How we use your information
This privacy notice advises you what to expect when Acorn Finance Limited (“AFL”) collects your personal data and makes sure that we continue to comply with privacy law and regulation. AFL is the Data Controller for the information you provide to us and information we obtain. We have developed this policy because we want you to feel confident about the privacy and the security of your personal information. AFL is registered under the Data Protection (Jersey) Law 2018 and Data Protection Authority (Jersey) Law 2018, effective 25th May 2018, following the EU General Data Protection Regulation (GDPR).
What information do we ask for and why?
When we refer to “personal information”, we mean information which identifies you as an individual, or is capable of doing so. We may hold and use data about you in your capacity as a consumer, business customer, individual, as a shareholder, or any other capacity in which you and your representatives may use our services. This will include related client due diligence records, financial data and other personal information relating to your application. We collect this personal information in order to provide you with loan related products, advice and services provided by us and our funding partners. We rely on the lawful basis of contract in order to process your personal data, as this processing is necessary for us to assist you. We do not seek to collect more information than what we need to process your requirements. If you do not provide the information that we ask you for, then we may not be able to provide you with the products or services you require. Any information that you provide will be retained by us for at least five years following completion of our business relationship.
We collect information about you when you submit an enquiry to us, call or email us to discuss a product or service, become our client, and apply to use any of our services or contact us in person, by telephone, by e-mail, social media or by post. We also collect information from you when you complete a contact form on our website. When you access or use our website, usage information is collected using cookies. Cookies are small files which can be stored on your computer when you visit a website. These files contain information about the web pages you look at so that the next time you visit the site it can be customised to meet your needs. Most browsers support cookies but you can set your browser to decline them and delete them whenever you like. However, some functions of our website may not function as they should if cookies are not enabled. You can find out more about how to manage cookies on the AboutCookies.org website.
We collect information about you for the following reasons:
• For processing of your application and to assess your suitability to use our products and services;
• Assisting us in providing you with the services that you are requesting;
• To verify your identity to help prevent money laundering and financial crime;
• To identify you on contact with us to help protect your information and prevent unauthorised access;
• To send you general and marketing communications, if you provide consent to allow us to do so;
• Helping us to administer our website and improve your browsing experience; and the services we provide.
What will we do with the information you provide to us?
All of the information you provide to us and obtained by us will only be used for the purpose specified, or to fulfil contract, legal or regulatory requirements. This may involve the sharing of your personal data with third parties. Information may be disclosed to any of our employees, funding partners and their group entities, shareholders, officers, agents, suppliers or third parties where this is necessary to enable us to provide our services to you or to allow us to comply with our legal or regulatory obligations.
Third parties with whom we may share your information are as follows:
• Our Funding Partners, Brokers, Private Lenders, Intermediaries, Service Providers and their Group Companies: Sometimes we share information with these parties in order to ensure we can provide and maintain the provision of products and services to you.
• Regulators: The Jersey Financial Services Commission, law enforcement, government, courts, dispute resolution bodies, other regulatory bodies and some government agencies have a legal right to access the information we hold. We have a legal obligation to disclose information we hold to such bodies.
• Our professional advisers: Our appointed auditors, accountants, lawyers, debt collection agencies and other professional advisers sometimes require access to the information we hold in order to advise us.
