Who we are
We are Fullbrook Thorpe Investments LLP and we can be contacted using the following details:
The Boardwalk, Mercia Marina, Findern Lane, Willington, Derby DE65 6DW
Telephone: 01283 249761
FCA number: N/A
ICO registration number: ZA202339
Our Data Protection contact is: Lucy Thomas
Our legal grounds for handling your personal data
The UK’s data protection laws allow us to use your personal data provided we have a lawful basis to do so. This includes sharing it in certain circumstances, as described below.
We consider we have the following reasons (legal bases) to use your personal data:
- Performance of contract with you: we need to use your personal data to be able to successfully legally contract with you.
- Compliance with our legal obligations: we need to use your personal data so as to comply with certain legislation such as financial crime legislation.
- Legitimate interests: these are our business and commercial reasons for using your data, which we have balanced against your interests. We have certain legitimate interests in using your data which are not outweighed by your interests, fundamental rights or freedoms. These legitimate interests are to help prevent and detect financial crime, fraud and money laundering, to promote responsible lending, and to assist our compliance with the legal and regulatory requirements placed upon us.
- Your consent: we may also use your data when you consent to it. You can withdraw this consent at any time, in which case we will cease to use it, unless we have a right and a need to continue processing it for one of the other reasons set out above.
More information on how we use your personal data and for what purposes is set out below.
What personal data is collected about you and how we collect it
We may collect data about you from the following sources:
Data provided by you:
- When you apply for products and services and throughout the course of our dealings: for example, your name, national insurance number, postal address, your email address, your IP address, telephone numbers, date of birth, bank account details, home ownership details, reason for borrowing, your assets and liabilities, details of your proof of identity documentation and proof of address documentation etc.
- When you talk to us: for example, on the phone, or in person including call recordings and voice messages. We may monitor or record calls with you to check we have carried out your instructions, to resolve queries or disputes, to improve the quality of our service or for regulatory or fraud prevention purposes
- In writing: for example, letters, emails, texts and other electronic communications etc.
- Online: for example, when you use our website.
- In financial reviews, for renewals and in any surveys etc
Data we collect when you use our services:
- Usage and profile data: for example, the profile you create to use our website and how you use it. We gather this data from the devices you use, using cookies, Google analytics and other software.
Data provided by third parties:
- Data from persons that introduce you to us: for example, brokers, financial advisers, agents or other third parties.
- Data from credit reference agencies, most likely either to be Equifax or Experian
- Data from fraud prevention agencies
- Data from the Criminal Records Bureau
- Publicly available information: for example, from the land registry, companies house, insolvency service, the electoral register, other information available online or in the media, including social media
- Data from your representatives where relevant: for example, your legal and financial advisers such as lawyers and accountants*
- Data from your employers and medical data where relevant*
- Sanction checks and PEP (politically exposed person) checks from our outsourced providers, Equifax, Veriphy.
*In certain circumstances we may ask you to provide us with medical information if we determine that this is a requirement for us to either proceed to enter into the agreement with you or once we have entered into the agreement with you determine that the same is necessary for whatever reason. Full details as to the reason for our request and how we will use this information will be given to you at the time should we request such information from you. You will be asked to consent to the provision of this information.
*We may also require a statement signed by an independent qualified accountant as to your financial worth which may include information such as your gross and net worth, your assets and liabilities and information as to your available collateral or security. You will be asked to consent to the provision of this information.
Why personal data is collected by us
We collect personal data from you for many reasons including:
|Activity||Legal basis||Legitimate interest|
| exercising our contractual rights and obligations|| contract performance|
| pre contractual checks|
post contractual checks
| contract performance|
| verifying identity|
maintaining up to date records
seeking consent where relevant
| product analysis and development|
| legitimate interests|| business efficacy|
| profiling, statistical and analytics|| contract performance|| product development|
| regulatory and legal requirements|
business management and operations, including record keeping
| legitimate interests|
| business compliance|
| business development|
From time to time we may contact you to ask for your consent to use your personal data for other purposes. Your personal data may also be used for other purposes where required or permitted by law.
When we and fraud prevention agencies process your personal data, we do so on the basis that we have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the services or financing you have requested. We, and fraud prevention agencies, may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime. Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.
