Privacy Notice & Policy
Midshires Rural Finance (“We”) are committed to protecting and respecting your privacy. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting our websites you are accepting and consenting to the practices described in this policy.
For the purpose of the European Data Protection Regulations (‘GDPR’) and the Data Protection Act 2018 (the Act) and, the data controller is Midshires Rural Finance, Middle Farm, Field Aston, Newport, Shropshire, TF10 9LE. Our nominated representative for the purpose of the Act is Heather Wagstaff.
This Privacy Statement explains how we process your information and your rights under both DPA and GDPR.
Information we may collect from you
We may collect and process the following data about you:
Information you give us- You may give us information about you by filling in forms on our site https://www.midshiresruralfinance.co.uk (our site) or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our site, subscribe to our service, search for a product, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number.
We will use this information:
- to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep our site safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
- Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive).
- We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
- We are also working closely with third parties (including for example credit reference agencies) and may receive information about you from them.
We make sure that we have appropriate security measures to protect your information. We will periodically review your personal information to ensure that we do not keep it for longer than is permitted. Note that it is your responsibility to check and ensure that all information, content, material or data you provide on the Sites is correct, complete, accurate and not misleading and that you disclose all relevant facts.
In order to provide you with a quote our lenders may need to collect personal information which data protection legislation defines as sensitive personal information, such as medical history or criminal convictions. We will request your consent to process this information at the time you give it and by proceeding with obtaining a quote you give your explicit consent to such sensitive personal information being processed by us and our providers for the purposes stated in this Privacy Policy.
We do not knowingly collect or store any personal information about children under the age of 16. If you are aged under 16 please get your parent or guardian’s permission before you provide any personal information to us.
If you are providing us with another person’s information you should first ask them to read this Privacy Policy and our Terms of Use. By giving us information about another person you are confirming that they have given you consent to provide the information to us and that they understand how their details will be used.
In order to ensure the Services we provide you continue to meet your needs we may ask you for feedback on your experience of using the Site. Any feedback you provide will only be used as part of our programme of continuous improvement and will not be published on the Site.
Uses made of the information
We use information held about you in the following ways:
- sending you renewal information based on information you previously provided to us (if you have requested quotes) – when our systems indicate that your renewal is due (based on the dates you entered for your most recent quote).
- sending you a confirmation email of your quote – when you obtain a quote with us, you will be sent confirmation of your quote by email so that you have a record of it and can easily retrieve your quote in the future. This is a standard part of our Services and by using the Services you agree to receive these communications;
- to process a transaction between you and a third party;
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
- to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
- If you agree, we will contact you (depending on your contact preferences) via email, post, telephone, sms, or by other electronic means such as via social and digital media this may include new product launches, newsletters and opportunities to participate in market research;
- to notify you about changes to our service;
- to ensure that content from our site is presented in the most effective manner for you and for your computer.
Disclosure of your information
We will only collect and use your personal information in accordance with data protection laws. 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 example, we will only send you certain marketing emails and process any sensitive information about you if we have your consent.
- Legitimate Interests – We may use and process some of your personal information where we have sensible and legitimate business grounds for doing so. Under European privacy laws there is a concept of “legitimate interests” as a justification for processing your personal information. Our legitimate interests for processing your personal information are:
- To communicate with you about the Services. We need to keep you informed about your use of the Services for example sending you a confirmation email of your quotes. This won’t include marketing communications unless you have given us your consent to receive these; and
- To improve our Services. We may use your personal information to: personalise aspects of our service; for market research. We constantly aim to improve our Services to you and using your personal information in this way helps us to do this.
- Analytics and search engine providers that assist us in the improvement and optimisation of our site.
- Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
- We may disclose your personal information to third parties:
- 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.
- If Midshires Rural Fincance or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
From May 2018, you will have a right to object to our use of your personal information for these legitimate interests including where we may use your personal information to create a profile to inform customer demographics. If you raise an objection we will stop processing your personal information unless very exceptional circumstances apply, in which case we will let you know why we are continuing to process your personal information. Please contact Heather on info@midshiresruralfinance.co.uk if you wish to exercise this right.
We may share your information with selected third parties including :
- Business partners, suppliers and sub-contractors for the performance of any contract we enter into with [them or] you, including without limitation any data processor we engage.