• Credit reference agencies (CRAs), fraud prevention agencies (FPAs) debt recovery agents, screening providers and related service providers: We may use credit reference agencies and fraud protection agencies to assess your ability to meet financial commitments. We may do this when you first approach us, as part of the provision of services to you, and thereafter as required to manage your account with us retaining a copy on our records. We are happy to provide you with a list of the agencies we use upon request, should you wish to contact them directly for personal data records held. When you apply for finance the Company will check your details against databases of the financial records about you and related parties for verification. If you are making a joint application or tell us that you have a spouse, partner or financial associate, we will link your records together so you must be sure that you have their consent to disclose information about them and provide them with a copy of this notice. CRAs also will link your records together and these will remain on your and their files until such time as you or your partner successfully files for a disassociation with the CRAs to break that link. Further information relating to the use of your data by the CRA’s in relation to GDPR can be found here www.experian.co.uk/crain
Information on applications will be sent to CRAs and will be recorded by them; this will also leave a specific footprint of the search. Where you borrow from us, we will give details of your account and how you manage it/them to CRAs. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt. This information may be supplied to other organisations by CRAs and FPAs to perform similar checks and to trace your whereabouts and recover debts that you owe. This may affect your ability to obtain further credit. Furthermore if you have borrowed from us and do not make payments owed, we will seek to trace your whereabouts and recover debts, we may use a debt tracing/collection agency for this purpose.
We would like to send you information about products, services, updates and news of ours and other Acorn Group companies which may be of interest to you. This will only be sent if you have consented to receive marketing, by opting in. You have a right to stop us from contacting you for marketing purposes upon request at any time, please let us know by email at email@example.com or by contacting the Data Protection Officer as per contact details below.
How we protect your personal information
We take appropriate security measures (including physical, electronic and procedural measures) to help safeguard your personal information from unauthorised access and disclosure. For example, only authorised employees are permitted to access personal information, and they may do so only for permitted business functions. In addition, we use firewalls to help prevent unauthorised persons from gaining access to your personal information.
Your rights under the regulation and laws:-
Following implementation of GDPR, you have rights as an individual which you can exercise in relation to the information we hold about you. Individual Data Rights are:-
– The right to be informed. As provided by this notice.
– Right of access. You have the right to know what personal data we hold about you and how we use it.
– Right to rectification. You have the right to have any errors in the data we hold for you to be corrected if inaccurate or incomplete.
– In some circumstances you have the right to request that we erase your information. However we may continue to retain your information if we’re entitled or required to retain it.
– In some circumstances, you have the right to withdraw your consent to our processing of your information; however we may continue to process your information if we have a legitimate reason for doing so.
– Right to data portability. You have the right to be supplied with a copy of the all the personal data that we hold for you in a readable portable format and/or request that we transmit to a third party.
– The right to object to, and to request that we restrict our processing of your information in some circumstances. Again, there may be situations where we are entitled to continue processing your information and/or to refuse that request.
– Right not to be subject to a decision based solely on automated processing. We do not base any decisions solely on automated processing of your personal data, but if we did, you would have the right to restrict our use of your data for this purpose.
You can exercise your rights by contacting us as below or you also have the right to complain to the Office of the Information Commissioner in Jersey by visiting www.oicjersey.org
Subject Access Requests
You have the right to see the information that we hold about you and to have any inaccurate or incomplete information that we have about you to be corrected. If you would like a copy of your personal information we hold, please contact us using the contact details below. We will also advise why we are holding it and advise you who it could be disclosed to. We want to assist to make sure that your personal information is accurate and up-to-date and in this respect you may also ask us to correct or remove information you think is inaccurate, we also ask that you keep us updated of any changes to your information. There is no fee to you to obtain this information or make corrections.
Complaints or queries
AFL tries to meet the highest standards when collecting and using personal information. For this reason, we take any feedback or complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures. This privacy notice was drafted with brevity and clarity in mind and does not provide exhaustive details in all aspects of Acorn’s collection and use of personal information. However, we are happy to provide any additional information or explanation needed. If you require further information, or have a complaint about the way we have collected and processed your personal information you can contact us as below:
The Data Protection Officer, Acorn Finance Limited, First Floor, IFC 5, Esplanade, St Helier, Jersey, JE2 3BY, or email us on firstname.lastname@example.org or by contacting the Data Protection Officer on 01534 618628.
This Privacy Notice may be updated from time to time and the most recent version can be found at www.acorn.je. This privacy notice was last updated in May 2018.