We take your privacy seriously and treat all the personal data you give us with great care.
Who is the controller of your data?
What personal data do we process?
We process personal data about you that you give to us when you contact us, register as an introducer or as a client, ask to receive information, submit a new case to us or enquire about finance. When you visit our website we also automatically receive your IP address which is a unique identifier for your computer or other device you are using to access our site.
Visitors to our website
When someone visits www.firstmerchant.co.uk we collect standard internet log information and details of visitor behaviour patterns in order to provide the best experience we can for users and keep the site up to date and relevant. We will not associate any data gathered from this site with any personal data from any source.
We collect information from or about the computers, phones, or other devices where you access our websites. We may associate the information we collect from your different devices, which helps us provide a consistent user experience.
How do we use your data?
Personal data collected and processed by us may be used for the following key purposes:
- Administration of loan accounts
- Administration of introducer database
- Responding to enquiries
- Research and statistical analysis
- Communication about new products and other news
- Invitations to Seminars and other events
Personal data provided to us will be used for the purposes outlined at the time of collection or registration in accordance with the preferences you express.
We process your data for marketing purposes to ensure that we are contacting you with the most appropriate communication, which is relevant and timely and will ultimately provide you with an improved experience. In doing so, we may use profiling techniques using publicly available data or information that you have already provided to us. This helps us to make appropriate requests to donors who may have the means and the desire to give more. Importantly, it enables us to raise more funds in a cost-effective way.
You can opt out of your data being used in this way at any time by contacting us on email firstname.lastname@example.org, call 020 7935 4146, or write to First Merchant Finance Plc, 36 Seymour Street, Marylebone, London W1H 7JF.
Receiving marketing information from First Merchant Finance Plc will always be your choice. You can change your mind at any time and we will keep your preferences up to date. You can contact us on email email@example.com, call 020 7935 4146, or write to First Merchant Finance Plc, 36 Seymour Street, Marylebone, London W1H 7JF at any time to be removed from our lists.
We do not make unsolicited phone calls and would only telephone you if we had a specific query.
Where does your personal data come from?
Most of the data we process about you comes from you, for example, information you provide to us online. Some information comes from third parties such as our partners.
Other information is gathered during your use of our website (e.g. IP addresses or information obtained via cookies).
Do you have to provide your personal data?
In most cases, providing your personal data to us is optional, however, in some circumstances if you do not provide it, we will probably not be able to fulfil processes, keep you up to date with news or events or our website may not work properly for you. For example: you can turn off cookies on your browser and we will not place any cookies on your device or computer. However, this is likely to mean that you may not be able to use all parts of our website.
What are the legal grounds for processing your personal data?
Data protection laws require us to tell you what legal basis we use for processing your personal data. These bases are set out in the applicable data protection law. We generally use the following:
- the processing is necessary to perform a contract with you (i.e. the contract for the sale and purchase of your subscription or event tickets), or to take steps requested by you before entering into this contract;
- the processing is in First Merchant’s or someone else’s legitimate interests, and these interests are not overridden by your interests or rights in the protection of your personal data;
- the processing is necessary to meet a legal obligation which applies to First Merchant;
- you have consented to our processing of your personal data. If you have consented, you can withdraw your consent at any time by contacting us here.
Who do we share your personal data with?
Personal data collected and processed by us may be shared in the following situations:
- With First Merchant Finance Plc employees and partners;
- With contractors, agents and other third parties who provide services to us.
We will hold your personal information on our systems for as long as is necessary for the relevant activity for which your data was originally obtained. For example we will keep a record of donations for at least seven years.
If you request that we stop sending you marketing materials we will keep a record of your contact details and appropriate information to enable us to comply with your request not to be contacted by us.
Security and performance
First Merchant Finance Plc uses a third party service to help maintain the security and performance of the website and we may share information with this third party where necessary.
What are your rights?
You have several rights in relation to your personal data. These include accessing your data, correcting any mistakes, having your data erased, restricting the processing of your data, objecting to the processing of your data, data portability, and rights relating to automated decision making and profiling. In most cases there are conditions attached to these rights. Please see below for further information on each of these.
Accessing your data
You can ask us to:
- Confirm whether we are processing your personal data;
- Give you a copy of that data;
You do not have to pay a fee for a copy of your information unless your request is unfounded, respective or excessive, in which case we will charge a reasonable amount in the circumstances. We will let you know of any charges before completing your request.
