We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint about how we have dealt with your data.
When we use your personal data we are regulated by the Information Commissioners Office (ICO) under the Data Protection Act 2018 (DPA 2018). UK GDPR now applies across the United Kingdom and we are responsible as ‘controller’ of that personal data for the purposes of the UK GDPR. Our use of your personal data is subject to your instructions, the GDPR, other relevant UK U legislation and our professional duty of confidentiality.
Key Terms
We, us, our
Personal data
Special category personal data
Equaliti Limited T/A Carki
Any information relating to an identified or identifiable individual
Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership. Genetic and biometric data. Data concerning health, sex life or sexual orientation
Personal data we collect about you
The information below sets out the personal data we will or may collect in the course of advising and/or acting for you.
Personal data we will collect
Your name, address and telephone number
Information to enable us to check and verify your identity, for example your date of birth or passport details
Electronic contact details, for example your email address and mobile phone number
Information relating to the finance product in which you are seeking a quotation or finance for.
Information to enable us to undertake a credit or other financial checks on you
Your financial details so far as relevant to your instructions.Information about your use of our IT, communication and other systems, and other monitoring information, for example if using our or other third party secure online Customer portals
Personal data we may collect depending on why you have come to us as a Customer.
Your National Insurance and tax details
Your bank and/or building society details
Details of your online presence, for example your Facebook or LinkedIn profile
Details of your spouse/partner and dependants or other family members, for example if you instruct us on a family matter or a will
Your employment status and details including salary and benefits, if you instruct us on matter where these details are relevant
Personal identifying information, such as your eye colour or your parents’ names, for example if you instruct us to incorporate a company for you
This personal data is required to enable us to provide our service to you. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you.
How your personal data is collected
We collect most of this information from you, direct or via our secure online client portal. However,we may also collect information:
· from publicly accessible sources, for example Companies House or HM Land Registry;
· directly from a third party, including:
· your bank or building society, other financial institutions or advisors;
· your employer and/or trade union, professional body;
· consultants and other professionals we may engage in relation to your credit application;
· sanctions screening providers;
· credit reference agencies;
· Customer due diligence providers;
· via our website based upon our use of cookies (for more information on cookies, please see our cookies policy)
· via our information technology (IT) systems, including:
· case management, document management;
· automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems;
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason:
· to comply with our legal and regulatory obligations;
· for the performance of our contract with you or to take steps at your request before entering into a contract;
· for our legitimate interests or those of a third party; or
· where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so longas this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal data for and our reasons for doing so:
To provide Financial services to you.
Ensuring business policies are adhered to, for example policies covering security and internet use
Operational reasons, such as improving efficiency, training and quality control
Ensuring the confidentiality of commercially sensitive information
Statistical analysis to help us manage our practice and to assess our financial performance, client base, work type or other efficiency measures
Preventing unauthorised access and modifications to systems
Updating and enhancing Customer records
Statutory returns
Ensuring safe working practices, staff administration and assessments
Marketing our services and those of selected third parties to:
· existing and former Customers;
· third parties who have previously expressed an interest in our services;
· third parties with whom we have had no previous dealings
Credit reference checks via external credit reference agencies
External audits and quality checks, for example ISO, our providers of finance / Customer lenders or Investors in People accreditation and the audit of our accounts
For the performance of our contract with you or to take steps at your request before entering into a contract
For our legitimate interests or those of a third party, to ensure we are following our own internal procedures so we can deliver the best service to you
For our legitimate interests or those of a third party, to be as efficient as possible so we can deliver the best service for you at the best price
For our legitimate interests or those of a third party,to protect our intellectual property and other commercially valuable information
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, to be as efficient as we can so we can deliver the best service for you at the best price
For our legitimate interests or those of a third party,for example to prevent and detect criminal activity that could be damaging for us and for you
To comply with our legal and regulatory obligations
For the performance of our contract with you or to take steps at your request before and after entering into a contract.
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, for example making sure that we can keep in touch with our Customers
To comply with our legal and regulatory obligations
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
For our legitimate interests or those of a third party, for example to promote our business to existing and former Customers
For our legitimate interests or a those of a third party, including for credit control and to ensure our Customers are likely to be able to meet financial obligations of lenders / providers of finance
For our legitimate interests or a those of a third party, to maintain our accreditations so we can demonstrate we operate at the highest standards
To comply with our legal, financial and regulatory obligations
Where and when we need your consent - There will be circumstances where we will only process your data if we have your consent to do so. For example, if you provide us with data that is classed as a special category of data such as health information, criminal records of convictions and offences, or allegations of criminal offences. We will only process this with your permission (unless we feel the processing is necessary to protect your vital interests or if the law allows us to do so). You have a right at any time to ask us to stop the processing of that specific data.
