Organisation Name: Credit Partners Ltd
Date: April 2018
1. We process your personal data
We process your personal data in accordance with the requirements of the General Data Protection Regulation (GDPR). In particular, we process personal data solely for lawful purposes, either in connection with a contract we have with you, subject to your consent, or on another permitted basis. We only process the minimum amount of personal data that is required for the relevant processing purpose, and we limit our processing to specific limited purposes necessary to conduct our activities. We only store your personal data as long as it is necessary for the purpose of the specific processing activity it was collected for, or for any longer period of time that we may be obligated by law to retain it.
As defined in the GDPR, “personal data” is any information relating to an identified or identifiable natural person (a “data subject”), being a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
2. Personal data collected on our Website
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic, such as which pages are found most useful, which can be used to improve our website. This information is only used for statistical analysis purposes and is then removed from the system. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
3. How we use your personal data
Credit Partners uses personal data to better understand your needs and interests and to provide you with a better service. Once you choose to provide us with personal data, whether through this website or by other means in the course of our activities and interaction with you, you can be assured it will be used only as specifically detailed below, or as otherwise explicitly consented by you.
We will collect data about you, both personal data (such as your name and contact details) and also sensitive personal data (such as information in your CV and call recordings). The personal data and sensitive personal data will be stored, processed, used and disclosed by us in the following ways:
From time to time we may seek your consent to process, use or disclose your information for any other purpose not listed above.
For further information on how we process your personal data, you can contact our company Managing Director, Alex Horlock at firstname.lastname@example.org. The controller responsible for the processing of your data is Credit Partners Ltd.
Where you have provided us with consent to process your personal data, you have the right to withdraw this consent at any time. This will however not affect the lawfulness of processing based on consent before its withdrawal. In any event, you can always inform us that you wish to withdraw your consent in respect of a specific processing activity and related personal data by emailing us at email@example.com.
If you do so, please provide us with your full name, email address and sufficient details about the consent you provided, including the scope of the consent and the personal data the consent related to. We collect your name and email address in this context only for the purpose of identifying you in order to execute your consent withdrawal request.
We only retain your personal data for as long as it is necessary for the relevant processing activity, or as otherwise required by law. We also maintain detailed policies and procedures regarding how and how long we retain your personal data.
4. Who we share your personal data with
Certain Credit Partners services may be linked with those from third-party companies, some which offer you the option to share personal data you provide with both Credit Partners and the third party. We will not share your personal data with third-party companies unless you make that choice.
Circumstances may arise where, whether for strategic or other business reasons, Credit Partners decides to sell, buy, merge or otherwise reorganize businesses in some countries. Such a transaction may involve the disclosure of personal data to prospective or actual purchasers or receiving it from sellers. It is Credit Partners practice to seek appropriate protection for information, including personal data, in these types of transactions.
Credit Partners may share your personal data with third parties acting on behalf of Credit Partners, which may be located in other jurisdictions. We ensure that such transfers are lawful, including by ensuring that they are to jurisdictions that are considered to have equivalent privacy protections, and/or ensuring that the third parties to whom we transfer your personal data are under contract to Credit Partners and bound by appropriate data protection clauses or other approved safeguards, as applicable in each situation.
5. Your rights
You have certain specific rights with respect to how we process your data. Credit Partners is committed to ensuring that your rights are protected. The GDPR sets out the following rights applicable to data subjects:
b) The right of access – You have right to obtain from us confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and the following information:
Where personal data are transferred to a third country or to an international organisation, we will inform you of the appropriate safeguards in place in relation to the transfer.
c) The right to rectification – We will rectify without undue delay any inaccurate personal data we hold concerning you, including completing any incomplete personal data.
d) The right to erasure (also known as the ‘right to be forgotten’) – You have the right to have us erase all personal data we hold concerning you, without undue delay, in one of the following circumstances:
We cannot execute your request if the personal data you are asking us to erase is necessary:
e) The right to restrict processing – You have the right to request that we restrict specific processing of your personal data, and we will comply, where one of the following applies:
While you have restricted its processing, we will only store your personal data in question, and may process it only with your consent or to establish, exercise or defend legal claims or protect the rights of another natural or legal person or for reasons of important public interest. We will notify you before lifting the processing restriction.
f) The right to data portability – You have the right to receive from us your personal data that you have provided to us, in a structured, commonly used and machine-readable format, and you have the right to transmit those data to another controller without hindrance from us, where:
Where technically feasible, we will transmit your personal data directly to the other controller.
g) The right to object – You have the right to object to Credit Partners processing your personal data in connection with our legitimate interests in the context of our activities (including profiling), direct marketing (including profiling), and processing for scientific and/or historical research and statistics purposes, where applicable.
h) Rights with respect to automated decision-making and profiling – You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. You can object to your personal data being used in this way. We are permitted to use automated decision-making and profiling if the decision:
Where we engage in automatic decision-making or profiling in connection with a contract between us or further to your explicit consent, we implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention from us in the course decision-making process, and the opportunity to express your point of view and to contest the decision.
i) Right to lodge a complaint with your data protection supervisory authority - In the event you believe that we are processing your personal data otherwise than in accordance with the provisions of the GDPR, you have the right to lodge a complaint with the data protection supervisory authority located in the EU jurisdiction where you reside. For the UK, the supervisory authority is the UK Information Commissioner’s Office.
6. Links to non-Credit Partners website
7. Children's privacy
Credit Partners is committed to protecting the privacy needs of children and we encourage parents and guardians to take an active role in their children's online activities and interests. Credit Partners does not knowingly collect information from children under the age of 16 and Credit Partners does not target its website or any of its services to children under the age of 16.
8. Keeping your personal data secure
Credit Partners is committed to protecting the information you provide us. To prevent unauthorized access or disclosure, to maintain data accuracy, and to ensure the appropriate use of the information, Credit Partners has in place appropriate technological and operational procedures to safeguard the information we collect.