How we use your personal information
Updated October 2021.
Your information will be held by Pure Commercial Finance Limited (PCF). This privacy notice is to let you know how PCF promise to look after your personal information.
Pure Commercial Finance Limited is registered in England and Wales under company number 08576127. You can contact us by writing to:
Pure Commercial Finance Limited, Kimberley House, Ty Glas Avenue, Llanishen, Cardiff, CF14 5DX or emailing us at compliance@pureadvisory.co.uk Alternatively you can call us on 02920 766565.
This privacy notice applies to all individuals or users (“data subjects”) whose Personal Data is processed by Pure Commercial Finance Limited (“us”, “we”, “our”).
Why should you to read this privacy notice?
During the course of dealing with us, we will ask you to provide us with detailed Personal Data relating to your existing circumstances, your financial situation and, in some cases, your health and family health history (Personal Data). This privacy notice is important as it allows us to explain to you what we will need to do with your Personal Data, and the various rights you have in relation to your Personal Data.
What is Personal Data?
Personal Data means any information that describes or relates to your personal circumstances. Personal Data may identify you directly, for example your name, address, date or birth, National Insurance number and the like. Your Personal Data may also identify you indirectly, for example, your employment situation, your physical and mental health history, or any other information that could be associated with your cultural or social identity.
In the context of providing you with assistance in relation to your Mortgage, Finance, Investment and Insurance requirements, your Personal Data may include:
- Title, names, date of birth, gender, nationality, civil/marital status, contact details, addresses and documents that are necessary to verify your identity.
- Employment and remuneration information, (including salary/bonus schemes/overtime/sick pay/other benefits), employment history.
- Bank account details, tax information, loans and credit commitments, personal credit history, sources of income and expenditure, family circumstances and details of dependents.
- Health status and history, details of treatment and prognosis, medical reports (further details are provided below specifically with regard to the processing we may undertake in relation to this type of information).
- Any pre-existing mortgage, finance, investment or insurance products and the terms and conditions relating to these.
- To fulfil a contract we have with you, or
- When it is our legal duty, or
- When it is in our legitimate interest, or
- When you consent to it.
- manage our relationship with you or your business;
- keep our records up to date, working out which of our products and services may interest you and telling you about them;
- develop and carry out our marketing strategy;
- develop new ways to meet our customers’ needs and to grow our business;
- develop services and defining what we charge for them;
- manage risk for us and our clients;
- support, develop and manage our staff members;
- develop and improve how we deal with financial crime, as well as doing our legal duties in this respect; and
- be efficient about how we fulfil our legal and contractual duties.
- Automated decision-making (making a decision solely by automated means without any human intervention.
- Profiling (automated processing of personal data to evaluate certain things about an individual). Profiling can be part of an automated decision-making process.
- Record and store your Personal Data in our paper files, mobile devices and on our computer systems (websites, email, hard drives, and cloud facilities). This information can only be accessed by employees and consultants within our Group and only when it is necessary to provide our Services to you and to perform any administration tasks associated with or incidental to that Service.
- Submit your Personal Data to Finance Providers, Mortgage Lenders, Commercial Lenders, Product Providers and Insurance Product providers, both in paper form and on-line via a secure portal. The provision of this information to a third party is essential in allowing us to progress any enquiry or application made on your behalf and to deal with any additional questions or administrative issues that mortgage lenders and insurance providers may raise.
- Use your Personal Data for the purposes of responding to any queries you may have in relation to any mortgage, finance product, investment or insurance policy you may take out, or to inform you of any developments in relation to those products and/or polices of which we might become aware.
- Companies within our Group including Pure Commercial Finance Limited, Pure Buy to Let Limited, Pure Wealth Management Limited and Pure Structured Finance Limited.
- Mortgage lenders, Finance lenders, Investment providers and insurance providers.
- Third parties who we believe will be able to assist us with your enquiry or application, or who are able to support your needs as identified. These third parties will include but may not be limited to, our Compliance department, product specialists, estate agents, providers of legal services such as estate planners, conveyancing, surveyors and valuers (in each case where we believe this to be required due to your particular circumstances).
- HM Revenue & Customs, regulators and other authorities
- UK Financial Services Compensation Scheme
- Credit reference agencies
- Fraud prevention agencies
- Organisations that introduce you to us, or Companies that we introduce you to
- Companies you ask us to share your data with.
- Confirm identities.
- Help prevent fraud and money-laundering.
- Fulfil any contracts you or your business has with us.
- We or an FPA may allow law enforcement agencies to access your personal information. This is to support their duty to detect, investigate, prevent and prosecute crime. FPAs can keep personal information for different lengths of time. They can keep your data for up to six years if they find a risk of fraud or money-laundering.
- Transfer it to a non-EEA country with privacy laws that give the same protection as the EEA.
- Put in place a contract with the recipient that means they must protect it to the same standards as the EEA.
- Transfer it to organisations that are part of Privacy Shield. This is a framework that sets privacy standards for data sent between the US and EU countries. It makes sure those standards are similar to what is used within the EEA.
- request copies of Your Personal Data that is under our control
- ask us to further explain how we use Your Personal Data
- ask us to correct, delete or require us to restrict or stop using Your Personal Data (details as to the extent to which we can do this will be provided at the time of any such request)
- ask us to send an electronic copy of Your Personal Data to another organisation should you wish
- change your marketing preferences (including withdrawing any consent in its entirety)