Promotional communications
We may use your personal data to send you updates (by email, text message, telephone or post) about product developments that might be of interest to you and/or information about our services, including exclusive offers, promotions or new services or products.
We have a legitimateinterest in processing your personal data for promotional purposes (see above‘How and why we use your personal data’). This means we do not usually needyour consent to send you promotional communications. However, where consent isneeded, we will ask for this consent separately and clearly.
We will always treatyour personal data with the utmost respect and never share it with otherorganisations for marketing purposes.
You have the right toopt out of receiving promotional communications at any time by:
· contactingus by sending an email to hello@carki.co.uk
· using the‘unsubscribe’ link in emails or ‘STOP’ number in texts
We may ask you toconfirm or update your marketing preferences if you instruct us to providefurther services in the future, or if there are changes in the law, regulation,or the structure of our business.
Who we shareyour personal data with
We routinely share personal data with:
· professional advisers who we instruct on your behalf or refer you to, for example financial advisers, other Sensible Group Holdings companies, accountants, tax advisors or other experts;
· other third parties where necessary to carry out your instructions, for example your loanprovider, or Companies House;
· credit reference agencies;
· insurers,brokers and lender legal providers;
· external auditors or accountants, for example in relation to accreditation and the auditof our accounts;
· our bank;
· external service suppliers, representatives and agents that we use to make our business more efficient, for example typing services, marketing agencies, document collation or analysis suppliers;
We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers relating to our instruction to them to ensure they can only use your personal data to provide services to us and to you.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal data with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually information will be anonymised, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
Where your personal data is held
Information may be held at our offices, third party agencies, service providers, representatives and agents as described above (see ‘Who we share your personal data with’)
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal data when this occurs, see below:‘Transferring your personal data out of the EEA’.
How long your personal data will be kept
We will keep your personal data after we have finished advising or acting for you. We will do so for one of these reasons:
· to respond to any questions, complaints or claims made by you or on your behalf;
· to show that we treated you fairly;
· to keep records required by law
We will not retain your data for longer than necessary for the purposes set out in this policy.Different retention periods apply for different types of data.
When it is no longer necessary to retain your personal data, we will delete or anonymise it.
Transferring your personal data out of the EEA
To deliver services to you, it is sometimes necessary for us to share your personal data outside the European Economic Area (EEA), for example:
· with your and our service providers located outside the EEA;
· if you are based outside the EEA;
· where there is an international dimension to the matter in which we are advising you.
These transfers are subject to special rules under European and UK data protection law.
These non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal data will be secure. Our standard practice is to use standard data protection contract clauses which have been approved by the European Commission.
Your rights
You have the following rights, which you can exercise free of charge:
Access
Rectification
To be forgotten
Restriction of processing
Data portability
To object
Not to be subject to automated individual decision-making
The right to be provided with a copy of your personal data
The right to require us to correct any mistakes in your personal data
The right to require us to delete your personal data (in certain situations)
The right to require us to restrict processing of your personal data in certain circumstances, for example if you contest the accuracy of the data
The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party (in certain situations)
The right to object:
· at any time to your personal data being processed for direct marketing (including profiling);
· in certain other situations to our continued processing of your personal data, for example processing carried out for the purpose of our legitimate interests.
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
For further information on each of those rights, including the circumstances in which they apply,please contact us or see the Guide to the General Data Protection Regulations (GDPR) from the Information Commissioner’s Office (ICO).
If you would like to exercise any of those rights, please:
· complete a data subject request form; or
· email, call or write to us; and
· let us have enough information to identify you (including your full name, address and client or matter reference number);
· let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
· let us know what right you want to exercise and the information to which your request relates.
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
How to complain
We hope that we can resolve any query or concern you may raise about our use of your information.
The GDPR also gives you right to lodge a complaint with a supervisory authority in the European Union(or EEA) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/make-a-complaint/ or telephone: 0303 123 1113.
Changes to this privacy policy
This privacy policy was updated on 20th February 2023
