01722 448050

PRIVACY

POLICY

privacy

We understand that we have a responsibility to protect and respect your privacy and look after your personal data.

This notice explains what personal data we collect, how we use and store it, and the reasons we may need to disclose it to other parties. 

Data Protection law changed on 25 May 2018 when the General Data Protection Regulations (GDPR) came into force, and this Privacy Notice sets out your rights under these new laws.

When we refer to “we” (or “our” or ‘”us”), that means Focus Finance Limited and all trading styles.

Registered in England & Wales Number 04168180 at 1 London Road Office Park, Salisbury.  SP1 3HP

Focus Finance Limited are Commercial Finance Brokers based in Salisbury, Wiltshire.  We act as a broker for our customers.  Focus Finance Limited are Authorised and Regulated by the Financial Conduct Authority: FRN 797598

For the data we collect and subsequently process we are the “Data Controller” and the “Processer”.  This means that we make decisions about how and why we use your personal data. We are responsible for making sure that your personal data is used in accordance with applicable data protection laws and this Notice.

Our approach to data protection is built around four key principles. They’re at the heart of everything we do relating to personal data.

Transparency: We take a human approach to how we process personal data by being open, honest and transparent.

Enablement: We enable connections and efficient use of personal data to empower productivity and growth.

Security: We champion industry leading approaches to securing the personal data entrusted to us.

Stewardship: We accept the responsibility that comes with processing personal data.

Data protection law allows us to use your personal data if we have a lawful basis to do so.  The reasons we process your personal data are:

Contract: the processing is necessary for a contract you have with us, or because you have asked us to take specific steps before entering into a contract (e.g. to provide you with documentation regarding our products and services).

Legal obligation: the processing is necessary for us to comply with our legal and/or regulatory obligations (e.g. HMRC reporting or Credit Reference Agencies, financial crime).

Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party (e.g. to market to you similar products and services in the future) to process the personal data and they’re not overridden by your rights

Consent: we may also use your data when you give consent.  You have given clear consent for us to process your personal data for a specific purpose.  You can withdraw this consent at any time, in which case we will cease to use it, unless we have a right and a need to continue processing it for one of the other reasons set out above.

We retain records of your queries and correspondence, in the event you contact us.  The personal data that we may collect from you may include any special types of information or location-based information, including but not limited to:

  • Contact details such as names, phone numbers and postal and email addresses;
  • ID verification information and copies thereof; this may include passport, driving licence, public record certificates, as well as dates of birth, address confirmation and signatures;
  • Financial information such as bank/payment card details, payment histories, personal and business bank statements and company accounts;
  • What we learn about you from verbal or written correspondence with you;
    Business details such as forecasts, business plans and CV’s;
  • Information obtained from fraud prevention agencies and credit reference agencies including but not limited to associated contacts, address history, voters roll and financial information such as credit account data.

We collect some information about you automatically when you visit our websites or use our services, like your IP address and device type.  We also collect information when you navigate through our websites and services, including what pages you looked at and what links you clicked on.  This information is useful for us as it helps us get a better understanding of how you’re using our websites and services so that we can continue to provide the best experience possible (e.g. by personalising the content you see).  Some of this information is collected using cookies and similar tracking technologies.  If you want to find out more
about the types of cookies we use, why, and how you can control them, take a look at our cookie notice.

We need to know your basic personal data to provide you with an accurate recommendation for your personal circumstances.  We will not collect any personal data from you we do not need to provide and oversee this service to you.

For processing of data to be lawful under GDPR Focus Finance Limited use:

(a) Consent: the individual has given clear consent for you to process their personal data for a specific purpose.

(b) Contract: the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract.

(c) Legal obligation: the processing is necessary for you to comply with the law (not including contractual obligations).

(d) Vital interests: the processing is necessary to protect someone’s life.

(e) Public task: the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law.

(f) Legitimate interests: 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. (This cannot apply if you are a public authority processing data to perform your official tasks.)

