Privacy Policy

Who are we?

We are Focus Commercial Limited and can be contacted on the below contact details:

 

Why do we collect and use your personal information?

We collect and use your personal information in order for us to provide you with our commercial finance broking service. This consists of taking steps to enter into a commercial finance broking agreement with you and/or, once we enter into an agreement with you, to perform our duties under the agreement by facilitating commercial finance to meet your funding requirements.

We use your personal information to send marketing communications to you about similar products and services that may be of interest to you. We will send our marketing communications to you by email. It is to be noted that you can object to your personal information being used by us to send you marketing information. Each marketing email will also include an unsubscribe link to enable you to opt-out of receiving future marketing communications.

 

What personal information do we collect and use?

We collect and use personal information such as:

  • Full names of director(s) of firms who have applied for planning permission;
  • The credit history of the firm;
  • Social media information relating to the director(s) of the firm;
  • Call recordings;
  • Email exchanges;
  • Telephone number;
  • Transaction history relating to our previous customers including;
    • Full names;
    • Social media information;
    • Call recordings;
    • Transaction documents (e.g. credit proposal form, credit agreement )
  • Analytics information such as the pages you view on our website and where you were sourced from (e.g. Google). Please refer to our cookies policy for more information.

 

What is our lawful basis for handling your personal information?

Under the General Data Protection Regulation (GDPR) we must have a lawful basis to legally handle your personal information. The lawful basis that we rely upon are as follows:

  1. Contract – to take steps, at your request, to enter into a contract to source commercial funding solutions for you;
  2. Legal obligation – to share personal information with law enforcement agencies and regulatory bodies if required to do so by law; and
  3. Legitimate interests – to use your personal information to send you marketing communications about similar products/services in the future, to share your personal information with third party professional service providers that we engage and to share your personal information with our successor(s) in the event of a merger or acquisition.

 

Where do we get your personal information from?

We obtain your personal information from third party data brokers who obtain this from publicly accessible registers. Once we obtain your personal information from data brokers, we may use publicly available sources such as social media platforms and Creditsafe to add more information about your profile in order to communicate tailored marketing content to you.

 

What happens if I do not provide my personal information?

We need your personal information in order to provide our commercial finance broking service you. If we do not collect your personal information we will not be able to provide our services to you.

 

Who will we share your personal information with?

We may share your personal information with insurance providers, commercial finance providers, credit reference agencies, valuers and professional service providers such as solicitors in the course of providing our services.

We use third parties to manage our CRM system, host our call recording, store our

electronic documentation and provide a file transfer service. These third parties may have access to the personal information we hold about you for the purposes of providing their services to us. We enter into a written agreement with all such third parties to obtain a contractual guarantee that they will keep your personal information secure.

We may share your personal information with law enforcement agencies, fraud prevention agencies and regulatory bodies such as the FCA and HMRC when required to do so by law.

We may engage the services of professional advisers such as compliance consultants, lawyers and accountants who may be given access to your personal information in order to provide their services to us. We will ensure that your personal information is protected by obtaining a written undertaking of confidentiality from the professional service providers.

 

How long will we store your personal information?

We will store your personal information relating to unsuccessful and successful commercial finance broking for six years. This is to enable us to refer to our records in the unlikely event that you want to lodge a complaint against us within six years.

If you do not exercise your right to object to marketing or unsubscribe to our marketing emails we will store your personal information for marketing purposes until you exercise your right to object or unsubscribe.

 

What are your rights in relation to your personal information?

Right to access
You have the right to request copies of the personal information we hold about you at any time.

Right to rectification
You have the right to request that we correct any inaccurate personal information we hold about you.

Right to erasure
You have the right to request that we delete your personal information from our records.

Please note that we will not be able to delete your personal information whilst we are still providing our services to you. We will be able to delete your personal information once you cancel the service or once the service is completed.

Right to restrict processing
You have the right to request that we restrict how we use your personal information.

Right to object
You have the right to object to the collection and use of your personal information at any time.

Right to data portability
You have the right to obtain a copy of your personal information in a legible and compatible format such as Excel or Word.

 

How can I exercise my rights in relation to my personal information?

You can exercise all of your rights by contacting us on any of the above contact details.

 

How do I lodge a complaint about the use of my personal information?

You can lodge a complaint with us directly by contacting us on one of the above contact details.

You also have the right to lodge a complaint directly with the Information Commissioner’s Office (ICO). The ICO are the regulator who makes sure that we use your personal information in a lawful way.

You can lodge a complaint with the ICO by following this link https://ico.org.uk/concerns/ or calling the ICO on 0303 123 1113.


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