YOU HAVE A RIGHT TO KNOW HOW WE WILL USE YOUR PERSONAL DATA.
We are committed to ensuring the security of your personal data.
The Data Protection Act 1998 (“DPA”) places obligations on us to process your information fairly and lawfully and to keep it secure. For the purposes of the DPA, the data controller of Website users’ personal data which is collected through the Website when users make an online enquiry is Together Financial Services Limited of Lake View, Lakeside, Cheadle, SK8 3GW. As a data controller, Together Financial Services Limited maintains a notification of its data processing activities with the Information Commissioner’s Office (ICO) and its registration number is ZA067862.
What is “Personal Data”?
The type of personal data we will collect about you via the Website
The Website provides users who are interested in our products/services with an opportunity to submit online enquiries to us. In addition, it enables users to submit their personal data to us for other purposes (such as for existing customers who wish to make payments towards their loans/mortgages using their credit/debit cards via the Website, to request a redemption figure, submit a Financial Statement Form (see below) or make a complaint).
The personal data that you may provide to us when submitting an online enquiry (or contacting us via the Website for the other purposes mentioned above) includes the following:
- your name;
- your contact details (including postal address, email address and phone number);
- your account number (when you are an existing customer and you contact us via the Website about your existing loan/mortgage, for example to request a redemption figure);
- your debit/credit card details (only when you choose to make a loan or mortgage payment online through the Website);
- information you choose to include in Financial Statement Forms which you download from the Website and post to us (please see ‘Financial Statement Forms’ section below); and
- any personal data you choose to include when typing additional comments in free text boxes (such as ‘tell us a little bit more about your enquiry’ or when submitting a compliant via the Website).
In addition, you may also provide us with your personal data by corresponding with us by phone, e-mail, post or otherwise. This includes personal data you submit when you subscribe to our service, apply for a loan, make an enquiry and/or when you report a problem with the Website. The information you give us may include some of the personal data listed above and any other personal data you choose to provide to us.
When you apply for our products/services, we will also collect information about you to verify your identify and your home address. We may also verify such information by accessing external databases held by third parties and agencies and also to prevent fraud and money laundering. This will be explained to you during your application for our products/services. We will provide you with details of these agencies should you require this information.
How we collect information about you
How we handle your personal data
We will observe the rights granted to you under applicable privacy and data protection laws and will ensure that queries relating to privacy issues are promptly and transparently dealt with. See below for details about how to contact us and how to exercise your right to obtain copies of your personal data from us under data protection laws.
We will only collect and process your personal data where we have lawful grounds to do so.
We will update our records if you inform us that your details have changed. Please tell us (see contact details below) as soon as possible about this. We will update our records promptly once we are satisfied that the new information (such as your new address or contact detail) is accurate.
How we will use the personal data we collect about you.
We will store and process your personal data on our computers and in our paper folders. Please see the Data Security header below for details about how we keep your personal data secure, in line with our obligations under the DPA.
We will use your personal data collected (including from any third parties, where relevant and lawful) to:
- contact you about our products/services (in response to your request for this contact which you have made via our Website);
- provide our products/services to you if you decide to go ahead and obtain them (but please note as explained above that supplemental privacy information, notices and/or statements will also be relevant to that processing);
- process payments you choose to may if you make a payment to us relating to your loan/mortgage via the Website:
- make decisions about the options we will provide to you if you are an existing customer who chooses to complete and send to us a Financial Statement Form downloaded via the Website (see ‘Financial Statement Form’ header below)
- comply with our legal obligations; and
- identify patterns which we can use to help us develop, administer, support and improve our services.
This list is not intended to be exhaustive and may be updated from time to time as business needs and legal requirements dictate.
Financial Statement Forms
The Website enables you to download a template Financial Statement Form which you can then complete and return to us by post. The Financial Statement Form is intended to be completed by existing personal customers whose circumstances have changed and may be worried about keeping up with repayments or have fallen behind with payments. Such customers can download a Financial Statement Form and post it to us, as described on the Website.
