PRIVACY POLICY
As a result of Data Protection legislation and associated regulation, you are entitled to be assured that your personal data is collected, processed and stored for specific purposes and that this is done so securely and confidentially. We, as Data Controllers, have responsibilities under Data Protection laws to inform you of the data we collect, why we collect it, how we process it and with whom it will be shared. This is set out in our Privacy Notice, a copy of which you may already have been given.
Should you require any further details or wish to inquire on the details we hold on you please contact the firm’s Data Protection Representative via the following:
Email:
Post:
The Bridging Group
Springhead Enterprise Park
Fleet House
Springhead Road
Northfleet
DA11 8HJ
Telephone:
0207 052 1652
WHO WE ARE
The Bridging Group Ltd is regulated by the Financial Conduct Authority (FCA) for the supervision for anti-money laundering purposes only. Certain loan types, for example loans on some Buy to Let properties and those loans for business purposes are not regulated.
Details on The Bridging Group Ltd can be obtained from the FCA’s company register: https://register.fca.org.uk/
All of the above entities are registered with the Information Commissioners Office (ICO) as Data Controllers. Each firms’ entry can be searched at: https://ico.org.uk/esdwebpages/search
The Bridging Group Ltd is a bridging lender who provides short term loans which are unregulated. Bridging loans are generally for 12 months or less in duration. These loans can be provided on a first or second charge basis on the property.
Our registration number with the FCA is 911250. Its registration number with the Information Commissioner’s Office is: ZA471208
WHAT DATA WE COLLECT
Data collected through our contact form(s) (on the website and/or through Facebook or LinkedIn lead generation):
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Your name
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Phone number
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E-mail address
Data collected through loan application form (needed to underwrite your loan application):
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Your name
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Your current and previous address(es)
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Your date of birth
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Details on your financial profile including your income and expenditures
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Your identification documents (e.g. copies of passport or driving licence)
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Other relevant details required to establish your identity
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Other relevant information pertinent to the application for a loan and our underwriting of the repayment probability
Details we will never require from you:
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Your religious views
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Your political views
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Your sexual orientation
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Your trade union memberships
USE OF DATA COLLECTED THROUGH LOAN APPLICATION FORM
Under Data Protection laws we must have a legal basis for the collection of your data. This means that there must be a specific reason for us to request your data. TBG collects data for the maintenance of a contract for a loan and for the preparation of entry into this contract. The information is used and processed in order for us to decide on whether we will provide you with loan funds.
All initial data that we gather about you will be provided by your financial adviser or broker acting under your instruction.
Using that data, we will obtain further data from those external companies who maintain data on your credit history (i.e. CRAs) and Fraud Prevention Agencies as well as HM Land Registry.
USE OF DATA COLLECTED THROUGH CONTACT FORM(S)
Your data will be used for contact purposes in regard to your inquiry.
Beside contact purposes, data willingly shared with us through our Facebook page or contact forms on our website may be used to determine lookalike audiences on Facebook and partnering advertising and marketing agencies. By submitting your e-mail address, you also automatically subscribe to our newsletter service. To unsubscribe, click the 'unsubscribe' button at the bottom of any e-mail you've received from us and follow instructions.
WITH WHOM DO WE SHARE YOUR DATA COLLECTED THROUGH LOAN APPLICATION
Your data will be shared with other, external data processors to assist us in providing you with finance. These include:
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Credit Reference Agencies (CRAs)
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Fraud Prevention Agencies
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The FCA
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Statutory Bodies on their lawful request, e.g. NCA, police forces
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External funders
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Valuers
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Solicitors
WITH WHOM WE SHARE YOUR DATA COLLECTED THROUGH FACEBOOK LEAD GENERATION FORM AND SIMILAR
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Facebook and partnering marketing and advertising agencies
CRAs
CRAs maintain credit profile data on consumers within the United Kingdom. As part of the application process, your details may be shared with the CRA in order that we can view your credit history and profile. This provides details on loans, credit accounts, personal finance and utilities that you maintain or have maintained displaying how you have managed their repayments. While this informs our decision on providing you with finance, this is not the sole criteria for our decision.
In certain circumstances your repayment profile with TBG may be provided to the CRAs for inclusion on your credit profile, this includes any outstanding balance and the frequency and maintenance of scheduled repayments.
FRAUD PREVENTION AGENCIES
As a provider of credit to individuals and businesses, TBG also has an obligation to ensure against fraud activities. As a result, we will share your data with certain Fraud Prevention Agencies. These agencies maintain a database detailing those individuals who have perpetrated or have attempted to perpetrate fraud against agency members when making application in the past. We will submit your details to these agencies for them to perform a search match against your details.
Where we identify any fraud or potential fraud perpetrated by you against TBG, we will provide details of this to the Agencies for their inclusion on their database. This will be available to those other financial institutions who subscribe to the Agency and with whom you submit other applications for finance.
