PRIVACY POLICY
We take your privacy very seriously and we ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint
WHO WE ARE
Pivot Lending Ltd uses and is responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
THE PERSONAL INFORMATION WE COLLECT AND USE
In the course of providing bridging loans collect the following personal information when you provide it to us:
name and job title;
address history
contact information including email address;
demographic information such as postcode, preferences and interests.
INFORMATION COLLECTED FROM OTHER SOURCES
We may also obtain personal information from other sources as follows:-
loan and financial intermediaries who you have agreed will provide us with information to assist with your loan application;
credit search agencies to determine your suitability for the loan; and
your employer to determine your suitability for the loan.
HOW WE USE YOUR PERSONAL INFORMATION
We use your personal information to:
fulfil our contractual obligations;
carry out due diligence to determine your suitability for any loans you are applying for;
internal record keeping;
improve our products and services;
send you promotional emails about new products, special offers or other information which we think you may find interesting where you have provided us with consent to do so;
contact you for market research purposes where you have provided us with consent to do so;
WHO WE SHARE YOUR PERSONAL INFORMATION WITH
We routinely share your personal data with legal advisers, credit search companies, RICS property valuers, and external finance agents for the purposes of fulfilling our obligations to you and determining your suitably for the loan you have applied for.
For a list of these organisations please contact us at info@pivotfinance.co.uk or telephone 020 3695 5510.
We will share personal information with law enforcement or other authorities if required by applicable law.
We will not share your personal information with any other third party.
Whether information has to be provided by you, and if so why
The provision of name, address, is required from you to enable us to provide you with bridging loans for commercial and residential properties. We will inform you at the point of collecting information from you, whether you are required to provide the information to us.
consumer credit reports
In order to process your application, we will perform credit and identity checks on you with one or more Credit Reference Agencies (CRAs). We may also carry out further periodic searches at CRA’s to allow us to manage your account with us.
To do this, we will supply your personal information to CRAs. This will include your name, date of birth and residential address. It may also include additional information such as your salary, previous residential addresses and other information you provide as part of your credit application.
The CRAs will match this information to the records they hold about you, and provide in return, 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; and
Ensure any offers provided to you are appropriate to your circumstances.
We will continue to exchange information about you with CRA’s while you have a relationship with us. We will also inform the CRA’s about your settled accounts. If you borrow and do not repay in full or on time, CRA’s will record the outstanding debt. This information may be supplied to other organisations by CRA’s
When CRA’s receive a search from us they will place a search footprint on your credit file that may be seen by other lenders.
If you are making a joint application, or tell us that you have a spouse of a financial associate, we will link your records together, so you should make sure you discuss this with them, and share with them this information, before lodging the application. CRA’s will also link your records together and these links will remain on your and their files until such time as your partner successfully files for a disassociation with the CRA’s to break the link.
The identities of the CRA’s, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRA’s are explained in more detail at www.equifax.co.uk/crain
HOW LONG YOUR PERSONAL DATA WILL BE KEPT
We will hold your personal information for the period for which your loan is in force and for a period of 6 years thereafter.
REASONS WE CAN COLLECT AND USE YOUR PERSONAL INFORMATION
We rely on Contract as the lawful basis on which we collect and use your personal data i.e. the processing is necessary to fulfil our contractual obligations to you.
We also rely on consent as the lawful basis on which we collect and use your personal data where you have given clear consent for us to process your personal data to provide you with information about our products and services and any future offers and to determine your suitability for the loan you have applied for.
YOUR RIGHTS
Under the General Data Protection Regulation, you have a number of important rights free of charge. In summary, those include rights to:
fair processing of information and transparency over how we use your use personal information;
access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address;
require us to correct any mistakes in your information which we hold;
require the erasure of personal information concerning you in certain situations;
receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations;
object at any time to processing of personal information concerning you for direct marketing;
object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you;
object in certain other situations to our continued processing of your personal information;
otherwise restrict our processing of your personal information in certain circumstances.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individual’s rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
email us at info@pivotfinance.co.uk, write to us at 1st Floor, 17-19 Maddox Street, London, W1S 2QH or telephone 020 3695 5510.
let us have enough information to identify you (e.g. your account number, full name, and address),
let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
let us know the information to which your request relates, including any account number.
KEEPING YOUR PERSONAL INFORMATION SECURE
We have appropriate security measures in place to prevent personal information from being accidentally lost, used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
HOW TO COMPLAIN
We hope that we can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
CHANGES TO THIS PRIVACY NOTICE
This privacy notice was published on 14th May 2018
We may change this privacy notice from time to time. You should check this policy occasionally to ensure you are aware of the most recent version.
HOW TO CONTACT US
Please contact us if you have any questions about this privacy notice or the information we hold about you.
If you wish to contact us, please send an email to info@pivotfinance.co.uk, write to us at 1st Floor, 17-19 Maddox Street, London, W1S 2QH or telephone 020 3695 5510.