In order to process your application, we may supply your personal information to credit reference agencies (CRAs) in which case they will give us information about you, such as about your financial history. We do this to assess creditworthiness and product suitability, check your identity, manage your account, trace debts and prevent criminal activity. When CRAs receive a search from us they may place a search footprint on your credit file that may be seen by other lenders and used to assess applications for finance from you and members of your household. The CRA may also share your personal information with other organisations. We may also continue to exchange information about you with CRAs on an on-going basis, including about your settled accounts and any debts not fully repaid on time. CRAs will share your information with other organisations. Your data will also be linked to the data of your spouse, any joint applicants or other financial associates. We can provide you with the identities of the CRAs and the ways in which they use and share personal information upon your request. More information about CRAs and how they use your personal data is available at www.experian.co.uk/crain, www.equifax.co.uk/crain and www.callcredit.co.uk/crain.
From time to time we may provide your information to our partners, third parties, and customer service agencies for research and analysis purposes so that we can monitor and improve the services (or as the case may be) we provide. We may contact you by post, e-mail or telephone (or as required) to ask you for your feedback and comments on our services (or as the case may be).
From time to time we may contact you about goods or services that may be of interest to you.
When personal data is shared
Your personal data may be used by our partners, product providers, brokers, agents, sub-contractors, insurers, lawyers and by any of our or their subsidiary or associated companies before, during and after your agreement with us.
We may also use organisations to perform tasks on our behalf including information technology service providers and payment service providers, who we will then be sharing your personal data with and who may also process and retain your data both before, during and after your agreement with us.
Any of these third parties may contact you by post, e-mail or telephone (or as required) to ask you for your feedback and comments on our or their services (or as the case may be) to give you information about their products and services and/or for marketing purposes. They may also use your personal data to communicate with you on any matter relating to the management and conduct of your account or agreement with us.
We may also share your personal data with CRAs, fraud prevention agencies, law enforcement agencies, regulators and other authorities, the UK Financial Services Compensation Scheme, any agent that you have given us authority to communicate with and persons you ask us to share your data with, companies that we introduce you to, market researchers and customer service agencies for the purposes set out above. These agencies and firms may also share your personal data with others.
If, in the future, we sell, transfer or merge all or part of our business or assets, including the acquisition of other businesses, we may share your data with other parties. We will only do this if they agree to keep it safe and private and to only use it in the same ways as set out in this notice.
If you would like further information please contact us on the details given for us in this notice.
When personal data is transferred outside the European Economic Area (EEA)
Whenever fraud prevention agencies transfer your personal data outside of the EEA, they impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the EEA. They may also require the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing.
If we, a product provider, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we/they may refuse to provide the services and financing you have requested or may stop providing existing services to you. A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you.
If you fail to provide us with data we require, this may delay or prevent us from entering into a contract with you and or complying with our obligations. Depending on the importance of the data, it may mean that we are entitled to terminate an agreement with you.
If you have any questions about the above, please contact us on the details in section 1 above.
What choices and rights you have
Your personal data is protected by legal rights, which include your right to:
• object to our controlling and processing your personal data;
• object to our sharing of your personal data with others or with certain organisations;
• request that your personal data is erased or corrected or that its processing be restricted;
• request access to your personal data and for it to be given to you in a portable format;
• request that we transfer your personal data to another lender;
• request that we confirm what personal data we currently control and/or process in relation to you.
For more information or to exercise your data protection rights, please contact us using the contact details for us given above.
There may be legal or regulatory reasons why we need to keep or use your data, but please tell us if you think we should not be processing your data.
If you are unhappy about how your personal data has been used by us please contact us and we will send to you our Complaints Policy. You also have a right to complain to the Information Commissioner’s Office which regulates the processing of personal data. You can contact them at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, on 0303 123 1113 or by email to firstname.lastname@example.org. See also https://ico.org.uk/global/contact-us/.
How long personal data is kept
We will retain your personal data for a period of 6 years. We may retain your personal data beyond this date for the purposes mentioned above (legal & regulatory purposes) and will in any case at all times retain your personal data for the minimum period required by law. We may also retain your data to deal with any disputes, to maintain records and to show we have dealt with you fairly.
We may also retain your data for research and statistical purposes in which case we will ensure it is kept private and used only for these purposes.
We can only use your personal information to send you marketing information if we have your consent or a legitimate interest. A legitimate interest will usually be a commercial reason which cannot be used unfairly against you.