This is privacy notice of Prudell Ltd
We respect your privacy and are determined to protect your personal data. The purpose of this privacy notice is to inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from). We’ll also tell you about your privacy rights and how the data protection law protects you.
1. WHO WE ARE AND IMPORTANT INFORMATION
What is the purpose of this privacy notice?
This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you complete an enquiry form.
This website is not intended for children and we do not knowingly collect data relating to children.
You must read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Data controller
The data controller of your personal information is Prudell Ltd, a limited liability company registered at Verulam Point, Station Way, ST Albans, Hertfordshire, AL1 5HE with company number 2012093.
For all data matters contact our Data Protection Representative, David Keenan:
By Telephone on: 0207 328 3280
By Email: david@prudell.co.uk
Third-party links outside of our control
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.
When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. THE PERSONAL DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Details about who you are e.g. your name, date of birth and contact details
- Details connected to your product or service with us e.g. your mortgage account details
- Details of your contact with us e.g. meetings, phone calls, emails / letters
- Information that is automatically collected e.g. via cookies when you visit our website
- Information classified as ‘special category’ personal information e.g. relating to your health, marital or civil partnership status. This information will only be collected and used where it’s needed to provide the product or service you have requested or to comply with our legal obligations
- Information you may provide us about other people e.g. joint applicants or beneficiaries for products you have with us
If you fail to provide personal data
Where we need to collect your personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. HOW WE COLLECT YOUR PERSONAL DATA
We use different methods to collect data from and about you including:
- Directly. You may give us your personal information by filling in forms or by corresponding with us by post, phone, Secure Portal, email or otherwise. This includes personal data you provide when you:
- Complete an enquiry form on our website
- Make an application for a Mortgage or Non Investment Insurance Product
- Request marketing to be sent to you
- Estate agents with whom you may be interacting, but only with your consent;
- New home builders, as a legitimate interest of the builder in order to assess affordability for the property;
- Enquiries you may perform on third-party mortgage sourcing websites.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Performance of a Contract this means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- Comply with a legal or regulatory obligation this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to (e.g. anti-money laundering and pursuant to our obligations to our regulator)
- Legitimate Interest this means the interest of our business in conducting and managing our business ( e.g. keeping our records up to date)
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
The personal information that we hold will be disclosed to third parties for the purpose of providing services to you, these include:
- Mortgage Lenders, insurance companies, for the purpose of processing your applications
- credit reference agencies and other companies
- Our regulator, the Financial Conduct Authority, who has a legal authority to check all our records
- our compliance consultants who help us to ensure that we abide by our regulations
- other professional advisers such as accountants and solicitors who may have referred you to our company or to whom we may wish to refer you for specialist advice when we consider
Use of Cookies
Some of our web pages utilise "cookies" and other tracking technologies. A "cookie" is a small text file that may be used, for example, to collect information about web site activity. Some cookies and other technologies may serve to recall Personal Information previously indicated by a web user. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them.
You may set most browsers to notify you if you receive a cookie or you may choose to block cookies with your browser, but please note that if you choose to erase or block your cookies, you will need to re-enter your original user ID and password to gain access to certain parts of the web site. Tracking technologies may record information such as Internet domain and host names; Internet protocol (IP) addresses; browser software and operating system types; clickstream patterns; and dates and times that our site is accessed. Our use of cookies and other tracking technologies allows us to improve our web site and your web experience. We may also analyse information that does not contain Personal Information for trends and statistics.
5. WHO WE SHARE YOUR PERSONAL DATA WITH
We may have to share your personal data with the parties set out below for the purposes set out in paragraph 4 above.
- Mortgage Lenders, insurance companies, for the purpose of processing your applications
- our regulator, the Financial Conduct Authority, who has a legal authority to check all our records
- our compliance consultants who help us to ensure that we abide by our regulations
- other professional advisers such as accountants and solicitors who may have referred you to our company or to whom we may wish to refer you for specialist advice when we consider that it would be in your best interest to do so
- credit reference agencies and other companies
Where third parties are involved in processing your data we will have a contract in place with them to ensure the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your data and that they will only act in accordance with our instructions.
If it is necessary for your personal data to be sent to a third party we will use appropriate and secure methods to do so.
If you do not wish us to collect and use your personal information in these ways, it may mean we will be unable to provide our services to you.
6. INTERNATIONAL TRANSFERS
The majority of your information is processed in the UK and European Economic Area (EEA). However, your personal information may be transferred to, and processed in, countries other than the country in which you are resident. Some of our external suppliers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
We may also use specific contracts approved by the European Commission that provide the same level of protection for personal data as it has in the EEA.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal or regulatory reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. We are subject to regulatory requirements to retain data for a specified minimum period. We also reserve the right to retain data indefinitely in case we need to refer to this information, even after you are no longer a client.
9. YOUR DATA PROTECTION RIGHTS
You have the following data protection rights:
You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below.
You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “How to contact us” heading below.
Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. For specific information about our processing of your special category personal data with your consent, please refer to our data protection statement.
You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries (including the US and Canada) are available at http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.
If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the “How to contact us” heading below.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
10. CHANGES TO THIS NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
We may change or update this Notice in order to maintain our compliance with applicable law and regulation or following an update to our internal practices. When we update our Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make.
11. HOW TO CONTACT US
To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact our Data Representative on 0207 328 3280 or by emailing enquiries@prudell.co.uk
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England, UK.