If you post us a completed Financial Statement Form, we will use the personal data/information contained within that form to gain a better understanding of the financial position you are in. Following reviewing your completed Financial Statement Form, one of our advisors will contact you to discuss your options.
The personal data which will be contained in a Financial Statement Form, when completed by you, includes (but is not limited to): your income (including salary); other types of incomes (including benefits and tax credits); the number of people living at your address (including children); pensions information; your essential expenses (including mortgage payments, council tax, court fines and care costs); housekeeping costs (including clothing, nappies and baby items, tobacco and alcohol); phone costs (home and mobile); travel costs (including car insurance); other spending (including health costs, school and work meals); details of existing debt; and your payment proposal.
We will only use the personal data contained in the Financial Statement Form for the purposes of reviewing your circumstances and contacting you to discuss your options and will not share the personal data submitted in that form with any third parties unless we have your explicit consent to do so (apart from any third parties acting as data processors on our behalf, as described below).
Sharing or disclosing your information with third parties
When our service is available via the websites of our partners, those partners may have access to your personal data. Their use of your personal data is governed by their privacy policies. We are not responsible for the privacy policies and practices of any other websites, even if you access them using links from the Website or if you can access the Website or use our services from them. We therefore recommend that you check the policy of each website that you visit and make sure that you are comfortable with the terms of such policies before providing any personal information.
If we offer or supply a service to you that is provided on our behalf by a third party we may have to pass your personal data to them in order to deliver the service. Where we do this, we will make this clear to you (by providing you with supplemental privacy information) before we pass your personal data to a third party.
We may also use third parties to provide services on our behalf which may include processing (but not using themselves for their own purposes) your personal data and this means we will disclose your personal data to them. For example (amongst others), to complete partial addresses, or to provide IT services such as data hosting. In either case, we will in accordance with our obligations under data protection law put in place appropriate written protections for your personal data including in our contract with them.
- our auditors, solicitors, professional advisors, sub-contractors or any person providing services to Together Financial Services Limited group companies and, who have agreed to treat your personal details as confidential;
- anybody having a legal right to your personal information, including the police and any other legal and regulatory authorities and government bodies;
- to any third party who acquires all, or substantially all, of the assets or shares in Together Financial Services Limited, any of our corporate group, and/or the Website, whether by sale, merger, acquisition or otherwise; and
- any other third party, where you have consented (where consent is required by law).
If you apply for finance
Although you are not able to directly apply for our products/services via the Website, you should be aware that in the event that you do apply for a mortgage or secured loan or other forms of finance (following your discussions with our advisors), then we will collect additional information from you in connection with your application, to enable us to manage any mortgage or secured loan or other form of finance you may enter into and to and provide services to you. This is described below for your information, but will be made clear to you at the point when you do apply for our products/services in supplemental privacy information, notices and/or statements.
When you apply
- We may pass your details to other companies in our group (associated companies) and to anyone who introduced you to us, in all cases as would be lawful under the DPA.’
- We may use your information to consider your application to enter a Credit Agreement with us and we will search your records at credit reference agencies. This will only be done where you have consented to such use of your personal information.
- The record of our search will be recorded by the agency and will be seen on any future searches made. We will provide you with further details about this in supplemental privacy information, notices and/or which we will provide to you before the search.
- The credit reference information may be linked to any person to whom you are linked financially (see 'associated records' below before you sign).
- We may use a credit scoring or automated decision making system to assess your application and verify your identity.
Before entering into any agreement with you we may search your records at credit reference agencies which may be linked to records relating to your spouse/partner or other persons with whom you are financially associated. It is your responsibility to ensure that you have the permission of such other person for us to process their personal data for the purposes of your application for our products/services.
For the purpose of an application you and any joint applicant may be treated as financially linked and your application will be assessed with reference to 'financially associated' records. Before any search or application is completed or any agreement is entered into involving joint parties you both consent to us recording your details with credit reference agencies – we will ask you to confirm this consent when you make an application for our products/services. As a result an association will be created which will link your financial records and your associate’s information may be taken into account when a future search is made by us or another company unless you file a 'disassociation' at the credit reference agencies.