We aim to respond to you within 1 month of receiving your request unless it is particularly complicated or you have made several requests, in which case we aim to respond within 3 months. We will let you know if we are going to take longer than 1 month in dealing with your request. If we have a lot of information about you we might ask you if you can tell us what exactly you want to receive. This will help us action your request more quickly.
Correcting your data
You can ask us to correct any data which is inaccurate or incomplete. This is free of charge.
If we have shared the data with anyone else, we will tell them about the correction wherever possible. We aim to deal with requests for correction within 1 month, although it might take us up to 3 months if your request is particularly complicated.
If we can’t action a request to correct your data, we will let you know and explain why this is.
Erasing your data
This right is sometimes referred to as “the right to be forgotten”. This is not an absolute right but you have the right to have your data erased, free of charge, in certain circumstances.
You can ask for your data to be erased where:
- it is no longer necessary for the purpose for which it was originally collected or processed;
- we are processing your data based on your consent, and you withdraw that consent;
- you object to the processing and we do not have an overriding legitimate interest for continuing;
- your data has been unlawfully processed;
- your data must be erased to comply with a legal obligation;
There are some exceptions to this right. If one of these applies, we do not have to delete the data.
If we have shared your data with third parties, we will tell them about the erasure of your data unless this is impossible or would involve disproportionate effort.
Restricting the processing of your data
You can ask us to restrict the processing of your personal data in some circumstances, free of charge. This is not an absolute right. If processing is restricted we can store the data and retain enough information to make sure the restriction is respected, but we cannot further process your data.
You can restrict the processing of your personal data in the following cases:
- if you contest the accuracy of your data, we will restrict processing until we have made sure the data is accurate;
- if you object to our processing and we are considering this objection;
- if the processing is unlawful but you do not want us to erase your data;
- if we no longer need the personal data but you require the data to establish, exercise or defend a legal claim.
If we have disclosed the data to a third party, we will inform them about the restriction unless it is impossible or would require a disproportionate effort. We will tell you if we decide to lift a restriction on processing your data.
Objecting to the processing of your data
Objecting to the processing of your data is free of charge. It is not an absolute right but you can object to our processing of your data where it is:
- based on the legitimate interests ground; or
- for the purposes of scientific/historical research and statistics.
We will stop processing your personal data unless we have compelling legitimate grounds for the processing which override your interests and rights, or unless we are processing the data for the establishment, exercise or defence of legal claims.
You can require us to stop using your data for direct marketing purposes. We will stop as soon as we receive your request. There are no exemptions or reasons for us to refuse.
This allows you to obtain and reuse your personal data for your own purposes across different services. It applies where the following conditions are met:
- you provided the personal data to us yourself;
- we are processing the data either based on your consent or because it is necessary for the performance of a contract; and
- the processing is carried out by automated means.
We will provide your data free of charge in a structured, commonly used and machine readable form. We aim to provide your data within 1 month of receiving your request unless it is particularly complicated or you have made several requests, in which case we aim to respond within 3 months. If we are going to take longer than 1 month we will let you know and explain why we need more time. If we consider that we cannot provide you with your data, we will contact you and explain why this is.
Automated decision making and profiling
You have the right not to be subject to a decision which is based on automated processing and which produces a legal (or similarly significant) effect on you.
We will tell you about any automated decision making that affects you. You have the right to:
- request human intervention;
- express your point of view;
- ask for the decision to be explained; and
- challenge the decision.
These rights are not absolute. They do not apply if the decision is:
- necessary for us to enter into or perform a contract with you;
- authorised by law (e.g. for fraud prevention); or
- based on your explicit consent.
If your personal details change, please help us to keep your information up to date by notifying us. You can also request access to any information we hold about you at any time by:
- emailing firstname.lastname@example.org; or
- writing to the First Merchant Finance Plc, 36 Seymour Street, Marylebone, London W1H 7JF.
Contact and complaints
If you have any questions about this policy or about how we use your personal data please email email@example.com, call 020 7935 4146, or write to the First Merchant Finance Plc, 36 Seymour Street, Marylebone, London W1H 7JF.
If you are unhappy about how we are processing your data or how we have responded to a request or complaint, you have the right to make a complaint to the UK’s data protection regulator, the Information Commissioner’s Office (ICO). You can find more details about how to contact the ICO on their website https://ico.org.uk/.
Changes to this policy
We may change or update this policy from time to time so please check this page periodically.
This policy was last reviewed on 23 March 2018