We use information about you in the following ways:

  • To process enquiries that you or a third party acting with your consent have submitted to us;
  • To comply with any contractual obligations such as administering and managing your account as well as to trace and recover debts;
  • To meet our legal and regulatory requirements;
  • To help us identify you, any accounts you hold with us and keep this information up to date;
  • To provide customer care, including responding to your requests if you contact us with a query;
  • To share your personal data with certain third party service providers such as payment services and credit reference agencies (CRAs). This information may be shared with other organisations by the CRA.
  • To detect and prevent criminal activity such as fraud and to verify what you have told us is correct we may perform identify checks, anti-money laundering checks and checks with Fraud Prevention Agencies (FPAs)
  • To notify you about changes to our website, services or terms and conditions;
  • To enable us to review, improve and provide you with information about our products and services which we feel may interest you;
  • To deal with requests from you to exercise your rights under data protection laws.

Automated Decision Making: Focus Finance Limited will pass your data captured to funders or banks who may use automated decision-making in respect of your application for finance.  We will only collect the minimum amount of data needed and have a clear retention policy for the profiles we create.

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or any significant affects.  You can request human intervention and challenge a decision made this way by contacting privacy@focus.finance.

At times we may disclose personal data to persons in our group of companies.  This can include subsidiaries, holding companies, or any other subsidiaries involved in our business.  We do not give or sell your personal data to third parties for marketing or advertising purposes but third party disclosure may occur for the following reasons:

  • When we are legally required to do so by law enforcement agencies and government or regulatory bodies;
  • To agencies that help in fraud prevention including credit reference agencies;
  • To allow auditors to complete their regulatory and contractual requirements;
  • For the provision of services on our behalf (for example processing card payment and direct debit transactions);
  • Should we sell any or all of our business to a third party;
  • Companies we have a joint venture or agreement to co-operate with and companies you ask us to share your data with.

All the personal data we use is controlled by Focus Finance Limited in the UK, however, for the purposes of IT hosting and maintenance, from time to time, your data may be transferred to and stored in a country outside the EEA in relation to provision of the services. 

The laws in these countries may not provide you with the same protection as in the EEA but the service provider will take steps to ensure that the necessary levels of protection are in place.  This may include measures such as entering into a written agreement with us to provide a contractual undertaking that they will keep your personal information secure. this information is located on servers within the European Union.

No third parties have access to your personal data unless the law allows them to do so.  We have a Data Protection regime in place to oversee the effective and secure processing of your personal data. 

By providing your personal data to us, you agree to this transfer and storage.

We will retain your data only for as long as necessary in accordance with applicable laws.  We may keep your data for up to seven years after your contract with us has ended as we may not be able to delete your data before this time due to our legal and/or accountancy obligations.  For our protection, certain data relating to criminal activity and fraud will be kept indefinitely.

We will retain your personal information for longer than seven years where you do not object or opt-out of receiving email marketing communication from us about similar products and services.  In this case we will store your personal information until you object or opt-out.

Under data protections laws you have a number of rights in relation to the collection and use of your personal data. These are:

  • The right to access to the information we hold about you;
  • The right to rectification so you can have your personal data corrected if it is inaccurate and to have incomplete personal data completed;
  • The right to erasure – you have the right to request that we delete your personal data from our records.  We will not be able to delete your personal information whilst we are still providing our services to you.  This right is not absolute and requests for erasure may be refused in some circumstances such where the personal data must be retained to comply with a legal obligation, to exercise/defend legal claims or to prevent financial crime;
  • The right to restrict how we use your personal information;
  • The right to object to the collection and use of your personal information at any time;
  • The right to obtain a copy of your personal data in a legible and compatible format such as Excel or Word.

More information about your rights can be found on the Information Commissioners website. https://ico.org.uk/

You should notify us of any changes to your status, contact and payment details without delay in order that the data we hold for you is kept up to date at all times.

If you wish to raise a complaint on how we have handled your personal data, you can contact our Data Protection Officer who will investigate the matter.

Please let us know by sending an email to privacy@focus.finance.  We will review and investigate your complaint, and try to get back to you within a reasonable time frame.

If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the Information Commissioner’s Office (ICO).

The ICO are the regulator who makes sure that we use your personal information in a lawful way.  You can do this at

www.ico.org/make-a-complaint/

or by calling 0303 123 1113.

Email: privacy@focus.finance

Post: Focus Finance Limited, 1 London Road Office Park, Salisbury. SP1 3HP

Phone: 01722 448050

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