When you have an agreement with us
We will add to your records with the credit reference agencies details of any agreement with us, the payments you make under it, any default or failure to keep to its terms and any change of name or address. Account information given to credit reference agencies remains on file for 6 years after the account is closed, whether settled by you or upon default.
How we and others use the information at credit reference agencies
IT IS IMPORTANT THAT YOU PROVIDE US WITH ACCURATE INFORMATION. If false or inaccurate information is provided and fraud is identified, details will be passed to fraud prevention agencies. Law enforcement agencies may access and use this information.
We and other organisations may also access and use this information to prevent fraud and money laundering, for example, when:
- checking details on applications for credit and credit related or other facilities;
- managing credit and credit related accounts or facilities;
- recovering debt;
- checking details on proposals and claims for all types of insurance;
- checking details of job applicants and employees.
Please contact us at Risk Department, Lake View, Lakeside, Cheadle, Cheshire, SK8 3GW if you want to receive details of the relevant credit reference and fraud prevention agencies from which we obtain, and to which we pass, information about you. We and other organisations may access and use, from other countries, the information recorded by fraud prevention agencies. You have a legal right to these details.
The information held by these agencies may also be used for other purposes for which you give your specific permission or, in very limited circumstances, when required by law or where permitted under the terms of the DPA.
From time to time and where we have collected appropriate consents under data protection laws to permit this, we, and other companies within our corporate group, would like to send you information about our/their other credit related and financial goods and services which may be of interest to you and which are similar to our own. If you have consented to receive these marketing communications, you may be contacted in each case by post, fax, telephone, recorded message, email, SMS or by any other method made clear to you at the time you gave your consent.
If you have consented to receive marketing communications but no longer want to receive details of these goods and services please write to us at Together, Marketing Department, Lake View, Lakeside, Cheadle, SK8 3GW or email us at: firstname.lastname@example.org. You will be reminded of how to unsubscribe in each electronic marketing communication too.
Where you have provided your consent, we may also pass your personal data to selected businesses outside of our corporate group who may contact you directly about their services and products that may be of interest to you.
If you have consented to us passing your personal data to companies outside of our corporate group but no longer want us to do this, please write to us at Together, Marketing Department, Lake View, Lakeside, Cheadle, SK8 3GW or email us at: email@example.com. Please note this does not mean we can obtain data back from those other companies. You would need to contact them directly to stop their marketing to you – their contact details should be in the marketing communications they send to you.
Recording of telephone calls
Once you have provided us with your personal data via the Website, we may contact you by telephone to discuss your enquiry. We may monitor and record incoming and outgoing telephone calls for staff training and quality control purposes.
How long we keep your personal data.
We take steps with a view to deleting, destroying or permanently anonymising your personal data (which means that we are no longer able to identify you from it) when it is no longer necessary for its purpose and we are not required by law to keep it.
How long we keep your personal data depends upon the purpose for which your personal data was collected was provided. Generally however:
- we will keep the information no longer than is necessary to enable us to provide you with a service that you have requested for as long as it takes us to provide that service;
- we will keep your contact details for a reasonable period after you have given us your consent to use them for marketing purposes (but we will not retain these details indefinitely); and
- we will keep other information about you if it is necessary for us to do so to comply with our legal obligations.
Will my personal data be transferred outside of the European Economic Area?
Your right to see your records
You have a right, upon payment of the appropriate fee (currently £10) to obtain a copy of the personal data we hold about you. If you wish to request a copy of the information we hold about you please write to: Together, Customer Care, Lake View, Lakeside, Cheadle, SK8 3GW. Alternatively you can email us at: firstname.lastname@example.org.
In accordance with our obligations under the DPA, to prevent unauthorised access to or disclosure of your personal data (including card payments), maintain data accuracy, and ensure the appropriate use of your personal data, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the personal data we collect online.
