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PRIVACY POLICY

Smart Home Finance respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

As we are based in the UK we are required to comply with UK and European legislation, in particular the General Data Protection Regulation (April 2016) and the Privacy and Electronic Communications Act 2003. For further information on these acts, please visit www.ico.gov.uk.

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how Smart Home Finance collects and processes your personal data through your use of this website, including any data you may provide through this website when you purchase/apply for a product or service.
This website is not intended for children and we do not knowingly collect data relating to children.

DATA CONTROLLER

Smart Home Finance, FCA number 610472 is the controller and responsible for your personal data. We are registered in accordance with the Data Protection Act with registration number ZA138583.

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy please contact the DPO using the details set out below.

CONTACT DETAILS

Our full details are:
Graham Abell
33 Newquay Close
Hinckley
Leicestershire
LE10 1XN

info@smarthomefinance.co.uk

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.

THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data

includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

• Contact Data

includes home address, email address and telephone numbers.

• Technical Data

includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

• Usage Data

includes information about how you use our website, products and services.

• Marketing and Communications Data

includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Use of Data

We will use your personal data to:

  • Process the application you have made by reference to lender information.
  • Make, or cause searches to be made, at a credit reference agency, or agencies.
  • To offer you other products which we make available.
  • Exercise or defend our legal rights and/or to comply with any legal requirements.
  • Provide your information to a lender for them to assess your suitability.
  • Complete the credit agreement on behalf of the lender.
  • Pass your information in its entirety to an alternative broker when Smart Home Finance cannot assist in brokering you a loan.

We may also use and disclose your personal information to:

  • A lender or lenders in accordance with your application.
  • Another broker if we are not able to arrange finance for you.
  • Enable us to pass your details to another company in the future with a view to them offering you products or services they feel may be of interest to you.
  • Permit access to your information by any regulatory authority where required by law (consent not required) and to ensure that we are complying with all regulatory requirements when processing your data.
  • Other legal authorities if required by law.
  • Contact you in the future to offer you products or services that we feel may be of interest to you.
  • Fraud prevention agencies to prevent fraud and money laundering.

We will disclose personal data to our partner Valid8 IP Ltd for the provision of credit report and identity information, which may include Equifax Ltd, Experian Ltd, and TransUnion. To understand how the credit reference agencies use and share personal data, please see the CRAIN notice:

TransUnion – http://www.transunion.co.uk/crain

Equifax – https://www.equifax.co.uk/crain/

Experian – https://www.experian.co.uk/legal/crain

I agree to the privacy policy of Smart Home Finance Ltd and authorise them to verify my identity and conduct soft credit searches on my behalf through their provider, Valid8 IP Ltd, with no impact on my credit score. I also agree to Valid8 IP’s privacy policy.

We may keep your information for several years to fulfil regulatory requirements, such as to enable us to deal with complaints. We will contact you for marketing purposes with products we feel may be of interest to you. You can change your mind about receiving marketing communications at any time by contacting us. We have a duty to keep the personal information which we hold about you up to date and accurate and secure from misuse or accidental loss or damage.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

[We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.]

METHODS OF DATA COLLECTION

We use different methods to collect data from and about you including through:

DIRECT INTERACTIONS.

You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you;

  • apply for our products or services;
  • create an account on our website;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us some feedback

COOKIES

As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree.

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. You will be asked to provide your consent for us to use cookies upon every visit to our website.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

THIRD PARTIES OR PUBLICLY AVAILABLE SOURCES

We may receive personal data about you from various third parties [and public sources] as set out below

  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
  • Identity and Contact Data from publicly availably sources [such as Companies House and the Electoral Register based inside the EU].

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • To enable us to provide a service to you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
  • Where we need to comply with a legal or regulatory obligation.
  • Where you give us your express consent to process your data in particular circumstances.
  • Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message.

Please contact us if you need details about the specific legal ground we are relying on.

DIRECT MARKETING

We provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

PROMOTIONAL OFFERS FROM US

You will receive marketing communications from us if you have provided your explicit consent via an opt-in box or you have previously purchased similar goods or services from us and, in each case, you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING
We will get your express opt-in consent before we share your personal data with any company for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time using the contact details outlined above.

TRANSFERRING DATA

We do not transfer your personal data outside the European Economic Area (EEA)./p>
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

We will appropriately dispose of any information you have provide in a confidential and secure manner once it is no longer required.

YOUR LEGAL RIGHTS

You have rights under the Data Protection Act laws in relation to your personal data including;

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data./li>
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact
Smart Home Finance, 33 Newquay Close, Hinckley, Leicestershire , LE10 1EQ
INFO@SMARTHOMEFINANCE.CO.UK

SUBJECT ACCESS REQUESTS

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

We respond to all legitimate requests within one month. Occasionally, it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

COMPLAINTS

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance using the contact details set out above.