..and we will make sure you’re correctly authorised to offer consumer credit facilities and you don’t breach the new FCA regulations
This policy (together with our Terms and Conditions and any other documents referred to) sets out the basis on which any personal data we collect directly from you, or is provided to us by our Appointed Representatives or our clients, will be processed by PPL.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. Our firm’s lawful basis for processing your personal data is done so under a Legitimate Interest as detailed in the General Data Protection Regulation; “the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.”
For all marketing activity by PPL, our firm’s lawful basis for processing your personal data is done so by Consent as detailed in the General Data Protection Regulation. By completing the form on the ‘Contact Us’ page of this website, you are providing your consent for us to contact you for marketing purposes.
For the purpose of the Data Protection Act 2018 (the “Act”), the data controller is Product Partnerships Limited of Salts Mill, Victoria Road, Shipley, BD18 3LA.
Information we collect from you
We will collect and process the following data about you:
Information you give us
This is information about you that you give us by filling in forms on our website, or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our portal, subscribe to/join our services, enter a competition, promotion or survey and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number.
Information we receive from other sources
We may obtain personal data about you from our clients and Appointed Representatives (including your name, address, date of birth, contact information, passport, driving licence and financial information) whenever you complete an online or paper form with them, make a telephone enquiry, or visit their premises.
Uses made of the information
We use information held about you in the following ways:
- To carry out our obligations arising from any contracts entered into between you and us or our Appointed Represntatives;
- To provide you with the information, products and services that you request from us;
- To notify you about changes to our service;
- In communications with and handling queries from regulators;
- To assist us in processing your enquiries and obtaining the services which you require;
- To help us identify you and any accounts that you hold with us;
- Complaints handling;
- To check correct processes are being followed by our Appointed Representatives;
- Marketing (providing you have opted-in);
- Fraud prevention and detection;
- Security vetting; and
- Improving our services.
Disclosure of your information
You agree that we have the right to share your personal information with selected third parties including:
- Business partners, suppliers of financial products and services and sub-contractors for the delivery of any service to them or you. This information will not be used for marketing purposes;
We will disclose your personal information to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or any terms and conditions of the supply of any services we may provide to you and other agreements; or to protect the rights, property, or safety of PPL, our clients/customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Any information provided directly to PPL by our clients or Appointed Representatives will not be disclosed by PPL to any third parties.
Storage of your personal data
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website or portal, you are responsible for keeping this password confidential. You should not share a password with anyone.
Any information provided by our clients or Appointed Representatives is stored on a Customer Relationship Management system, which is secure and we shall ensure that from time to time we use no lesser technical and organisational measures to safeguard personal data which is disclosed to us.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to safeguard your personal data, we cannot guarantee the security of your data transmitted to or through our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
You have the right to ask us not to process your personal data for marketing purposes. We will inform you (before collecting your data) if we intend to use your data for such purposes. You can exercise your right to prevent such processing at any time by writing to us at (for the attention of Data Protection Officer), Product Partnerships Limited, Salts Mill, Victoria Road, Shipley, BD18 3LA or at email@example.com, with the subject line “Removal from Marketing Preferences”, providing sufficient information to enable us to identify you.
Our site may, from time to time, contain links to and from the websites of our, for example, suppliers, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites 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.
Access to information
You have the right to request access to your personal data which we process. This formal request is made under the DPA and is referred to as a Data Subject Access Request. If you wish to exercise this right and make a Subject Access Request, you should;
- Put your request in writing; either by Email or by letter.
- Include proof of your identity and address (e.g. a copy of your driving licence or passport, and a recent utility or credit card bill);
- Specify the personal data you want access to, including any account or reference numbers where applicable.
You have the right to require us to correct any inaccuracies in your data free of charge. If you wish to exercise this right, you should:
- Either speak to us via telephone or put your request in writing;
- Provide us with enough information to identify you; and
- Specify the information that is incorrect and what it should be replaced with.
Under the provisions of the DPA, our firm’s lawful basis for processing personal data is based on a Legitimate Interest. We will only process your personal data providing we have a legitimate interest to do so.
The legitimate interest relates to a legal requirement for the firm to hold your personal data and financial information on record for up to a total of six years from the date the information is provided, or from the date of last correspondence with you, whichever is the latter. This six year period satisfies the requirement of our regulator, The Financial Conduct Authority and is also in line with other financial industry retention periods.
Product Partnerships Limited do not transfer personal data outside of the European Economic Area (EEA).
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We welcome your feedback and questions. If You wish to contact us, please send an email to firstname.lastname@example.org or you can write to us at Product Partnerships Limited Salts Mill, Victoria Road, Shipley, BD18 3LA or call us on 01274 921234.