent to the processing of your personal data, you may, as permitted by law, to withdraw your consent at any time. Such withdrawal will not affect the lawfulness of processing based on your previous consent and will not affect our processing of your personal information under any other basis of processing (e.g. processing your information for providing you with our products and services). Please note that if you withdraw your consent, you may not be able to benefit from certain service features for which the processing of your personal information is essential.
• Right to object to processing. You may, as permitted by law, request that we stop processing your personal information.
• Right to erasure. You may request that we erase your personal information and we will comply, unless there is a lawful reason for not doing so. If you terminate a contract with us, we may still retain your personal information if this is necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes, and to prevent fraud and abuse.
• Your right to lodge a complaint with the supervisory authority. Please contact us in the first instance with any questions or if you have a complaint in relation to how we process your personal information. However, you do have the right to contact the relevant supervisory authority directly. To contact the Information Commissioner’s Office in the United Kingdom, please visit the ICO website for instructions.

 

Linked websites

Please note that any websites that may be linked to our websites are subject to their own privacy policies.

 

Cookies

Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. They do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improve your experience.

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

The cookies we use are for statistical purposes only and we do not store any personal identifiable data about you.

Most browsers are initially set to accept cookies, but you can alter this if you prefer. For more information about our use of cookies, please refer to our Cookie notice.