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WHO ARE WE?
Mulberry Asset Finance is a Commercial Finance Broker. It acts as an introducer/advisor/broker/intermediary for our customers. Mulberry Asset Finance is Authorised and Regulated by the Financial Conduct Authority.
HOW WILL WE USE YOUR INFORMATION?
Here at Mulberry Asset Finance we take your privacy seriously and will use your personal information in a number of ways which will help us;
- Make lender decisions,
- For fraud prevention
- For audit,
- For statistical analysis,
- Credit reference checks
We may share your information with, and obtain information about you from, credit reference agencies or fraud prevention agencies. Information you provided may be put onto a register of claims and shared with other insurers to prevent fraudulent claims.
We will not disclose your information to any company outside of the reputable funding panel we use (a list of all the funders we use can be provided) except to help prevent fraud or if required by law to do so.
For further information on how your information is used, how we maintain the security of your information and your rights to access/alter and change information we hold on you, please contact Mike Robinson, Mulberry Asset Finance.
YOUR PERSONAL DATA
WHAT WE NEED
Mulberry Asset Finance will be what’s known as the ‘controller’ and the ‘Processer’ of the personal data you provide to us. We collect personal data about you which may also include any special types of information or location-based information.
WE ALSO GATHER
Name and address and date of birth of any other connected parties to your business - e.g. Partners and Directors for search purposes.
Special categories of data may be captured by Mulberry Asset Finance.
WHY WE NEED IT
We need to know your basic personal data in order to provide you with an accurate recommendation for your personal circumstances. We will not collect any personal data from you we do not need in order to provide and oversee this service to you.
WHAT WE DO WITH IT
All the personal data we use is controlled by Mulberry Asset Finance in the UK, however, for the purposes of IT hosting and maintenance, this information is located on servers within the European Union. No 3rd parties have access to your personal data unless the law allows them to do so. We have a Data Protection regime in place to oversee the effective and secure processing of your personal data. More information on this framework can be found on our website.
We may pass your data to panel of funders in order to provide you with offers of products suitable to meet your customer requirements.
Your data is stored on our secure password protected database and electronically on our cloud encrypted server. Our server is based in the UK
HOW LONG WE KEEP IT
We are required under Law to keep your basic personal data, such as name, address, contact details and all other personal data for a minimum of 6 years after which time it will be destroyed. The information used for marketing will be kept with us until you notify us that you no longer wish to receive this information.
WHAT ARE YOUR RIGHTS?
Right of Access
If at any point you believe retained information is incorrect you can request to see this information and even have it corrected and possibly deleted. Providing you this information is free of charge, but charges may apply for excessive requests.
Individuals now have more rights under GDPR, Mulberry Asset Finance, these are;
Right to be Informed
Mulberry Asset Finance provide every customer with a Privacy Notice at the point data is captured.
The information supplied in this notice demonstrates how Mulberry Asset Finance is transparent over our data processing. The notice is;
- concise, transparent, intelligible and easily accessible;
- written in clear and plain language, particularly if addressed to a child; and free of charge.
We include details of (but not limited to);
The Data Controller, the lawful reason for processing data, if any third parties have legitimate interests, categories of personal data, categories of recipients such as banks and credit unions, the data retention periods,
The individuals’ rights; including the right to withdraw, where the individual can complain about how the data is processed with a supervisory authority, source of data when it comes from a third party and where personal data is part of a contractual requirement or obligation.
Right to Rectification
Individuals are entitled to have personal data rectified if it is inaccurate or incomplete. If Mulberry Asset Finance has disclosed the personal data in question to third parties, then we will inform them of the rectification where possible.
Mulberry Asset Finance will respond to this request within one month or extended by two months where the request for rectification is complex.
Right to Erasure
Individuals have a right to have personal data erased and to prevent processing in specific circumstances.
Mulberry Asset Finance may refuse to comply with a request for erasure where the personal data is processed for the following reasons;
If Mulberry Asset Finance has disclosed the personal data in question to third parties, a notification will be sent, informing them about the erasure of the personal data, unless it is impossible or involves disproportionate effort to do so.
Right to Restrict Processing
Mulberry Asset Finance will restrict the processing of personal data in the following circumstances;
- where an individual contest the accuracy of the personal data, you should restrict the processing until you have verified the accuracy of the personal data.
- where an individual has objected to the processing (where it was necessary for the performance of a public interest task or purpose of legitimate interests), and you are considering whether your organisation’s legitimate grounds override those of the individual.
- when processing is unlawful, and the individual opposes erasure and requests restriction instead.
- if you no longer need the personal data but the individual requires the data to establish, exercise or defend a legal claim.
If any data has been disclosed to third parties, Mulberry Asset Finance will notify them about the restriction on the processing of the personal data, unless it is impossible or involves disproportionate effort to do so.
Right to Data Portability
For personal data an individual has provided to a controller; where the processing is based on the individual’s consent or for the performance of a contract; and when processing is carried out by automated means, Mulberry Asset Finance must provide the personal data in a structured, commonly used and machine-readable form. Open formats include CSV files. Machine readable means that the information is structured so that software can extract specific elements of the data. This enables other organisations to use the data. Mulberry Asset Finance must provide this service free of charge. If the individual requests it, we may be required to transmit the data directly to another organisation if this is technically feasible. Mulberry Asset Finance will respond without undue delay, and within one month or extended by two months where the request is complex or receive many requests.
Right to Object
If an individual has objected to processing data or direct marketing, Mulberry Asset Finance will cease to process the data.
As soon as an objection is received, Mulberry Asset Finance will stop processing personal data for direct marketing purposes. This will be actioned at any stage and is free of charge.
As Mulberry Asset Finance offer an online presence, www.mulberryassetfinance.co.uk ; we offer a way for individuals to object online.
Individuals must have an objection on “grounds relating to his or her particular situation”.
Mulberry Asset Finance will stop processing the personal data unless;
- compelling legitimate grounds for the processing, which override the interests, rights and freedoms of the individual; or
- the processing is for the establishment, exercise or defence of legal claims.
This is brought to the attention of the data subject at the first point of communication and in our privacy notice. This is separated out from any other information.
Rights in relation to automated decision making and profiling.
Mulberry Asset Finance understand that any form of automated processing of personal data intended to evaluate certain personal aspects relating to a natural person, or to analyse, or predict that person’s performance at work, economic situation, location, health, personal preferences, reliability, or behaviour falls under this right. Where this is conducted, the rules and guidance of the ICO will be adhered to and followed. To date, Mulberry Asset Finance does not conduct automated decision making including profiling.
LINKS TO OTHER SITES
Links to other websites do not necessarily represent an existence of any form of endorsement, support, relationship or partnership.If you wish to raise a complaint on how we have handled your personal data, you can contact our Data Protection Officer who will investigate the matter.
Where relevant, you have the right to withdraw consent at any time and this means that we cannot process your data provided without your consent.
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 (ICO). Our Data Protection Officer is Michael Robinson and you can contact him directly by e-mail or phone.
We will share your details with the relevant funder(s) on our panel that will pass information to the relevant credit reference agencies, so that they process your information, allowing Mulberry Asset Finance to offer suitable and sustainable products that they provide.