Privacy Policy

For details of our firm and how to contact us please refer to our website footer.

Your Personal and Sensitive Personal Data—What Is It?

Personal Data relates to a living individual who can be identified from that data; sensitive personal data covers specific information such as health details, origins and opinions. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. The processing of Personal Data is governed by
the General Data Protection Regulation 2016/679 (the “GDPR”) and the Data Protection Act 2018.

Who are we?

Paul Lloyd Williams is the Data Controller (“we,” “us”). This means they decide how your personal data is processed and for what purposes. 

How do we process your personal data?

We comply with our obligations under the GDPR by keeping personal and sensitive data up to date; sensitive personal data covers specific information such as health details, origins and opinions by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure; and by ensuring that appropriate technical measures are in place to protect your data.

We use your Personal and Sensitive Data for the following purpose:

1. To provide our advice and implementation service in respect of financial products, such as mortgages, life assurance, pensions, and investments. 

2. To keep in contact with our clients about products and services which we believe may be of value to them.

What is the legal basis for processing your personal data?

We will collect and record your personal data from a variety of sources, but mainly directly from you. You will usually provide information during the course of our initial meetings or conversations with you to establish your circumstances and needs and preferences in relation to your financial affairs. You will provide information to us verbally and in writing, including email.

We may also obtain some information from third parties, for example, credit checks, information from your employer, and searches of information in the public domain such as the voters roll. If we use technology solutions to assist in the collection of your personal data, for example, software that is able to verify your credit status. We will only do this if we have consent from you for us or our nominated processor to access your information in this manner. With regard to electronic ID checks, we would not require your consent but will inform you of how such software operates and the purpose for which it is used.

What happens to your personal data?

Article 6 Processing

• Consent of the Data Subject, where we are marketing to the public.
• Processing is necessary for the performance of a contract with the Data Subject or to take steps to enter into a contract, where we have been engaged to provide financial services.

Article 9 Processing

• Explicit consent of the data subject, where we wish to tell people about events, news, and services.

• Processing is necessary for the establishment, exercise, or defence of legal claims or where courts are acting in their judicial capacity.

Sharing Your Personal Data

Your personal and sensitive data will be treated as strictly confidential and will be shared only with Julian Harris Networks and providers of financial service products, third-party data storage providers, and legal or regulatory authorities if obliged to do so.

We keep your Personal and Sensitive Data for no longer than reasonably necessary and we only retain your data for servicing the financial services provided where agreed and in case of any legal claims and for regulatory purposes 

Your rights in relation to Your Personal Data

Unless subject to an exemption under the GDPR, you have the following rights with respect to your Personal Data:

– The right to request a copy of your personal and sensitive data that we hold about you.
– The right to request that we correct any personal or sensitive data if it is found to be inaccurate or out of date.
– The right to request your personal and sensitive data be erased where it is no longer necessary for us to retain such data.
– The right to withdraw your consent to the processing at any time.
– The right to request that the Data Controller provide the Data Subject with his/her Personal Data and, where possible, to transmit that data directly to another Data Controller.
– The right, where there is a dispute in relation to the accuracy or processing of your Personal Data, to request a restriction is placed on further processing.
– The right to object to the processing of personal data.
– The right to lodge a complaint with the Information Commissioner’s Office.

Further Processing 

If we wish to use your Personal and Sensitive Data for a new purpose, not covered by this Data Protection Notice, then we will provide you with a new notice explaining this new use prior to
commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.

Cybercrime Warning 

Please be aware that there is a significant risk posed by cyber fraud, specifically affecting emails enclosing bank account details. If you receive an email from Commodore Finance Ltd requesting or providing bank details, please contact your adviser immediately for clarification. All payment requests should be verbally validated. 

How to contact our Firm in relation to the use of Your Personal Data

If you have any questions or comments about this document or wish to make contact in order to exercise any of your rights set out within it, please contact our firm via the contact details within this website and ask for the person responsible for data protection.

If we feel we have a legal right not to deal with your request or to action, it in different way to how you have requested, we will inform you of this at the time.

You should also contact us as soon as possible upon your becoming aware of any unauthorised disclosure of your personal data so that we may investigate and fulfill our own regulatory obligations.

If you have any concerns or complaints as to how we have handled your personal data, you may lodge a complaint with the UK’s data protection regulator, the ICO, who can be contacted through their website at https://ico.org.uk/global/contact-us/ or by writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

Want to know more?

Call us for a friendly chat on 01745 850653 or email: paul@commodorefinance.co.uk