Privacy policy

  1. Introduction
    • 1.1 We are Fitzrovia Finance Ltd and Fitzrovia Finance Security Ltd. (referred to as "we", “us” and “Fitzrovia Finance”) and our contact details are in Clause 10. We are committed to protecting and respecting your privacy in relation to the Service in accordance with the principles relating to the processing of personal data under the Data Protection Act 1998/2018 (including the General Data Protection Regulation (EU) 2016/679, and any replacement statute from time to time (the “Act”). For the purpose of the Act, we jointly determine the purposes and means of the processing of your personal data. This means we are joint “controllers” under the Act. This Privacy Policy and the Service Terms determine our respective responsibilities for compliance under the Act.
    • 1.2This Privacy Policy is agreed as part of the Fitzrovia Finance Service Terms (“Service Terms”) on registration to use the Service, and it should be read in conjunction with the Service Terms. Capitalised terms not otherwise defined in this Privacy Policy shall have the meanings given in the Service Terms.
    • 1.3Please note that the Payment Service Provider you agree to use in conjunction with the Service has its own privacy policy, which you agree directly with the Payment Service Provider. In addition, the Service may from time to time contain links to and from the websites of 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 we do not accept any responsibility or liability for those policies. Please check those policies and any relevant service terms and conditions before you submit any personal data to those websites. We are not responsible for the content of any other websites or services.
    • 1.4This Privacy Policy explains what types of information relating to you (your “personal data”) we collect, the purposes for which we collect and process it , the legal basis for doing so and the organisations or types of organisations, if any, that we may provide your personal data. It is necessary to enter into the Service Terms, including the Privacy Policy, and to collect, process, share and store the personal data as described in order for us to be able to provide the Service to you.
  2. What personal data do we collect?
    • We may collect, store and use the following kinds of personal data for processing on the basis specified in Annex A at the end of this Privacy Policy. Personal data will be stored in accordance with Clause 6 of this Privacy Policy.
    • Please note that we aim to keep your personal information up-to-date, so you must notify us by emailing support@fitzroviafinance.com within thirty days if any of any change in your name, residential address, telephone number, or e-mail address and please advise us of any other changes to your personal data by email or by updating your Fitzrovia Finance Account.
  3. How do we use personal data not provided to us by you?
    • 3.1 We may use third-party advertising companies to serve advertisements when you visit our Service. These companies may use information about your visits to the Service and other websites in order to provide advertisements about goods and services of interest to you. This information does NOT include information like your name, address, email address, or telephone number.
    • 3.2 When you submit a Loan Application, we will check the following personal and business records about the director, partner, or member who agree to this agreement on behalf of the main applicant:
      • our own records;
      • records of CRA’s (Credit Reference Agencies);
      • records of FPA’s (Fraud Reference Agencies).
    • We check the records of CRA databases, which relate to the main applicant’s personal and business activities. Any personal data we receive in response to our checks will be stored in accordance with Clause 6 of this Privacy Policy.
    • We will make checks such as assessing the application for credit and verifying identities to prevent and detect crime and money laundering. We may also make periodic searches at CRA’s and FPA’s to manage our relationship with you.
    • The agencies will link your records to those of your financial associate(s) (e.g. someone with whom you have a joint credit account), including any previous and subsequent names of parties to the account. These links will remain on your, and their, credit reference files until you or they successfully files for a disassociation with the agency. When assessing the affordability of your repayments, we may take into account information about your financial associates in your credit reference.
    • When CRA’s receive a search from us they will place a search on the credit file of the applicant(s) that may be seen by other lenders. The CRA’s supply to us both public (including the electoral register) and shared credit and fraud prevention information. If you are a director, we may also seek confirmation, from credit reference agencies, that the residential address that you provide is the same as that shown on the restricted register of director’s usual addresses at Companies House.
    • We will give you at least 28 days’ notice if any decision to file notice of any default by you in your obligation to make repayments on your credit reference file. However, we may not always give you notice beforehand, for example, if enforcement action is planned.
    • If you give false or inaccurate information and we identify fraud, this will be recorded and may be shared by those agencies with other organisations and us, so that we and those other organisations, including law enforcement agencies and debt collection agencies, may access, use and search these records to:
      1. help make decisions about credit and credit related services, for you and members of your household;
      2. help make decisions on motor, household, credit, life and other insurance proposals and insurance claims, for you and members of your household;
      3. trace debtors, recover debt, prevent fraud, and to manage your accounts or insurance policies;
      4. 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;
        • Checking details on proposals and claims for all types of insurance; and
        • Checking details of job applicants and employees.
    • The main Credit Reference Agency that we use is Experian Ltd, who can be contacted via their Consumer Help Service, PO Box 8000, Nottingham NG80 7WF. You may contact them on 0844 481 8000 or visit their website at www.experian.co.uk.
    • We may also use Dunn & Bradstreet, WorldCheck and Veriphy from time to time.
    • Dunn & Bradstreet can be contacted via their Customer Services Helpline on 0845 145 1700 or on their website at www.dnb.com/dnbi-solutions
    • WorldCheck can be contacted at Reuters Limited, 30 South Colonnade, Canary Wharf, London, E14 5EP or via their website at https://risk.thomsonreuters.com/en/support.html.
    • Veriphy can be contacted on 0191 281 2227 or via their website at http://veriphy.com
    • Please contact us at support@fitzroviafinance.com if you want to receive details of the relevant fraud prevention agencies.
  4. When might we disclose your personal data?
    • We will not disclose your personal data to any third party, except as explained in Clause 3.2 and the table at the end of this Privacy Policy.
    • Generally, however, if substantially all of our assets are acquired by a third party, personal data held by us will be one of the transferred assets and may be disclosed to the prospective seller or buyer of such business or assets under the same conditions as this Privacy Policy which is necessary for the purposes of the legitimate interests pursued by us and the third party, and would not be overridden by your interests or fundamental rights and freedoms which require protection of personal data.
  5. Our use of cookies and web beacons
    • 5.1 Cookies are text files stored, either on a temporary or persistent basis on the browser or hard drive of your computer when you visit a website. Cookies are used for authenticating, session tracking and maintaining specific information about the use and users of the Service. In general, there are four different types of cookies, which are used on the website:
      • Necessary cookies: those required for the operation of the Service, which do not gather information about you that could be used for marketing or remembering where you have been on the internet.
      • Analytical/performance cookies: these allow us to collect information about how you use the Service, such as, how you move around our website and if you experience any errors. These cookies do not collect personal data. The information collected is anonymous and is only used to help us improve the way the Service works, understand what interests our users generally and measure how effective our advertising is. Some of the performance cookies we use are issued as part of services provided by third parties, like Google Analytics.
      • Functionality cookies: these are used to provide services or to recognise you when you return to our website. These would enable us to personalise our content for you, greet you by name and remember your preferences and improve your visit.
      • Targeting cookies: these record your visit to the Service, the pages you have visited and the links you have followed. They are set by and linked to services provided by third parties, such as "Like" and "Share" buttons. The third party provides these services in return for recognising that you have visited our website. The third party may subsequently use information about your visit to target advertising to you on other websites and present you with advertisements that you may be interested in.
    • 5.2 The data collected by cookies is anonymous. We use cookies in order to ensure our Service functions correctly and to improve our understanding of how you use the Service in order to make improvements. Cookies cannot harm your computer. You can delete all cookies that are already on your computer's hard drive by searching for files with "cookie" in it and deleting them. In addition, if you want to stop cookies from being stored on your computer or browser, you can edit your browser settings so that cookies are blocked. Unfortunately, if you block cookies you may not be able to use the full functionality of the Service.
    • 5.3 We can also collect information about Service usage from data contained in “log files” from third parties. Log files are not cookies; they do not contain any personal data; and they are not used to identify your personal use of the Service. When you request any web page from the Service, web servers automatically obtain your domain name and IP address, but they reveal nothing personal about you and that data is only used to examine Service traffic in aggregate, to investigate abuse of the Service and its users, and/or to cooperate with law enforcement. Such data is not disseminated to third parties, except in aggregate.
    • 5.4 Web beacons consist of a small string of software code that represents a graphic image request on a page or email. There may or may not be a visible graphic image associated with the web beacon and often the image is designed to blend into the background of a page or email. Web beacons can be used for many purposes - including site traffic reporting, unique visitor counts, advertising auditing and reporting, and personalization. Web beacons used by www.fitzroviafinance.com collect only anonymous data.
    • 5.5 If you register with us or if you continue to use the Service, you agree to our use of cookies.
  6. Where and for how long we store your personal data
    • 6.1 All information you provide to us is stored on our secure servers, which are located in the EEA.
    • 6.2 We take the security of your personal data very seriously. In particular, we use all reasonable endeavours to ensure that appropriate technical and organisational measures are in place to protect your personal data from unauthorised or unlawful processing and against accidental loss, destruction or damage. Unfortunately, the transmission of information via the internet is not completely secure and so we cannot guarantee the security of your data transmitted between you and the Service; any such transmission is at your own risk.
    • 6.3 Your personal data will be stored for the duration of the Service Terms and for such time thereafter as required by Applicable Law or the limitation period for bringing contractual claims (in effect, six years from the date of termination of the Service Terms).
  7. Your rights
    • The table in Annex B at the end of this Privacy Policy explains the rights which the Act gives you and any exceptions to those rights:
      • Right of access
      • Right to rectification
      • Right to erasure
      • Right to request the restriction of processing concerning you
      • Right to data portability
      • Right to object to processing
      • Right to ask us not to process your personal data for direct marketing purposes
      • Right not to be subject to automated individual decision-making, including profiling.
    • Please note that this Privacy Policy provides the confirmation referred to in relation to the Right of Access.
    • You may exercise these rights (subject to any applicable exceptions) by emailing us at support@fitzroviafinance.com.
  8. Changes to our privacy policy
    • We reserve the right to amend this 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.
  9. Regulatory and Contact details
    • Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to support@fitzroviafinance.com.
    • Fitzrovia Finance Ltd is registered with the Information Commissioner’s Office (“ICO”) with registered number ZA198150.
    • Fitzrovia Finance Security Ltd is registered with the ICO with registered number ZA372303.
    • For more information about data protection and the protection of personal data, please visit the ICO website at: www.ico.org.uk.
  10. Complaints
    • You can complain to the ICO if you consider there has been a breach of the Data Protection Legislation in connection with your personal data.
  11. General
    • This Privacy Policy shall be governed by and construed in accordance with English law and the parties agree that the courts of England shall have exclusive jurisdiction to decide any dispute arising under it.

Annex A

Personal Data Collected Purpose Basis for processing
If you decide to register as a User of the Service, you will be asked to complete a form which will require you to provide your name, address and email address
  • to manage and administer the Service;
  • to enable you to use the Service;
  • to deal with enquiries, complaints and feedback from you;
  • to send you contractual notices;
  • to keep you informed about the progress and performance of your Loan Contracts and/or activity relating to Security Documents
  • to send you newsletters and other relevant and targeted promotional communications (with your consent);
To disclose to third parties for:
  • To instruct the Payment Service Provider to make payments to and from you as required under the Service Terms, Loan Contract(s) and/or Security Document(s);
  • To comply with a current judicial proceeding, a court order or legal process served on us or our Service, any request by the FCA or any other regulator who may have jurisdiction over us from time to time or for audit purposes and to meet obligations to any relevant regulatory authority or taxing authority;
  • To enforce this Privacy Policy, the Service Terms, Loan Contract(s) or Security Document(s);
  • to a credit reference agency to check your identity and to prevent fraud, (it will also keep a record of your request and use it whenever anyone applies to be authenticated in your name);
  • to tell credit reference agencies that you have an account and how you run that account on an ongoing basis;
  • to agents and subcontractors, acting for either us or a Lender, to use for the purpose of operating the Service and obtaining the payment of any amount owed by you or a related Borrower;
  • to organisations providing a centralised application matching service which they collect from and about mortgage and/or credit applications, for the purpose of preventing and detecting fraud;
  • to debt collectors and other third parties to trace you and recover any debt;
  • processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract;
  • processing is necessary for compliance with a legal obligation to which we are subject;
  • processing is necessary for the purposes of the legitimate interests pursued by us or a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data.
Information about your computer, mobile device or other item of hardware through which you access the Service and your visits to and use of the Service (including without limitation your IP address, geographical location, browser/platform type and version, Internet Service Provider, operating system, referral source/exit pages, length of visit, page views, website navigation and search terms that you use)
  • to improve your browsing experience by personalising the Service;
  • to analyse and improve the features offered on the Service.
  • To ensure that content on the Service is presented in the most effective manner for you and for your computer;
To disclose to third parties for:
  • To comply with a current judicial proceeding, a court order or legal process served on us or our Service, any request by the FCA or any other regulator who may have jurisdiction over us from time to time or for audit purposes and to meet obligations to any relevant regulatory authority or taxing authority;
  • To enforce this Privacy Policy, the Service Terms, Loan Contract(s) or Security Document(s);
  • processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract;
  • processing is necessary for the purposes of the legitimate interests pursued by us or a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data.
Information relating to your previous browsing habits on the Service
  • to deal with enquiries, complaints and feedback from you;
  • to analyse and improve the features offered on the Service.
To disclose to third parties for:
  • To comply with a current judicial proceeding, a court order or legal process served on us or our Service, any request by the FCA or any other regulator who may have jurisdiction over us from time to time or for audit purposes and to meet obligations to any relevant regulatory authority or taxing authority;
  • To enforce this Privacy Policy, the Service Terms, Loan Contract(s) or Security Document(s);
  • processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract;
  • processing is necessary for compliance with a legal obligation to which we are subject;
  • processing is necessary for the purposes of the legitimate interests pursued by us or a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data.
Information that you provide by filling in forms on the Service Website. This includes information provided at the time of registering to use the Service, posting material or requesting further services. We may also ask you for information when you report a problem with the Service.
  • To instruct the Payment Service Provider to make payments to and from you as required under the Service Terms, Loan Contract(s) and/or Security Document(s);
  • to deal with enquiries, complaints and feedback from you;
To disclose to third parties for:
  • To instruct the Payment Service Provider to make payments to and from you as required under the Service Terms, Loan Contract(s) and/or Security Document(s);
  • To comply with a current judicial proceeding, a court order or legal process served on us or our Service, any request by the FCA or any other regulator who may have jurisdiction over us from time to time or for audit purposes and to meet obligations to any relevant regulatory authority or taxing authority;
  • To enforce this Privacy Policy, the Service Terms, Loan Contract(s) or Security Document(s);
  • processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract;
  • processing is necessary for compliance with a legal obligation to which we are subject;
  • processing is necessary for the purposes of the legitimate interests pursued by us or a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data.
Copies of passports or other identification evidence
  • To identify, prevent, detect or tackle fraud, money laundering and other crime;
  • To carry out checks required by applicable regulation or regulatory guidance;
To disclose to third parties for:
  • To the Payment Service Provider to contract for its services in connection with the making of payments to and from you as required under the Service Terms, Loan Contract(s) and/or Security Document(s);
  • To comply with a current judicial proceeding, a court order or legal process served on us or our Service, any request by the FCA or any other regulator who may have jurisdiction over us from time to time or for audit purposes and to meet obligations to any relevant regulatory authority or taxing authority;
  • To enforce this Privacy Policy, the Service Terms, Loan Contract(s) or Security Document(s);
  • to a credit reference agency to check your identity and to prevent fraud, (it will also keep a record of your request and use it whenever anyone applies to be authenticated in your name);
  • to organisations providing a centralised application matching service which they collect from and about mortgage and/or credit applications, for the purpose of preventing and detecting fraud;
  • processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract;
  • processing is necessary for compliance with a legal obligation to which we are subject;
  • processing is necessary for the purposes of the legitimate interests pursued by us or a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data.
If you access the Service through a social networking profile, we may collect, store and use the details of that social networking profile or feed.
  • to populate any forms you might wish to complete on the Service
To disclose to third parties for:
  • To comply with a current judicial proceeding, a court order or legal process served on us or our Service, any request by the FCA or any other regulator who may have jurisdiction over us from time to time or for audit purposes and to meet obligations to any relevant regulatory authority or taxing authority;
  • To enforce this Privacy Policy, the Service Terms, Loan Contract(s) or Security Document(s);
  • processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract;
  • processing is necessary for the purposes of the legitimate interests pursued by us or a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data.
Correspondence between you and us
  • to manage and administer the Service;
  • to enable you to use the Service;
  • to deal with enquiries, complaints and feedback from you;
To disclose to third parties for:
  • To comply with a current judicial proceeding, a court order or legal process served on us or our Service, any request by the FCA or any other regulator who may have jurisdiction over us from time to time or for audit purposes and to meet obligations to any relevant regulatory authority or taxing authority;
  • To enforce this Privacy Policy, the Service Terms, Loan Contract(s) or Security Document(s);
  • To instruct the Payment Service Provider to make payments to and from you as required under the Service Terms, Loan Contract(s) and/or Security Document(s);
  • processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract;
  • processing is necessary for compliance with a legal obligation to which we are subject;
  • processing is necessary for the purposes of the legitimate interests pursued by us or a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data.
Credit checks to assess the creditworthiness of any Borrower or the counterparty to any Security Document
  • to manage and administer the Service;
  • to enable you to use the Service;
  • To assess lending and insurance risks, including creditworthiness and affordability
To disclose to third parties for:
  • To comply with a current judicial proceeding, a court order or legal process served on us or our Service, any request by the FCA or any other regulator who may have jurisdiction over us from time to time or for audit purposes and to meet obligations to any relevant regulatory authority or taxing authority;
  • To enforce this Privacy Policy, the Service Terms, Loan Contract(s) or Security Document(s);
  • to a credit reference agency to check your identity and to prevent fraud, (it will also keep a record of your request and use it whenever anyone applies to be authenticated in your name);
  • processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract;
  • processing is necessary for compliance with a legal obligation to which we are subject;
  • processing is necessary for the purposes of the legitimate interests pursued by us or a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data.
Details of transactions you carry out through the Service
  • to manage and administer the Service;
  • to enable you to use the Service;
  • to provide regulators and third parties with statistical anonymised information about the Service;
  • For statistical analysis;
  • To develop and improve the Service;
To disclose to third parties for:
  • To instruct the Payment Service Provider to make payments to and from you as required under the Service Terms, Loan Contract(s) and/or Security Document(s);
  • To comply with a current judicial proceeding, a court order or legal process served on us or our Service, any request by the FCA or any other regulator who may have jurisdiction over us from time to time or for audit purposes and to meet obligations to any relevant regulatory authority or taxing authority;
  • To enforce this Privacy Policy, the Service Terms, Loan Contract(s) or Security Document(s);
  • to a credit reference agency to check your identity and to prevent fraud, (it will also keep a record of your request and use it whenever anyone applies to be authenticated in your name);
  • to tell credit reference agencies that you have an account and how you run that account on an ongoing basis;
  • to agents and subcontractors, acting for either us or a Lender, to use for the purpose of operating the Service and obtaining the payment of any amount owed by you or a related Borrower;
  • to organisations providing a centralised application matching service which they collect from and about mortgage and/or credit applications, for the purpose of preventing and detecting fraud;
  • to debt collectors and other third parties to trace you and recover any debt;
  • processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract;
  • processing is necessary for compliance with a legal obligation to which we are subject;
  • processing is necessary for the purposes of the legitimate interests pursued by us or a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data.
Records of any telephone, email or other communication with you
  • to check any instructions given to us, for training purposes, for the detection and prevention of money laundering and fraud;
  • to improve the quality of our customer service.
To disclose to third parties for:
  • To instruct the Payment Service Provider to make payments to and from you as required under the Service Terms, Loan Contract(s) and/or Security Document(s);
  • To comply with a current judicial proceeding, a court order or legal process served on us or our Service, any request by the FCA or any other regulator who may have jurisdiction over us from time to time or for audit purposes and to meet obligations to any relevant regulatory authority or taxing authority;
  • To enforce this Privacy Policy, the Service Terms, Loan Contract(s) or Security Document(s);
  • to debt collectors and other third parties to trace you and recover any debt;
  • processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract;
  • processing is necessary for compliance with a legal obligation to which we are subject;
  • processing is necessary for the purposes of the legitimate interests pursued by us or a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data.
Information about your physical or mental health or condition (where necessary and appropriate to comply with regulatory requirements relating to customers with such conditions)
  • to manage and administer the Service;
  • to enable you to use the Service;
  • to negotiate alternative repayment plans and/or exercise forbearance, where appropriate, when attempting to recover monies owed;
To disclose to third parties for:
  • To instruct the Payment Service Provider to make payments to and from you as required under the Service Terms, Loan Contract(s) and/or Security Document(s);
  • To comply with a current judicial proceeding, a court order or legal process served on us or our Service, any request by the FCA or any other regulator who may have jurisdiction over us from time to time or for audit purposes and to meet obligations to any relevant regulatory authority or taxing authority;
  • To enforce this Privacy Policy, the Service Terms, Loan Contract(s) or Security Document(s);
  • to agents and subcontractors, acting for either us or a Lender, to use for the purpose of operating the Service and obtaining the payment of any amount owed by you or a related Borrower;
  • to debt collectors and other third parties to trace you and recover any debt;
  • processing is necessary for the establishment, exercise or defence of legal claims;
  • An exemption under the Act also applies to records of our intentions in relation to any negotiations with you to the extent that the provisions would be likely to prejudice those negotiations

Annex B

Rights Exception
Right of Access: 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: (a) the purposes of the processing; (b) the categories of personal data concerned; (c) the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations; (d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period; (e) the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing; (f) the right to lodge a complaint with a supervisory authority; (g) where the personal data are not collected from the data subject, any available information as to their source; (h) the existence of automated decision-making, including profiling, referred to in Article 22(1) of the GDPR and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
Right to rectification: to obtain from us without undue delay the rectification of inaccurate personal data concerning you.
We must communication to each recipient to whom the rectified personal data have been disclosed, unless this proves impossible or involves disproportionate effort.
We shall inform the data subject about those recipients if the data subject requests it.
Right to erasure: to obtain from us the erasure of personal data concerning you without undue delay where:
  1. the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
  2. you object to the processing based on legitimate interest where there are no overriding legitimate grounds for the processing;
  3. the personal data have been unlawfully processed;
  4. the personal data have to be erased for compliance with a legal obligation to which we are subject.
We must communication to each recipient to whom the erased personal data have been disclosed, unless this proves impossible or involves disproportionate effort.
We shall inform the data subject about those recipients if the data subject requests it.
Processing is necessary for
  1. compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in us; or
  2. the establishment, exercise or defence of legal claims.
Right to request the restriction of processing concerning you: to obtain from us restriction of processing where:
  1. the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of the personal data;
  2. the processing is unlawful and you oppose the erasure of the personal data and request the restriction of its use instead;
  3. we no longer need the personal data for the purposes of the processing, but it is required by you for the establishment, exercise or defence of legal claims;
  4. you object to the processing based on legitimate interest pending the verification whether our legitimate grounds override yours.
We must communication to each recipient to whom the restricted personal data have been disclosed, unless this proves impossible or involves disproportionate effort.
We shall inform the data subject about those recipients if the data subject requests it.
Where processing has been restricted under this right, such personal data shall, with the exception of storage, only be processed:
  1. with your consent; or
  2. for the establishment, exercise or defence of legal claims; or
  3. for the protection of the rights of another natural or legal person; or
  4. for reasons of important public interest of the Union or of a Member State.
The right to data portability: to receive the personal data concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from us, where:
  1. the processing is based on consent or is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract; and
  2. the processing is carried out by automated means.
You have the right to have the personal data transmitted directly from us to another controller, where technically feasible.
The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to the right to erasure.
That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.
The right to object to processing: to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on processing necessary for the purposes of the legitimate interests pursued by us or a third party (except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data), including profiling. Where:
  1. we demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject; or
  2. for the establishment, exercise or defence of legal claims.
The right to ask us not to process your personal data for direct marketing purposes: to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
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 support@fitzroviafinance.com
The right not to be subject to automated individual decision-making, including profiling: to not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. If the decision:
  1. is necessary for entering into, or performance of, a contract between you and us;
  2. is authorised by Union or Member State law to which we are subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests; or
  3. is based on the data subject's explicit consent.
In the cases referred to in points (a) and (c) we shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on our part, to express his or her point of view and to contest the decision.

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