During the course of dealing with us, we will ask you to provide us with detailed personal information relating to your existing agreement types, your previous address history and details, your Date of Birth, your credit situation (Your Personal Data). This document 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.2. What do we mean by “Your Personal Data”?
Your Personal Data means any information that describes or relates to your personal circumstances. Your Personal Data may identify you directly, for example your name, address, date or birth. Your Personal Data may also identify you indirectly, for example, your employment situation. In the context of providing you with assistance in relation to your Mis sold Financial Agreement/PDL/PBA 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 details, employment history • Bank account details, loans and credit agreement details, personal credit history,3. The basis upon which our Firm will deal with Your Personal Data
When we speak with you about your Mis sold Agreement/PDL/PBA we do so, on the basis that both parties are entering a contract for the supply of services. In order to perform that contract, and to arrange the service you require, we have the right to use Your Personal Data for the purposes detailed below. Alternatively, either in the course of initial discussions with you or when the contract between us has come to an end for whatever reason, we have the right to use Your Personal Data provided it is in our legitimate business interest to do so and your rights are not affected. For example, we may need to respond to requests from our regulator regarding how we processed your claim, or to make contact with you to seek feedback on the service you received. In conjunction with requests from our regulator, we will use Your Personal data for contractual responsibilities we may owe our regulator Financial Conduct Authority, or for wider compliance with any legal or regulatory obligation to which we might be subject. In such circumstances, we would be processing Your Personal Data in order to meet a legal, compliance or other regulatory obligation to which we are subject.4. How do we collect Your Personal Data?
We will collect and record Your Personal Data from a variety of sources, our website (www.redhawklegal.co.uk), 3rd party data providers and lead generators who we have carried out Due Diligence on, and who have provided us with information regarding how they collected your data. Further information in relation to how your policy was sold you will provide to us verbally, and any missing information in writing, including email. We may also obtain some information from third parties, for example, lenders to ascertain if they sold you a PDL Policy or PBA policy.5. What happens to Your Personal Data when it is disclosed to us?
In the course of handling Your Personal Data, we will: • Record and store Your Personal Data in our 3rd party software provider “Bright Office” and on our computer systems (email, hard drives, and cloud facilities). This information can only be accessed by employees and managers within our Firm and only when it is necessary to provide our service to you and to perform any administration tasks associated with or incidental to that service • Submit Your Personal Data to your lender, bank, other institutes that may have mis-sold PDL/PBA, 3rd parties to progress the case such as FOS/FSCS, 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 our financial claim process for you and to deal with any additional questions or administrative issues that lenders and providers may raise. • Use Your Personal Data for the purposes of responding to any queries you may have in relation to any PDL/PBA claim and to progress it further, or to inform you of any developments in relation to those claims to which we might become aware. • Obtain your interest in products and services that we may be able to offer or arrange. We will usually ask about your interests in these products in order to gain your consent to future marketing. Where you have an existing relationship with us, we may contact you under our legitimate interests to offer products and services only where we think it reasonable to do so and have carried out an appropriate assessment. You can object at any time from receiving such marketing. • Administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.6. Social Media Platforms
Communication, engagement and actions taken through external social media platforms that our website participates on, are custom to the privacy policies held within each social media platform respectively. Users are advised to use social media platforms wisely and communicate/engage upon them with due care and caution in regard to their own privacy and personal details. Our websites will never ask for personal or sensitive information through social media platforms, and encourage users wishing to discuss sensitive details to contact them through primary communication channels such as by telephone or email. You should be aware that social media sites are likely to be collecting information about what you are doing all around the internet, including on our websites. You are advised before using such social media platforms that you do so at your own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account. In some cases, these sites will register that you are visiting our website and the specific pages you are on, even if you don’t click on the buttons but are logged into their services, like facebook or google. You should check their respective privacy policies to find out what they do with your information and to find out how to opt out or delete such information.7. Sharing Your Personal Data
From time to time Your Personal Data will be shared with: • The Financial Ombudsman Service/Financial Services Compensation Scheme/Lenders or any 3rd parties involved in the process for reclaiming your mis-sold PDL/PBA. Third parties who we believe will be able to assist us with your application. • Relevant Banks and Lenders responsible for processing your PDL/PBA case. • Payment processing facilities used to accept Credit/Debit card transactions from you for payment of our fees. In each case, your Personal Data will only be shared for the purposes set out in this customer privacy notice, i.e. to progress/complete your mis sold PDL/PBA case. Please note that this sharing of Your Personal Data does not entitle such third parties to send you marketing or promotional messages: it is shared to ensure we can adequately fulfil our responsibilities to you, and as otherwise set out in this Customer Privacy Notice. We do not envisage that the performance by us of our service will involve Your Personal Data being transferred outside of the European Economic Area.8. Security and retention of Your Personal Data
Your privacy is important to us and we will keep Your Personal Data secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard Your Personal Data against it being accessed unlawfully or maliciously by a third party. We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us, such as not sending confidential information over unprotected email, ensuring email attachments are password protected or encrypted and only using secure methods of postage when original documentation is being sent to us. Your Personal Data will be retained by us either electronically or in paper format for a minimum of six years, or in instances whereby we have legal right to such information we will retain records indefinitely.9. Website
Our website allows you to complete and submit an online form, to express your interest in our services. We request personal data from you such as your name, telephone number and email address in order that we may contact you about our PDL reclaim services. If you submit your data via the online submission form, your data will be stored securely and used by us to make contact with you about our service.10. Cookies
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. We may use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system. Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.11. Your rights in relation to Your Personal Data
You can: • 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 the basis of any consent you may have provided to enable us to market to you in the future (including withdrawing any consent in its entirety)12. How to make contact with our Firm in relation to the use of Your Personal Data
If you have any questions or comments about this document, or wish to make contact in order to exercise any of your rights set out within it please contact: Data Controller firstname.lastname@example.org 01792 917 987 If we feel we have a legal right not to deal with your request, or to action it in different way to how you have requested, we will inform you of this at the time. You should also make contact with us as soon as possible on you becoming aware of any unauthorised disclosure of Your Personal Data, so that we may investigate and fulfil our own regulatory obligations. If you have any concerns or complaints as to how we have handled Your Personal Data you may lodge a complaint with the UK's data protection regulator, the ICO, who can be contacted through their website at https://ico.org.uk/global/contact-us/ or by writing to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.