- Analytics and search engine providers that assist us in the improvement and optimisation of our site.
We may disclose your personal information to third parties :
- 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.
- 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 our Terms of Use or terms and conditions of supply and other agreements; or to protect the rights, property, or safety of Midshires Rural Finance, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Where we store your personal data
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
All information you provide to us is stored on our secure servers.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site: any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try and prevent unauthorised access.
Your rights
You have the right to ask us not to process your personal data for marketing purposes. We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at info@midshiresruralfinance.co.uk .
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Your rights under Data Protection Law
We operate under the Data Protection Act 2018 (‘DPA’) and the European General Data Protection Regulation (‘GDPR’).
The DPA and GDPR apply to ‘personal data’ we process and the data protection principles set out the main responsibilities we are responsible for.
We must ensure that personal data shall be:
- Processed lawfully, fairly and in a transparent manner
- Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes
- Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed
- Accurate and where necessary kept up to date
- Kept for no longer than is necessary for the purposes for which the personal data are processed. We operate a data retention policy that ensures we meet this obligation. We only retain personal data for the purposes for which it was collected and for a reasonable period thereafter where there is a legitimate business need or legal obligation to do so. For detail of our current retention policy contact our privacy officer at info@midshiresruralfinance.co.uk
- Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures
We ensure lawful processing of personal data by obtaining consent; or where there is a contractual obligation to do so in providing appropriate products and services; or where processing the data is necessary for the purposes of our legitimate interests in providing appropriate products and services.
In the majority of cases we process personal data based on your contract with us. In other cases, we process personal data only where there are legitimate grounds for so doing.
To meet our Data Protection obligations, we have established comprehensive and proportionate governance measures.
We ensure data protection compliance across the organisation through:
- Implementing appropriate technical and organisational measures including internal data protection policies, staff training, internal audits of processing activities, and reviews of internal HR policies
- Maintaining relevant documentation on processing activities
- Implementing measures that meet the principles of data protection by design and data protection by default including data minimisation, pseudonymisation, transparency, deploying the most up-to-date data security protocols and using data protection impact assessments across our organisation and in any third party arrangements
Under the GDPR You have the following specific rights in respect of the personal data we process:
- The right to be informed about how we use personal data – This Privacy Statement explains who we are; the purposes for which we process personal data and our legitimate interests in so doing; the categories of data we process; third party disclosures; and details of any transfers of personal data outside the UK
- The right of access to the personal data we hold. In most cases this will be free of charge and must be provided within one month of receipt
- The right to rectification where data are inaccurate or incomplete. In such cases we shall make any amendments or additions within one month of your request
- The right to erasure of personal data, but only in very specific circumstances, typically where the personal data are no longer necessary in relation to the purpose for which it was originally collected or processed; or, in certain cases where we have relied on consent to process the data, when that consent is withdrawn and there is no other legitimate reason for continuing to process that data; or when the individual objects to the processing and there is no overriding legitimate interest for continuing the processing.
- The right to restrict processing, for example while we are reviewing the accuracy or completeness of data, or deciding on whether any request for erasure is valid. In such cases we shall continue to store the data, but not further process it until such time as we have resolved the issue
- The right to data portability which, subject to a number of qualifying conditions, allows individuals to obtain and reuse their personal data for their own purposes across different services
- The right to object in cases where processing is based on legitimate interests, where our requirement to process the data is overridden by the rights of the individual concerned; or for the purposes of direct marketing (including profiling); or for processing for purposes of scientific / historical research and statistics, unless this is for necessary for the performance of a public interest task
- Rights in relation to automated decision making and profiling
Please contact our privacy officer at info@midshiresruralfinance.co.uk for more information about the GDPR and your rights under Data Protection law.
If you have a complaint about data protection at Midshires Rural Finance, please contact our privacy officer at info@midshiresruralfinance.co.uk
Alternatively contact our supervisory authority for data protection compliance: www.ico.org.uk :
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Tel: 0303 123 1113 (local rate) or 01625 545 745 (national rate)
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Changes to our privacy policy
Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.
Contact
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to info@midshiresruralfinance.co.uk
Policy Last updated: 25 th May 2018