Decisions that TBG make are not solely based on information that we receive in these circumstances but will result in our requesting further details from you to clarify the issues that may be raised. Should you require more details on the agencies we use and how they process personal data then please contact TBG’s Data Protection Representative via the above methods.
EXTERNAL FUNDERS
In some circumstances, your data will be shared with our external funders to enable them to determine whether they will be able to provide finance on the loan application you have made.
VALUERS
Your personal data will be submitted to a surveyor to carry out a valuation on your property. The data passed will only consist of sufficient information they require in order to carry out this specific function.
SOLICITORS
As part of the loan process, we will in certain circumstances pass your data to solicitors acting on behalf of the company. These details will only be shared to facilitate the completion of a loan and the management of the transfer of funds to that solicitor acting on your behalf.
THE FCA AND OTHER STATUTORY BODIES
We have requirements, where requested by other statutory bodies, such as the National Crime Agency, police forces, the Serious Fraud Office, etc. to provide specified personal data on their lawful request for information. This is done on a confidential basis and, through legislation, you will not be entitled to be informed of when this transfer of data has occurred. Details of what data we have submitted to these entities are also exempt from disclosure under a Data Subject Access Request.
FACEBOOK AND PARTNERING MARKETING AND ADVERTISING AGENCIES
Your data may be used for advertising purposes in, e.g. lead generation and creation of lookalike audiences (within reason), on Facebook, Whatsapp, Messenger, Instagram and other closely related bodies.
YOUR RIGHTS
Data Protection legislation provides you with express rights which include:
YOUR RIGHT TO OBJECT OR REQUEST ERASURE OF THE DATA WE HOLD
You can object to TBG holding or processing your personal data and/or request that we remove this data from our storage. Please be advised, however, that should you request that this takes place before a loan completes then we will be unable to provide you with funds. Where your loan does complete, we have an obligation to retain your information in order to assure the performance of the loan contract so will be unable to remove your data during the term of any loan taken out with TBG. Please contact the firm’s Data Protection Representative for further details or to exercise your rights.
YOUR RIGHT TO CORRECT YOUR DATA
Where you or we become aware of an error in the data that TBG processes or holds, you have a right to have that data corrected. You can inform our Data Protection Representative of any errors that need to be corrected.
YOUR RIGHT TO A COPY OF YOUR DATA
You also have the right to request either the details of the data we hold on you or to request a copy of this. We are obliged to provide this to you within 30 days of receipt of your request. Please contact the firm’s Data Protection Representative to request this.
YOUR RIGHT TO DATA PORTABILITY
You have the right to request that data which we hold is passed to another Data Controller for their use on your behalf via a “machine readable” format. This can be requested from the Data Protection Representative of TBG.
YOUR RIGHT TO COMPLAIN
You have a right to complain, via our Data Protection Representative, in regard to how and why we process, or any errors we have made in the processing of, your data. Your complaint can also be made to the Information Commissioners Office:
Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Telephone: 0303 123 1113
Website: www.ico.org.uk
DATA RETENTION
TBG will only retain your data for as long as is necessary. In all cases this will be for the term of the loan plus 7 years, where you drawdown on your application. Where the loan does not complete, we will retain your data for 7 years from the date of final decision on whether you or we wish to proceed with the loan. We are obliged to retain your data for this period in order to meet our regulatory and legislative obligations.
DATA STORAGE
The TBG database provider complies with the EU-U.S. and Swiss Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. The database provider has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/
‘COOKIES’
A ‘cookie’ is a piece of data that a website transfers to the internet browser on your computer’s hard disk, which lets the website “remember” who you are. It will usually contain a unique, randomly generated, number. Major commercial and business websites generally employ cookies. They cannot be used by themselves to identify you, and we will not attempt to use them for this purpose. You can delete cookies manually – if you wish to do so, please consult your browser help manual. (There are also websites that help you do this.) “Session cookies” stay in your browser only until you close it. “Persistent cookies” stay in your browser for longer – how long depends on the “lifetime” of the relevant cookie.
USE OF ‘COOKIES’
We use session cookies to allow you to carry information across pages and avoid you having to re-type it. We may use persistent cookies so we can recognise your number (but not identify you further) when you return to our website, and, potentially, to enable us to note your interests, and arrange or edit content to match your interests, or those of borrowers generally, in a better way. Third parties may also serve cookies through this website. They may be used to put together statistics to help understand how people use the site, or to check whether, and how often, particular content is being viewed.
WEB BEACONS
Some pages may contain these electronic markers to allow us to count up the people who have visited these pages. They collect limited information, including the time when the page was viewed, and the cookie number. We may also carry web beacons placed by third party advertisers in order to track a campaign’s effectiveness, but, again, these will not collect information that would allow you to be identified personally.