Astmoor Finance Limited understands how important your privacy is and we take its security seriously. Please read this policy carefully, along with our Client Terms of Business and Introducer Agreement, together with any other documents referenced within this policy.
Astmoor Finance is a trading style of Astmoor Finance Limited (company registration number: 12297014). Astmoor Finance is directly authorised by the Financial Conduct Authority (the “FCA”). Our FCA registration number is 941193. You can check our authorisation and permitted activities on the Financial Services Register by visiting the FCA’s website or by contacting the FCA on 0800 111 6768. Astmoor Finance is a credit broker not a lender. The firm deals with a panel of lenders.
|Application||means a proposal with the intention of sourcing a product or service for you. Applications, Apply, and Applying shall be interpreted accordingly|
|Credit Reference Agency (CRA)||means a person which provides credit references on businesses and individuals. Credit Reference Agencies shall be interpreted accordingly|
|Credit Search||means a search carried out with a Credit Reference Agency. Credit Searches shall be interpreted accordingly|
|Provider||means any entity to which we may make an Application including (but not limited to) banks, peer-to-peer lenders, private investors, alternative finance providers, insurers and other intermediaries. Providers shall be interpreted accordingly|
Data protection and regulatory notice
We shall comply with all applicable requirements of the General Data Protection Regulation ((EU) 2016/679) (the “GDPR”) and any other relevant regulatory requirements currently in effect and those that come into effect in the future. We are registered with the Information Commissioner’s Office (the “ICO”) as a “Data Controller” which has meaning given to it by the ICO and more information is detailed on the ICO website. Our ICO reference number is ZA563946.
You are providing your personal information to us to enable us to assist you in obtaining appropriate products and/or services in support of your requirements, along with providing information on your business and requirements. In processing this information, we may share this data with carefully selected third-parties who may either be a Provider or a packager / broker of such services whom the company believes can satisfy your requirement. We may also share data with other third-parties to assess your requirement and source appropriate solutions such as comparison platforms.
We take our responsibilities under GDPR seriously and we will at all times respect your privacy and legal rights. We will never sell or distribute any data you have provided to us to any unrelated or unconnected third-party except where necessary to source a product or service with a Provider or a packager / broker of such services, or to adhere to prevailing regulatory and compliance obligations. We may contact you on an ongoing basis to inform you about relevant products and services only if you have given us specific permission to do so and at any time you may opt out of receiving such contact and information from us.
Your information is collected and may be shared and processed with our Providers and third-party service partners to:
- Help make decisions about credit, loan or mortgage applications and credit or insurance related services
- Establish the best possible source of financial support to satisfy your borrowing requirements
- Trace debtors, recover debt, prevent money laundering and financial fraud
In order to fully assess your circumstances in support of any Applications we make, we and relevant Providers may wish to search your records with selected Credit Reference Agencies (CRAs) by conducting Credit Searches. Credit Searches may be conducted on any partner, director, or beneficial stakeholder connected to the applicant entity and its wider group and relevant requirement/requirements. Credit Searches may add a record of the details of the search made to the relevant credit file when they are conducted. We and Providers may see Credit Searches conducted by other organisations. Similarly, other organisations that carry out such searches may see Credit Searches conducted by us and Providers we approach.
Providers may be required to check your details with Fraud Prevention Agencies as part of their assessment of an Application. If you provide us false or inaccurate information then this may be recorded at such agencies.
An association between you (or another individual a Credit Search is conducted on) and any named partner or spouse may be created at the Credit Reference Agency. This may link your financial records, each of which may be taken into account in all future Applications by either or both of you. If an association already exists then your application may be assessed with reference to these associated records. This situation will continue until one of you successfully files a disassociation with the relevant Credit Reference Agency.
We will generally collect your personal data directly from you, or via third-parties such as introducers or other intermediaries. We may also collect data from and/or combine your personal data with information from other source such as CRAs, fraud prevention agencies, marketing affiliates, agents working on our behalf and publicly available sources such as Companies House, your websites, and social media.
We collect and process your data when:
The nature of information provided may depend on the nature of the requirements you seek our assistance with and may include but is not limited to details as follows:
Who you are:
Your employment status and sources of income:
Your financial commitments and position:
We will not collect or retain any personal data from you we do not need for our purposes. The legal grounds that are relevant to us in justifying our processing of your personal data are as follows:
- To source your consent or to process your consent to share your personal information with our Providers for a specific purpose, such as Applying for a product or service
- To market relevant services we and our Providers can provide to you and your businesses where you have opted in to receive this marketing
- To perform our contract with you or to take specific steps to enter into contract with you
- To source further information about you from third-party data providers such as CRAs
- To enable Providers and packagers / brokers of such services whom we believe can satisfy your requirement to contact you to progress the required solution for you and/or your businesses
- To verify with Providers and packagers / brokers of such services that a solution has been provided or to ascertain the current status of any Application that has been made, including applications that entity may have previously received for you or your businesses
- To send you service communications and notifications including login access codes, regulatory notices and information from a Provider pertaining to an agreement you or your business has entered or is entering into
- To personalise or improve aspects of our service, systems and websites including troubleshooting and quality control testing, as well as responding to any queries or complaints raised by you or about you and your businesses
- For us to comply with our legal obligations (not including contractual obligations)
- For us to meet vital interests such as the protection of someone’s life
- To detect and prevent financial crime, including fraud
- To notify other people or organisations such as CRAs, fraud prevention agencies, regulatory bodies such as the FCA, the Prudential Regulation Authority, the Financial Ombudsman Service, the ICO, courts and other organisations where it is necessary for the administration of justice, to protect vital interests and to protect the security or integrity of our business operations, including the National Crime Agency
- For your legitimate interests or the legitimate interests of a third-party unless there is a good reason to protect your personal data which overrides this legitimate interest.
We are required under regulation to keep your basic personal data, such as name, address, and contact details for a minimum of 6 years, after which time it will be erased. The information used for marketing purposes will be kept with us until you notify us that you no longer wish to receive marketing communication from us.
Your data is securely stored on our customer relationship management systems and client file directories. With the exception of signed documentation pertaining to a contract or agreement, we do not typically retain physical copies of your data.
Should you wish to be provided with the details of the data and information we hold on you please email email@example.com detailing your request and the information you wish to be provided with. You have the legal right to be provided with these details and to receive a copy of all data that we hold about you. At your request Astmoor Finance will amend/correct/destroy all data that we hold about you and remove all records from our systems, except where the right to erasure conflicts with our legal obligation to keep hold of your data to comply with financial or other regulations, or other relevant circumstance as outlined by the ICO’s guidance.
Some Providers and Credit Reference Agencies to whom your data may be provided may require you to apply in writing directly in respect of any request for information or erasure and a fee may be payable for the provision or erasure of such information.
As part of providing our services to you, we may share data with Providers and relevant third-parties by interfacing with third-party systems or via an application programming interface (API). To enable us to manage your data effectively, you agree to grant us an irrevocable, royalty-free, sub-licensable, transferable, perpetual license to use, copy, reformat, translate, excerpt (in whole or in part) and distribute these data for any purpose on or in connection with our services, systems and websites, and to prepare derivative works of, or incorporate into other works.
If you wish to raise a complaint on how we have handled your personal data, you can so by following the steps in the section referencing “Complaints” in our Client Terms of Business, or our Introducer Agreement, and marking your complaint for the attention of the Data Protection Officer.