Fairview Financial understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, www.fairviewfinancial.co.uk (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Cookie”: means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below;
“Cookie Law” : means the relevant parts of the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;
“Personal data”: means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”);
“We/Us/Our”: means Fairview Financial, a limited company registered in England under company number 10912424, whose registered address is 107 Promenade, Cheltenham, GL50 1NW
2. Information About Us
2.1 Our Site is owned by Fairview Financial Ltd, registered in England and Wales no: 10912424, registered office: 107 Promenade, Cheltenham, GL50 1NW. Our site is hosted and operated by MA DESIGN, a limited company registered in England under company number 05294974, whose registered address is 3 The Paddocks, Lassington, Highnam, Gloucester GL2 8DD and whose main trading address is Cheltenham Film Studios, Hatherley Lane, Cheltenham GL51 6PN.
2.2 Our VAT number is 850 7527 20.
2.3 Our Data Protection Officer is Adam Stretton, and can be contacted by email at email@example.com, by telephone on 01564 732 744, or by post at St Johns Court, 70 St Johns Close, Knowle, Solihull, B93 0NH.
2.4 We are regulated by the Financial Conduct Authority, our FCA number is 786469.
2.5 Fairview Financial Ltd is an appointed representative of The Right Mortgage Limited, a limited company registered in England under company number 08130498, whose registered address is St Johns Court, 70 St Johns Close, Knowle, Solihull, B93 0NH.
3. What Does This Policy Cover?
4. Your Rights
4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
4.1.1 The right to be informed about Our collection and use of personal data;
4.1.2 The right of access to the personal data We hold about you (see section 12);
4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);
4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);
4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7The right to object to Us using your personal data for particular purposes; and
4.1.8 Rights with respect to automated decision making and profiling.
4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
5. What Data Do We Collect?
5.1 Personal details which may include (without limitation): names, addresses, date of birth, sex, National Insurance number, passport number, tax identification numbers, telephone and mobile numbers and email addresses
5.2 Race, ethnic origin, religion, biometric, political, genetic data, trade union membership, sexual orientation, sex life
5.3 Employment and education history
5.4 Lifestyle and social circumstances
5.5 Goods and services
5.6 Income and financial details which may include (without limitation): bank account details, investment details, insurance details, documentation of the above and notes of meetings.
5.8 IP addresses
5.9 Information from credit reference agencies or fraud prevention agencies and other publicly available sources
5.10 Any other information which is provided by the individual to the Company pursuant to their contractual agreements.
6. How Do We Use Your Data?
6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.
6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
6.2.1 Providing and managing your access to Our Site;
6.2.2 Personalising and tailoring your experience on Our Site;
6.2.3 Supplying Our products and services to you (please note that We require your personal data in order to enter into a contract with you);
6.2.4 Personalising and tailoring Our products and services for you;
6.2.5 Replying to emails from you;
6.2.6 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by clicking the unsubscribe link in the footer of all emails or email firstname.lastname@example.org);
6.2.7 Market research;
6.2.8 Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;
6.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email, telephone, text message and post with information, news and offers on Our products and services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011.
6.4 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
6.5 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
6.5.1 For no longer than it is necessary for us to fulfil our legal and regulatory responsibilities
7. How and Where Do We Store Your Data?
7.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
7.1 Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR including:
7.1.1 Privacy Shield; this framework was designed by the US Department of Commerce, European Commission and Swiss Administration to provide companies on both sides on the Atlantic with a mechanism to comply with Data Protection regulation. For further information www.privacyshield.gov
7.2 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
7.4 Steps We take to secure and protect your data include:
7.4.1 Keeping software up to date;
7.4.2 Restricted access;
7.4.3 Anti-virus software;
7.4.4 Server and email encryption.
8 Do We Share Your Data?
8.1 We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
8.2 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.
8.3 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
We also have a regulatory responsibility to share data with our regulator, The Financial Conduct Authority (FCA).
9. What Happens If Our Business Changes Hands?
9.2 In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes
10 How Can You Control Your Data?
10.1 We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails or by emailing email@example.com.).
11 Your Right to Withhold Information
11.1 You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
12 How Can You Access Your Data?
12.1 You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact us for more details at firstname.lastname@example.org, or using the contact details below in section 14.
13.2 All Cookies used by and on Our Site are used in accordance with current Cookie Law.
13.3 Before Cookies are placed on your computer or device, you will be shown a prompt, e.g. cookie pop up, requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.
13.4 Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 13.5. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 13.7, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
13.5 The following Cookies may be placed on your computer or device:
13.5.1 Strictly necessary cookies. These are cookies that are required for the operation of our site. They include, for example, cookies that enable you to log into secure areas of our site, use a shopping cart or make use of e-billing services.
13.5.2 Analytical/performance cookies. They allow us to recognise and count the number of visitors, and to see how visitors move around our site when they are using it. This helps us to improve the way our site works, for example, by ensuring that users are finding what they are looking for easily.
13.5.3 Functionality cookies. These are used to recognise you when you return to our site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
13.6 Our Site uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and the products and services offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
13.6.1 The analytics service(s) used by Our Site use(s) Cookies to gather the required information.
13.6.2 The analytics service(s) used by Our Site use(s) the following Cookies:
Name of Cookie: Tracking Cookie
Third Party: Third Party
Purpose: All of this information is anonymous and is used to compile general visitor statistics such as what type of device is used, how long spent on sites, what pages are looked at, how people reached our sites (e.g. from a search engine) and whether they have been here before.
All of this data is completely anonymous and helps us to build a better website and experience for our visitors.
13.7 In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
13.8 You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, personalisation settings.
13.9 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
14 Contacting Us