Privacy Notice For Introducing Finance Intermediaries
For the purposes of this Privacy Notice, Montpelier Private Finance Limited is a data controller as defined in the General Data Protection Regulation (GDPR). This is because Montpelier Private Finance Limited may in some cases determine how your personal information will be used. By personal information, we mean information which, either by itself or combined with other information that is available to us, can be used to identify you, your principals, directors, shareholders or anyone employed by you or engaged by you who may access our online systems. For the purpose of this Privacy Notice, where we refer to “you” or “your” this will also include your principals, directors, shareholders, employees, contractors and workers.
We are registered with the Information Commissioner (Z1998710).
You can contact us for general data protection queries by email to email@example.com, or in writing to the Data Protection Officer, Montpelier Private Finance Limited, Old House Farm Barn, Oldhouse Lane, Coolham, RH13 8QP.
The information we collect
We will process your information in support of any applications made through Montpelier Private Finance Limited in line with the Introducer Agreement. Such personal data is given directly by you and by people or companies authorised by you to act on your behalf, and it may also include information obtained from those third parties authorised by you to share such information with us, including:
Identity Information – Forenames, last name, maiden name, date of birth, gender, marital status, and username or similar identifier
Contact Information – Home address, Business address, email address and telephone and fax numbers
Financial Information – Banking details (to enable payment of fees payable to you)
Technical Information – Internet protocol (IP) address, browser type and version, browser plug-in types and versions, operating system and platform and other technology on the devices used to access www.montpelierpf.co.uk.
Profile and Usage Information – Feedback and survey responses, and how you use our website, products and services
Marketing and Communications Information including your preferences in receiving future news and services from Montpelier Private Finance Limited.
When using our website to submit enquiries, you confirm that you have obtained the consent of your client to share their data with Montpelier Private Finance Limited and provided them with a copy of our Privacy Notice.
Why we need your data?
We will only collect and use your personal information in accordance with data protection laws for the purpose of facilitating your registration onto our Intermediary panel and onward processing of any applications you make on behalf of your clients through Montpelier Private Finance Limited. Our grounds for processing your personal information are as follows:
For the purposes of performing our Contract (Introducer Agreement) with you. This includes the administering and management of our relationship in relation to the role that you undertake under the Agreement with Montpelier Private Finance Limited. For more information, please refer to the Introducer Agreement.
For the purposes of our own Legitimate Interests – We may use and process some of your personal information where we have sensible and legitimate business grounds for doing so. Our grounds for processing your personal information are as follows:
For the Management of our own accounting and other business operations;
To monitor emails, calls and other communications in line with our Agreement with you as an Intermediary to Montpelier Private Finance Limited;
To respond to case enquiries or grievances / complaints
Records of any surveys that you may be asked to complete for research purposes (although you do not have to respond to them);
Developing statistics for market research and ongoing analysis to improve our website, product / services, marketing, customer relationships and experiences;
To deal with our good governance requirements
For the purposes of future marketing under Consent – You will be asked for your Consent to receive communications from Montpelier Private Finance Limited in relation to our services and products. We will never sell or pass your details onto third parties.
Where we store your personal data
Once we have received your personal data, we will use (and require our suppliers and partners to use) procedures and security features to try to prevent unauthorised access, unlawful processing, accidental loss or destruction of, or damage to it. However, the transmission of information via the Internet is not completely secure and, while we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our service and any transmission is at your own risk.
How long we keep your data
You will be asked whether you consent to your information being used for marketing purposes. If you consent, the information we use for marketing purposes will be kept with us until you notify us that you no longer wish to receive this information.
If you have any concerns or would like to be removed from future marketing, please contact us on firstname.lastname@example.org
Disclosure of your information
We will keep your personal data confidential and only disclose it to others for the purposes of facilitating your loan application on behalf of your client, as well as in the following specific circumstances:
To investigate, prevent or detect fraud or carry out checks against money laundering;
For audit purposes and to meet obligations to any relevant regulatory authority or taxing authority;
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply any agreements to which you are a party; or to protect our rights, property, or safety, or that of our customers or others (which includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction);
In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; or
If substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
Fraud Prevention Agencies (FPAs)
Before we provide products, services or financing to your client, we undertake checks for the purposes of preventing fraud and money laundering, including verifying your identity. To do this, we may share you and your clients’ personal information with FPAs.
When we and fraud prevention agencies process you or your clients personal data, we do so on the basis that we have a legitimate interest in preventing fraud and money laundering, in order to protect our business and to comply with laws. Such processing is also a contractual requirement of the services and financing you have requested. When appropriate, we and fraud prevention agencies, may also enable law enforcement agencies to access and use your clients’ personal data to detect, investigate and prevent crime.
Fraud prevention agencies can hold you or your clients’ personal data for different periods of time and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years. A record of any fraud or money laundering risk will be retained by the fraud prevention agencies and may result in others refusing to provide services, financing or employment to your client. If you have any questions about this, please contact us on the details above.
Montpelier Private Finance Limited uses TransUnion to undertake fraud prevention checks. Information relating to their privacy policies can be found at https://www.transunion.co.uk/legal-information/bureau-privacy-notice. Further information about TransUnion’s activities can be found at this location.
You have the right to request a copy of the personal information that we hold about you, its origin and any recipients of it as well as the purpose of any data processing carried out.
Right to access: the right to request copies of your personal information from us;
Right to correct: the right to have your personal information rectified if it is inaccurate or incomplete;
Right to erase: the right to request that we delete or remove your personal information from our systems;
Right to restrict our use of your information: the right to ‘block’ us from using your personal information or limit the way in which we can use it;
Right to object: the right to object to our use of your personal information
Right to data portability: the right to request that we move, copy or transfer your personal information;
By phone on 01403 741099, via email to email@example.com, or write to us directly to our address; Montpelier Private Finance Limited, Old House Farm Barn, Oldhouse Lane, Coolham, RH13 8QP
We will aim to respond to all requests within 30 days except in instances where the request may be complex. We shall let you know within the 30-day period if we will need more time but no longer than 90 days.
Please let us know if you are unhappy with how we have used you or your clients' personal information. You can contact us by phone on 01403 741099, via email to firstname.lastname@example.org, or write to us directly to our address; Montpelier Private Finance Limited, Old House Farm Barn, Oldhouse Lane, Coolham, RH13 8QP.
You also have the right to complain to the Information Commissioner’s Office. Find out on their website how to report a concern.
We keep our privacy notice under regular review. This privacy notice was last updated on 20th May 2020.