Eagle Asset Finance Limited (EAF) – Privacy Policy

EAF is committed to protecting and respecting your privacy.

EAF and what we do
Eagle Asset Finance Ltd are credit brokers. We are a totally independent company who have access to a representative range of lenders within the asset finance sector. We can introduce you to a wide range of finance providers dependent upon both your needs and your compatibility with their respective underwriting policies.

We source the funding for particular assets for a good price and we receive a payment of introductory commission from the lender for that service. Eagle Asset Finance Ltd does not levy any charges to yourselves in relation to the administration and overhead costs involved in the preparation of proposals and completion of documentation.

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.  Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting our websites you are accepting and consenting to the practices described in this policy.

For the purpose of the European Data Protection Regulations (‘GDPR’) and the Data Protection Act 2018 (the Act) and, the data controller is Eagle Asset Finance Ltd , 31 Barn Place, Livingston EH54 7EN.

This Privacy Statement explains how we process your information and your rights under both DPA and GDPR.

 

Information we may collect from you
We may collect and process the following data about you:

Information you give us: Personal information including, but not limited to, names of business partners/directors, dates of birth, addresses over the past three years, home ownership status, equity in home etc.

• Information we collect about you. Copies of bank statements, copies of accounting information and where appropriate business plans and financial projections
• Information we receive from other sources. Personal credit searches, HPi checks, Company searches, where appropriate.

 

Uses made of the information
We use information held about you in the following ways:

Information you give to us. We will use this information to evaluate the most suitable lender to match your individual needs. In the case of a future prospect we would hold your details on file to aid communication in the future,

Information we collect about you. We will use this information to formulate a finance proposal into an acceptable format to enable presentation of the information to a prospective lender.

Information we receive from other sources. This information will aid both us and the potential lender to evaluate your previous and existing borrowing history and evaluate whether or not they will accept any proposal and to establish any conditions of sanction thereon.

Disclosure of your information
We may share your personal information with anyone (or more) potential lender with a view to them evaluating any proposal and arriving at a decision as to whether they will accept or decline to provide finance to you.

We may share your information with selected third parties including:

• Business partners, suppliers and sub-contractors for the performance of any contract we enter into with [them or] you, including without limitation any data processor we engage.
• Analytics and search engine providers that assist us in the improvement and optimisation of our site.

We may disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Use or terms and conditions of supply and other agreements; or to protect the rights, property, or safety of EAF, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

 

Where we store your personal data
All information you provide to us is stored on our secure servers.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Your rights
You have the right to ask us not to process your personal data for marketing purposes. We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data.  You can also exercise the right at any time by contacting us at sclark@eagleasset.co.uk.

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates.  If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.  Please check these policies before you submit any personal data to these websites.

Your rights under Data Protection Law
We operate under the Data Protection Act 2018 (‘DPA’) and the European General Data Protection Regulation (‘GDPR’).
The DPA and GDPR apply to ‘personal data’ we process and the data protection principles set out the main responsibilities we are responsible for.

We must ensure that personal data shall be:

1. processed lawfully, fairly and in a transparent manner;
2. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
4. accurate and where necessary kept up to date;

 

1. kept for no longer than is necessary for the purposes for which the personal data are processed.  We operate a data retention policy that ensures we meet this obligation. We only retain personal data for the purposes for which it was collected and for a reasonable period thereafter where there is a legitimate business need or legal obligation to do so. For details of our current retention policy contact Stephen James Clark, Director EAF, at sclark@eagleasset.co.uk
2. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

We ensure lawful processing of personal data by obtaining consent; or where there is a contractual obligation to do so in providing appropriate products and services; or where processing the data is necessary for the purposes of our legitimate interests in providing appropriate products and services.

In the majority of cases, we process personal data based on your contract with the lender.  In other cases, we process personal data only where there are legitimate grounds for so doing.

To meet our Data Protection obligations, we have established comprehensive and proportionate governance measures.

We ensure data protection compliance across the organisation through:

1. implementing appropriate technical and organisational measures including internal data protection policies, staff training, internal audits of processing activities, and reviews of internal HR policies.
2. maintaining relevant documentation on processing activities.
3. implementing measures that meet the principles of data protection by design and data protection by default including data minimisation, pseudonymisation, transparency, deploying the most up-to-date data security protocols and using data protection impact assessments across our organisation and in any third party arrangements.

Under the GDPR You have the following specific rights in respect of the personal data we process:

1. The right to be informed about how we use personal data. This Privacy Statement explains who we are; the purposes for which we process personal data and our legitimate interests in so doing; the categories of data we process and third-party disclosures.
2. The right of access to the personal data we hold.  In most cases, this will be free of charge and must be provided within one month of receipt.
3. The right to rectification where data is inaccurate or incomplete.  In such cases, we shall make any amendments or additions within one month of your request.
4. The right to erasure of personal data, but only in very specific circumstances, typically where the personal data is no longer necessary in relation to the purpose for which it was originally collected or processed; or, in certain cases where we have relied on consent to process the data, when that consent is withdrawn and there is no other legitimate reason for continuing to process that data; or when the individual objects to the processing and there is no overriding legitimate interest for continuing the processing.
5. The right to restrict processing, for example, while we are reviewing the accuracy or completeness of data, or deciding on whether any request for erasure is valid.  In such cases, we shall continue to store the data, but not further process it until such time as we have resolved the issue.
6. The right to data portability which, subject to a number of qualifying conditions, allows individuals to obtain and reuse their personal data for their own purposes across different services.
7. The right to object in cases where processing is based on legitimate interests, where our requirement to process the data is overridden by the rights of the individual concerned; or for the purposes of direct marketing (including profiling); or for processing for purposes of scientific / historical research and statistics, unless this is for necessary for the performance of a public interest task.
8. Rights in relation to automated decision making and profiling.

Please contact our Stephen James Clark, Director EAF, at sclark@eagleasset.co.uk for more information about the GDPR and your rights under Data Protection law.

If you have a complaint about data protection at EAF contact Stephen James Clark, Director EAF at sclark@eagleasset.co.uk. Alternatively, contact our supervisory authority for data protection compliance (www.ico.org.uk):

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Tel: 0303 123 1113 (local rate) or 01625 545 745 (national rate)

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Changes to our privacy policy
Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

Contact
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to sclark@eagleasset.co.uk

Last updated: 25/05/18