DIRECT CLIENTS

For the purposes of this Privacy Notice, Sirius Private Finance Limited (‘SIRIUS’) is a data controller as defined in the General Data Protection Regulation (GDPR). This is because Sirius 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.

DIRECT CLIENTS

We use your information to provide you or your intermediary with a quote, to process your application and for marketing purposes. We will treat all your information as private and confidential except where we are permitted to disclose your information by law, or where the disclosure is made at your request, or is made with your consent in relation to arranging your loan or mortgage. Where necessary to process your application, your data will be shared with third parties such as the lender, your intermediary, your mortgage provider, joint applicants and credit reference agencies.

Further information regarding how we and the lender will use your information will be provided by your intermediary with any loan documentation that may be sent to you.

The Data Protection Officer for Sirius is William Lloyd, Operations Director. We are registered with the Information Commissioner (ZA449123).

If you have any questions regarding this Privacy Policy, please email us at customerservice@siriusfinance.co.uk.

THE INFORMATION WE COLLECT

Personal Information

We only collect personal data relevant to making a loan application.  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:

 

• Your title, full name, your contact details – including your email address, home and mobile telephone numbers;

• Your home address and address history, together with information about your occupier status;

• Your date of birth;

• Your occupation, job title and employment details;

• Identification; which could include your passport details or driving licence reference number;

• Financial situation and financial history, including any County Court Judgements or arrears on other credit.

Data collected from third party sources includes

• Land Registry

• Companies House

• Credit Referencing Agencies (Experian, Equifax and Call Credit)

Information from Credit Referencing Agencies will include your financial situation and financial history, including public information from the electoral register.

 

We will need this information to;

• Verify the accuracy of the information you have provided us with and

• Prevent criminal activity, fraud and money laundering

 

For more information on credit referencing checks, please refer to the Terms of Business or Initial Disclosure Document provided 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.siriusfinance.co.uk and www.easysource.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 Sirius.

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 mortgage or credit application.  Our grounds for processing your personal information are as follows:

 

Consent – Where necessary we will only collect and process your personal information if you have given your consent for us to do so.

 

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:

• To communicate with you about your loan application.  If you are a direct client of Sirius, we will need to keep you informed about your application throughout via various communication means, including email.  This won’t include marketing communications unless you have given us your consent to receive these.

• For the Management of our own accounting and other business operations;

• To monitor emails, calls and other communications for the processing of your application;

• To respond to case enquires or grievances / complaints

• To notify you about changes to our terms or privacy policy

• Records of any Trustpilot 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 Sirius in relation to our services and products. We will never sell or pass your details onto third parties.

 

 

Where we store your personal data

We currently only store data within the European Economic Area (“EEA”). We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

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

Unless a longer retention period is required or permitted by law, we will only hold your personal information on our systems for the period necessary to fulfil the purposes outlined in this Privacy Policy or until you request it is deleted.

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 customerservice@siriusfinance.co.uk

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;

The Use of Your Data with Regards to Trustpilot

We have teamed up with the independent review company Trustpilot to collect independent customer reviews. Through Trustpilot, we will contact you with your permission, via your email address provided, to ask you to please share with us your experience of Sirius Private Finance. The only information that Trustpilot get is your name and email address to enable them to contact you on our behalf.

We provide Trustpilot with these details under the following conditions:

• Trustpilot will only use the customer details to send one review request and one reminder.

• Any customer details will not be used for any other purpose and cannot be given to any 3rd party organisations or businesses.

Your rights

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;

If you have any questions or would like to exercise your right under this Privacy Policy, please contact William Lloyd via the following methods;

Email – customerservice@siriusfinance.co.uk

Phone – 01277 500900

Address – C/O Brightstar Financial, Unit 7, Woodbrook Crescent, Billericay, CM12 0EQ

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.

Complaints

If you wish to raise a complaint on how we have handled your personal data, you can contact us to have the matter investigated.

Email – customerservice@siriusfinance.co.uk

Phone – 01277 500900

Address – C/O Brightstar Financial, Unit 7, Woodbrook Crescent, Billericay, CM12 0EQ

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 http://ico.org.uk/