PRIVACY NOTICE
Celtic Finance Ltd customer privacy notice
This privacy notice tells you what to expect us to do with your personal information.
Contact details
Post
Celtic Finance Ltd, Unit 15, Neptune Court, Vanguard Way, CARDIFF, , CF24 5PJ, GB
Telephone
07537 141 209
nathan@celticfinance.co.uk
What information we collect, use, and why
We collect or use the following information to provide services and goods, including delivery:
· Names and contact details
· Addresses
· Date of birth
· Purchase or account history
· Payment details (including card or bank information for transfers and direct debits)
· Credit reference information
· Health information (including dietary requirements, allergies and health conditions)
· Account information
· Call recordings
· Records of meetings and decisions
· Identification documents
· Information relating to compliments or complaints
· Information relating to sponsorship
We collect or use the following information to prevent, detect, investigate or prosecute crimes:
· Names and contact information
· Customer or client accounts and records
· Call recordings
· Financial transaction information
We collect or use the following information for service updates or marketing purposes:
· Names and contact details
· Addresses
· Marketing preferences
· Location data
· Call recordings
· Purchase or viewing history
· Website and app user journey information
· Records of consent, where appropriate
We collect or use the following information for research or archiving purposes:
· Names and contact details
· Addresses
· Location data
· Purchase or viewing history
· Website and app user journey information
· Personal information used for administration of research
· Personal information used for the purpose of research
· Records of consent, where appropriate
We collect or use the following information to comply with legal requirements:
· Name
· Contact information
· Identification documents
· Financial transaction information
· Any other personal information required to comply with legal obligations
· Safeguarding information
We collect or use the following personal information for dealing with queries, complaints or claims:
· Names and contact details
· Address
· Payment details
· Account information
· Purchase or service history
· Call recordings
· Relevant information from previous investigations
· Customer or client accounts and records
· Financial transaction information
· Correspondence
Lawful bases and data protection rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
· Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.
· Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.
· Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure.
· Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.
· Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing.
· Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.
· Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.
If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
Our lawful bases for the collection and use of your data
Our lawful bases for collecting or using personal information to provide services and goods are:
· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
· Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
o We use your personal information to research what mortgage products are available to you upon first contact, and which lender and product are the best suited for your needs and circumstances. Without recording all of the relevant information, our advice would be limited and therefore unsuitable, meaning we cannot assist.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Our lawful bases for collecting or using personal information to prevent, detect, investigate or prosecute crimes are:
· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
· Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
· Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.
· Public task – we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.
Our lawful bases for collecting or using personal information for service updates or marketing purposes are:
· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Our lawful bases for collecting or using personal information for research or archiving purposes are:
· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
· Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
· Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.
· Public task – we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.
Our lawful bases for collecting or using personal information for legal requirements are:
· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
· Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
· Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.
Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:
· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
· Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
· Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.
Where we get personal information from
· Directly from you
· Credit reference agencies
· Third parties:
· We sometimes receive client information from introducing mortgage brokers. It is the introducing mortgage broker\'s responsibility to ensure that they have first obtained your permission prior to providing us with any personal information.
How long we keep information
We retain your information in line with the Financial Conduct Authority’s record-keeping requirements. Details of these can be found here.
Who we share information with
Data processors
TMG Direct Ltd
This data processor does the following activities for us: TMG Direct Ltd carry out audits and reviews of client files to ensure that the advice being given is suitable, and all rules and regulations have been followed correctly.
Others we share personal information with
· Organisations we need to share information with for safeguarding reasons
· Professional or legal advisors
· Financial or fraud investigation authorities
· Relevant regulatory authorities
· External auditors or inspectors
· Organisations we’re legally obliged to share personal information with
· Emergency services
How to complain
If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint