PremFina

Privacy and Cookies Policy

Last Updated: July 2015

PremFina recognises the importance of the honest and responsible use of your personal information. This Privacy and Cookies Policy (“Policy”) describes how and for what purposes PremFina Ltd (“PremFina”, “we”, “us” and/or “our”) collects and processes personal information about you when you either (i) visit our Website www.premfina.com (the “Website”); (ii) enter into agreements with us; and/or (iii) contact us, either in relation to the Website or an agreement or generally, using the contact options detailed within this Policy or on the Website.

The Website is controlled by PremFina and PremFina will be the data controller of any personal data it collects pursuant to this Policy. If you have any questions regarding this Policy, PremFina may be contacted via the following e-mail address: info@premfina.com

Any references to “Group” in this Policy are to PremFina, its parent company IXL Holdings Limited and any of its subsidiaries.

  1. What type of personal data does PremFina collect and process?
    1. When you enter into a agreement for credit or other services (the " Service"), we may collect the following personal data from you:
      1. your name;
      2. your contact details, including postal address, telephone number and e-mail address;
      3. your date of birth;
      4. a copy of your signature;
      5. your country of residence;
      6. employment and residential status (including time at current address);
      7. bank account details (including usage data); and/or
      8. any other information necessary for regulatory compliance.
    2. Where you use the Website, we may collect the following personal data from you:
      1. your name and contact details, including postal address, telephone number and e-mail address;
      2. your IP address; and/or
      3. any other information necessary for regulatory compliance.
    3. Where you contact us, either through the Website or via email, letter or phone, we may collect the following personal data from you:
      1. your name and contact details, including postal address, telephone number and e-mail address;
      2. the reason for your contact; and/or
      3. any other information necessary for regulatory compliance.
    4. This information will be collected primarily from you but we may also collect it, where lawful to do so, from and combine it with information which we may already hold about you (for example, if you have obtained products and/or services from PremFina or have had previous contact with PremFina) or have obtained from credit reference agencies (a “CRA”), public sources, third party service providers, government, tax and/or law enforcement agencies, and other third parties.

  2. How does PremFina use your personal data?
    1. When you enter into an agreement or credit arrangement with us, we may use information about you:
      1. to perform any contract PremFina has with you;
      2. to provide us with information in order to improve our products and services and develop new products and services;
      3. where in compliance with applicable laws or regulatory rules, to conduct credit reference checks or to obtain details of credit history or other information from CRAs, to ascertain risks;
      4. where necessary for compliance with applicable laws or regulatory rules or otherwise with your consent, to check your information with fraud prevention agencies;
      5. for internal record keeping, including but not limited to details regarding products and/or services by PremFina to you, and to assist with customer complaints;
      6. for compliance with legal, regulatory and other good governance obligations;
      7. to contact you (directly, either by PremFina or through a relevant partner or agent) by e-mail for the above reasons;
      8. to provide you with information regarding the Service and to notify you of changes to the Services, or to provide you with information in relation to other products or services offered by PremFina (with your consent, where required);
      9. to share your details with our trusted partners who may use it to provide you with information related to their products and services (with your consent, where required);
      10. to anonymise data in order to perform or undertake analysis and/or research of our products and services, including using broad demographic data based on your country of residence; and/or
      11. for any other purposes related to the management of your legal relationship with PremFina.
      12. Please note that this list may be updated from time to time as PremFina’s business needs and legal requirements dictate.

    2. When you use the Website, we may use information about you:
      1. to improve the functionality of the Website
      2. to administer the Website; and
      3. for anonymised analytical purposes, including to collecting demographic data based on the location of IP addresses.
    3. When you contact us, we may use information about you to respond to and/or deal with your request or enquiry.
    4. In addition to the above, we may also use your personal data:
      1. as part of any restructuring or sale of PremFina or any relevant part of its business or assets;
      2. for other legitimate business purposes including but not limited to management analysis, audit, forecasts, business planning and transactions, ensuring our compliance with applicable laws, regulatory requirements and PremFina policies, and dealing with legal claims and related administrative activities and related records retention; and/or
      3. to establish or exercise our legal rights and to comply with law enforcement or other government agency requests or court orders.
  3. Does PremFina share personal data with third parties?
    1. Your personal data will be disclosed as necessary for the purposes mentioned above (or as otherwise notified to you from time to time and where there is a lawful reason to do so), within PremFina and to other members of its Group, and also with our third party service providers, First Capital Cash Flow Ltd (for processing direct debit collections) (and any other service providers we may appoint from time to time) and as otherwise detailed in this Policy.
    2. We may also disclose specific information on reasonable request by government authorities, law enforcement and regulatory authorities where required or permitted by law and/or for tax or other purposes. Personal data may also be disclosed to external parties in response to legal process, and when required to comply with laws, or to enforce our agreements, corporate policies, and/or terms of use or supply, or to protect the rights, property or safety of PremFina.
    3. In addition, we may disclose your personal data to prospective or actual buyers in the event that PremFina or any part of the Group sells all or any of its business or assets.
    4. By providing your information to PremFina pursuant to this Policy, the provision of your information will also act as your consent to the transfer of your personal data as set out in this Policy.
  4. Will your personal data be transferred abroad?
    1. All personal data processed pursuant to this Policy will be held and processed within the European Economic Area (“EEA”) and PremFina does not transfer any personal data it obtains in relation to the Website or the Service to any jurisdiction outside the EEA unless it is lawfully permitted to do so.
  5. What are your marketing rights?
    1. Where we have you consent or it is lawful to do so:
      1. we (or members of our Group) may provide you with direct marketing communications about our own or their products and services which may be of interest to you; or
      2. we may share your personal information with our trusted partners so that they can provide details of their products and services,
      and such information may be sent by post or by e-mail, telephone or SMS.
    2. If you receive marketing materials from us, a member of our Group or one of our partners, you may unsubscribe at any time by following the instructions contained within the relevant e-mail, letter or other form of correspondence. You may also opt-out from receiving any other marketing or promotional communications that we (or a member of our Group) may send to you from time to time, by sending your request by e-mail to us at OptOut@PremFina.com. If you wish to opt-out from receiving marketing materials from any of our trusted partners, please contact the relevant business directly.
    3. Please be aware that if you opt-out of receiving marketing communications from us (or a member of our Group), we will process your opt-out request as soon as possible but in the meantime you may continue to receive marketing communications from us (or a member of our Group, as applicable). In such cases we would not necessarily remove all your personal information from our databases but would note and respect your changed direct marketing preferences. Additionally, even after you opt-out from receiving marketing communications from us, you may continue to receive administrative messages from us regarding our Services, as part of our provision of the Services.

  6. What safeguards are in place to protect your personal data?
    1. Subject to paragraph 6.2 (below), PremFina takes steps to seek to protect the security of your personal data in accordance with applicable law.
    2. As for all Website operations, we cannot guarantee the security of any transmission of personal data over the Internet. Communications over the Internet such as e-mails are not secure unless they have been encrypted. So, while we strive to protect such information, we cannot ensure or warrant the security of any information transmitted to us.  Please do not submit personal data through the Website unless you accept the inherent security risks and implications of using the Internet.

  7. What rights do you have to review, amend and or delete personal data?
    1. You have the right to request certain information about the processing of your personal data. These rights vary depending on the country you are based in, but generally include (amongst others) the right to request copies of, access, and, in certain circumstances under applicable laws, oppose the processing of your personal data and/or request the deletion of your personal data held by PremFina and to have certain inaccurate information about you corrected.
    2. If you believe that any information we have about you is incorrect or incomplete, please write to or e-mail us as soon as possible. We will take steps to seek to correct or update any information as necessary and in accordance with applicable law and pursuant to our checks on whether that information is in need of correction or update.
    3. All requests to amend, update, delete, access or to obtain copies of your personal data will be processed in accordance with applicable law.
    4. Where the processing of your personal data is done with your consent or you have directly/indirectly opted-in to receiving marketing materials, please note you have the right to withdraw your consent or opt-out at any time. If you wish to withdraw your consent or opt-out, please contact us at: OptOut@PremFina.com
  8. Keeping you informed and record retention
    1. We may occasionally update this Policy. When we do, we will post the updated Policy and revise the “last updated” date at the beginning of the Policy. If we change this Policy in a manner that materially alters your rights or obligations under this Policy, we will use reasonable efforts to notify you of the change. For example, we may send a message to your email address, if we have one on file, or generate a pop-up or similar notification when you access the Website for the first time after such material changes are made. We encourage you to periodically review this Policy to stay informed about how we collect, use, and disclose your personal information.
    2. PremFina may keep your details on record for as long as is necessary for the purposes for which it may use your personal data, as set out above and as allowed in accordance with applicable law.
  9. Cookies
    1. We use “cookies” for certain areas of our Website. Cookies are small data files stored on your hard drive by a Website. Cookies help us monitor and improve the functionality and usage of our Website and your experience of the Website.  We use cookies to [see which areas and features are popular and to count visits to our Websites, to recognise you as a returning visitor and/or to tailor your experience of the Website according to your preferences.
    2. To delete or block cookies on the Website, you can do this through your browser settings at any time and for more general information about cookies including the difference between session and persistent cookies, visit allaboutcookies.org.
    3. The cookies used on our Website may be categorised, as follows
      1. Cookies which are “strictly necessary” for functionality of the Website’s platforms. These cookies are essential in order to enable users to move around the Website and use its features;
      2. Functionality” cookies which allow the Website to remember choices you make and your preferences;
      3. Performance/Analytical” cookies which collect information about how users navigate the Website; for example, which pages users access most frequently. They identify how users interact with our Website, any errors that occur, which pages are not used often, which pages take a long time to load, which pages users tend to visit and in what order. These cookies do not collect any information which could identify you and are only used to help us improve how our Website works and understand what interests our Website’s users.
    4. A summary of the first party and third party cookies which we use on our Website are set out below:
    5. Cookie name/type

      Expiration Period

      Purpose

      Category of cookie as defined in the International Chamber of Commerce UK Cookie Guide

      Identification cookie

      Session

      This enables us to remember who you are across each of the pages you visit and, where appropriate, what information you may have entered on a previous page.

      Functionality

      Google Analytic

      Session

      Allows us to monitor site usage, including the number of visitors to the site and pages visited.

      Analytical

      Cookie Acceptance

      Persistent

      This enables us to track when you’ve accepted the use of cookies on the Website

      Functionality

  10. Your consent to our use of Cookies
    1. We may need to ask for your consent to the use of certain cookies set out in this Policy when you access the Website. Accordingly, when you first visit the Website, a box/banner will appear which advises you of the use of cookies on the Website and advises you that by continuing to use the Website, you consent to the setting of cookies which are used on the Website which are summarised above. The box/banner will also advise that you may oppose the use of cookies and refer you to you browser settings.
    2. You can usually set your browser to warn you when a cookie is being sent or to remove or reject cookies. Each browser is different, so look at your browser ‘Help’ menu to learn the correct way to modify your cookie settings.  If you choose to remove or reject cookies, it may affect features or services on our Website.
    3. If you agree to cookies from our Website by continuing to use the Website, and you later wish to delete the cookies we have set on your device, please refer to your browser ‘Help’ menu.
  11. Contact us
  12. If you have any questions about this Policy, please contact us at info@premfina.com