Who we are, what we do, and how we process your data

We are Wigmore Bridging & Finance Limited trading as Wigmore Finance, with registered office is at 10-12 Bourlet Close, London W1W 7BR and company registration number 12652588 (referred to as “Wigmore Finance”, “we”, “us” or “our” in this privacy policy).

Changes to the privacy policy and changes to your personal data

We keep our privacy policy under regular review. This version was last updated on 25th November 2020.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Making a complaint

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.

If you do not provide data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. We will notify you if this is the case at the time.

The type of personal data that we collect and use

We may collect, use, store and transfer different kinds of personal data about you, as follows.

Identity including first name, maiden name, last name, username or similar identifier, marital status, religious beliefs, title, date of birth and gender, national insurance number, tax reference

Contact including home address, company address, email address and telephone numbers

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

Financial including bank account and payment card details

Transactions including details about payments to and from you and other details of products and services we have provided to you

Technical including 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

Profile including your username and password, your interests, preferences, feedback and survey responses

Usage including information about how you use our website

Where do we get your personal data from?

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

Direct interactions. You may provide us with your personal data by corresponding with us by post, phone, email or otherwise.
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below.
- Technical Data from analytics providers such as Google based outside the EU, advertising networks and search information providers.
- Contact, Financial and Transaction Data from lawyers, lenders, and others in connection with you, your assets and debts
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU

If you visit our website, we will log your IP address and use cookies to track your interactions. Our website uses the following types of cookies:

Google Analytics to analyse the use of our website.

The Google Analytics software will save a cookie to your device’s hard drive in order to track and monitor your engagement and usage of the website, but will not store, save or collect personal information. Google Analytics privacy policy can be viewed at

https://support.google.com/analytics/answer/6004245?hl=en

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.

Our website is hosted by wix.com – their privacy policy can be viewed at

https://www.wix.com/about/privacy

How we 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:

Where we need to perform the contract we are about to enter into or have entered into with 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.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

To engage you as a new client

To perform our role as a provider of finance

To manage our relationship with you which will include:

Notifying you about changes to our terms or privacy policy

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

To make suggestions and recommendations to you about goods or services that may be of interest to you

Type of data

(a) Identity

(b) Contact

(a) Identity

(b) Contact

(d) Transaction

(a) Identity

(b) Contact

(a) Technical

(b) Usage

(a) Identity

(b) Contact

(d) Usage

(e) Profile

(f) Marketing and Communications

Lawful basis for processing including basis of legitimate interest

Performance of a contract with you

Necessary to comply with a Legal Obligation

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Necessary for our legitimate interests (to develop our products/services and grow our business)

Disclosing your personal data to others

We may have to share your personal data with the parties set out below for the purposes set out in the table marked “Purposes for which we use your personal data” above.

Type of third party

Lawyers

Lenders

Bankers

Accountants

Auditors

Insurers

HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers

Country in which they are based

United Kingdom

Service provided / need for disclosure

Legal services

In connection with borrower debts

Banking services

Accounting services

Accountancy services

Insurance services

Require reporting of processing activities in certain circumstances

We also use a third-party provider Bright Office for our CRM and loan administration. You can view their privacy policy here: https://www.brightoffice.co.uk/privacy/

Credit Reference Agencies (CRAs)

We may carry out credit and identity checks in respect of you or your business. We may use Credit Reference Agencies and fraud prevention agencies to help us with this.

We will share your personal information with CRAs and they will give us information about you. This data includes:

• name, address and date of birth of you or your officers or members;

• your credit application;

• your financial situation and history;

• fraud prevention information; and

• public information, from sources such as the Electoral Register and Companies House.

We use this data to confirm your identity, assess the accuracy of the information provided to us, as well as to manage our relationship, trace and recover debts and to help to detect financial crime.

We will go on sharing your personal information with CRAs and fraud prevention agencies for as long as we are dealing with your case.

Where we store and transfer your data

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). We will only send your data outside of the EEA to comply with a legal duty or work with our suppliers in providing products and services to you. If we do transfer your personal information outside the EEA to our suppliers, we will make sure that it is protected to the same extent as in the EEA. We will use one of these safeguards:

• Transfer it to a non-EEA country where the European Commission has deemed that such country provides an adequate level of protection for personal data.
• Put in place a specific contract approved by the European Commission with the recipient that means they must protect it to the same standards as the EEA.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have an operational need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting 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.

By law we have to keep basic information about our appointments (including Contact, Identity, Financial and Transaction Data) for up to ten years after they cease being live appointments.

Exercising your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. There may be legal or other official reasons why we need to keep or use your data.

You have the right to:

• get a copy of the personal information we hold about you;

• question any information we have about you that you think is incorrect, so that we can take reasonable steps to check and correct it;

• share your data with outside companies, as a digital file, so that you can keep and use it yourself, or give it to other organisations;

• object to us keeping or using your personal data;

• ask us to delete, remove or stop using your personal data if there is no need for us to keep it;

• restrict the use of your data, so that it can only be used for certain things, such as legal claims or to exercise legal rights; and
• withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time.

If you wish to exercise any of the rights set out above, please contact us at privacy@wigmore.finance

No fee usually required

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 could refuse to comply with your request in these circumstances.

What we may need from you

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 may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could 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.

Tel: (0)20 3949 7943 Email: info@wigmore.finance

Tel: (0)20 3949 7943 Email: info@wigmore.finance

Privacy Policy