However, you acknowledge that, unfortunately, the transmission of information via the internet, including the online enquiry forms you submit to us, is not completely secure. We cannot guarantee the security of your data transmitted to the Website: any transmission (i.e. your sending of the personal data to us) is at your own risk. Once we have received your personal data, we will use the steps detailed above to protect it.
You should be aware that there are inherent risks in transferring personal data over the Internet. For example, if you send us an e-mail from your private mailbox, we cannot guarantee the security of the content during its transmission to us. For that reason, please do not send to us an unsecured e-mail with confidential information such as your National Insurance or bank account numbers, or any sensitive personal data.
Customer feedback and complaints
If you have any questions about our Privacy Notice please contact Customer Care at Together, Lake View, Lakeside, Cheadle, SK8 3GW.
Last updated: 9 December 2016.
This Website is operated by Together Financial Services Limited, trading as “Together”, a company registered in England and Wales under company registration number 02939389 and its registered office address situated at Lake View, Lakeside, Cheadle, Cheshire, SK8 3GW. References in this Cookies Policy to "we", "us", "our" and "ourselves" are references to Together Financial Services Limited. References to “you” or “your” are references to any person reading this Cookies Policy.
A description of the types of cookies used by the Website and how we use them can be found below. We may update this description from time to time. As mentioned, steps will be taken to draw this to the user’s attention and to collect appropriate new consents at that time, where necessary.
When users use the Website they will be using a browser and this means that they can control, block or restrict cookies through their browser settings. Information on how to do this can be found within the Help section of the browser used. All cookies are browser specific. Therefore, if you use multiple browsers or devices to access websites, you will need to manage your cookie preferences across all of these elements. In addition when you first visit our Website you will see a cookies consent banner or pop-up which draws your attention to the fact that cookies are used and which links through to this Cookies Policy.
There are also several online resources that can provide more information on cookies and how they can be controlled within a variety of different web browsers. Please visit either http://www.aboutcookies.org or http://www.allaboutcookies.org for more information.
If you use a mobile device to access the Website, you will need to refer to your instruction manual or other help/settings resource in order to find out how to control cookies on the particular device.
Please note: if you restrict or delete cookies, you may experience a loss of functionality while accessing the Website and you will be treated as a first time visitor the next time you visit the website.
The Website uses session cookies (which expire once a user closes their web browser). The Website may also use persistent cookies (these remain on a user’s computer or other device when they close their web browser – until such time as they expire or the user deletes them).
We have grouped the cookies used by the Website into the following categories, to make it easier for you to understand why we use them:
- Strictly Necessary: these cookies are strictly necessary for the Website to work properly and for us to keep to seek it secure. They are needed to allow users to use the Website and its features, including to move between pages of the website.
- Functionality: these cookies enable technical performance of the Website and allow us to ‘remember’ the choices users make and their preferences. They allow us to give a better online experience, such as ‘remembering a user’ (e.g. their language preferences) when they next access the Website. They also help us to track performance of the Website.
- Performance/Analytical: these cookies allow us to collect certain information about how a user navigates the Website. They help us to understand which parts of the Website are interesting to users and which are not as well as what we can do to improve the Website. They also help us to identify when lots of people give up on an application process at a particular step – so we can try to make that step easier to use.
You might notice that some cookies on the website are not related to us (i.e. Together Financial Services Limited). This is because some of the pages on the Website contain embedded content from third party websites – such as video from YouTube for example. Because this content is from another website, we do not control the cookies which relate to this. If a user wants to change their cookie preferences to block these third party cookies, they should check the third party websites for information on how to manage their cookies.
We may also embed social sharing icons throughout the Website. These sharing options are designed to enable users to easily share the Website’s content with their friends using a variety of different social networks. These social sharing sites may set a cookie when a user is logged into their service. Please note that we do not control the dissemination of these cookies and users should consult the relevant third party website for information on how these cookies are used and how the user can control them.
Last updated: 9 January 2017