HOW WE USE YOUR PERSONAL DATA
Our Privacy Promise
Armadale Capital promises you:
- To keep your data protected and private
- Not to sell your data to any third parties
- To give you control on managing and reviewing your marketing choices at any time
PERSONAL INFORMATION AND THE LAW
Who we are
Armadale Capital Plc is the legal name of the company who holds your personal information, known as the ‘legal entity’.
How the law protects you
Data Protection law states that Armadale Capital can use personal information when we have a proper reason to do so. These reasons are listed below:
- To fulfil any contract that we have with you
- For any legal duty that Armadale Capital has
- When it is in our legitimate interest, or
- When you have provided Armadale Capital consent
Armadale Capital may use your personal information for business or commercial reasons, otherwise known as legitimate interest. As a business we will only rely on legitimate interest when it is necessary, even when we do we will let you know what it is. However, we will make sure that it is not unfair against your own interests.
Sensitive personal data is referred to in law and other regulations as special data. This information includes; racial or ethnic origin, sexual orientation, political opinions, trade union membership, genetic data, health data, sexual orientation and criminal records. Armadale Capital will not collect this data from you unless you provide explicit consent or the law allows us to. Armadale Capital will only collect this data under law if it relates to:
- For reasons that are of substantial public interest, or
- To establish, exercise or defend legal claims
Where we collect personal data from
We may collect data about you or your business from the following sources:
- Your application form when you apply for one of Armadale Capital’s products or services
- Use of our website, mobile device apps, web chat or contact requests forms
- When you speak with us over the phone, included recorded calls or notes which are made
How long we keep your personal information
Armadale Capital will retain your personal information for as long as you are a customer. Once you have stopped being a customer we may keep your data for up to 10 years from that point. The reasons that Armadale Capital may keep your data are:
- To follow all rules that apply to Armadale Capital for keeping records
- To respond to a question or complaint raised, or to show whether you were given fair treatment by Armadale Capital
There may be some instances in which Armadale Capital will have to keep your data for longer than 10 years. This may be a result of being unable to delete it for legal, regulatory or technical reasons.
Armadale Capital will only use this retained data for the purposes outline above and will ensure that your personal information is protected.
If you choose not to give personal information
Armadale Capital may need to collect personal information by law, to enter into or fulfil a contract which we have with you. You can choose not to give us your personal information, however this will have the following effects:
- Armadale Capital may be prevented from fulfilling our contract with you or there may be delays in us fulfilling this contract
- There may be delays or prevention in Armadale Capital being able to do what is necessary by law
- It may result in Armadale Capital not being able to run your accounts or Armadale Capital may need to cancel any products or services you have
As we are defined as a ‘transactional site’ under the EU Privacy & Electronic Communications Directive, we will be unable to offer you online account services if you remove the cookies from your device, as you will be unable to use the sit securely.
THE CONTROL YOU HAVE
This section outlines your rights under law and regulation when it comes to your personal information.
The right to be informed – Armadale Capital have an obligation to provide ‘fair processing information’ typically through a privacy notice.
The right of access – customers are entitled to access copies of their personal information held by Armadale Capital. Please see section titled How to get a copy of your personal information, for further details.
The right to erasure – this allows you to delete, remove or stop using your personal information if there is no reason or need for us to keep it.
The right to ratification – all individuals have the right to have their data rectified if it is incorrect or incomplete. Please see section How to let us know if your personal information is correct, for further details.
The right to restrict processing – you are able to restrict the use of your data, this means that VS can only use it for certain things such as legal claims or to exercise legal rights.
The right to data portability – you can obtain and reuse your personal data for your own purposes.
The right to object – you can object to us keeping or using your personal information.
The right to opt-out – you have the right to opt out of receiving email marketing communications from us at any time by contacting us using the contact details set out below; or using the “unsubscribe” link in emails.
If you wish to object to how we use your data, or delete the data we have or restrict how we use it please contact us at email@example.com or call us on +44 20 7236 1177 – lines are open Monday – Friday 8am to 6pm. Please note that all our calls are recorded and may be monitored.
How to complain
This section gives you information on how to contact us to make a complaint about data privacy. It also explains how you can get in touch with the relevant government regulator.
If you are unhappy with how we have used your personal information, please let us know. You can contact us at firstname.lastname@example.org or call us on +44 20 7236 1177 – lines are open Monday – Friday 8am to 6pm. Please note that all our calls are recorded and may be monitored.
As a customer you also have the right to complain to the regulator, and if you are not happy with your outcome of an complaint regarding private information you can lodge an appeal. The Information Commissioner’s Office is the regulatory body in the UK, you can find out on their website how to report a concern.
How to withdraw your consent
You can withdraw your consent if you no longer want us to hold or use your personal information at any time. Please contact email@example.com if you want to do so.
By withdrawing consent this will only affect the information we use on the basis of consent. Please see further information about restricting the use of the information under ‘Your Rights’.
Please note that by withdrawing your consent, we will not be able to tell you about our products, services or various offers that may benefit you. We will of course, continue to inform you of any important changes to the terns under which your account is operated.
How to let us know if your personal information is correct
Please let us know if you believe that the information which we have on record for you is incorrect, incomplete or out of date.
As an Armadale Capital customer it is your right to question any of the information which we have about you and that you think is incorrect.
If you want to do this please contact us on firstname.lastname@example.org or call us on +44 20 7236 1177 – lines are open Monday – Friday 8am to 6pm. Please note that all our calls are recorded and may be monitored.
How to get a copy of your personal information
You are entitled, to a copy of all information and details we hold about you with no cost. If you wish to request all personal information you can do so by writing to us at:
Armadale Capital Plc
1 Arbrook Lane, Esher, Surrey, KT10 9EG
Now under regulation you have the right to get a copy of personal information as a digital file, so you can keep it for your own personal use or provide it to another organisation if you choose to. If you want to do this, please contact us on email@example.com or call us on +44 20 7236 1177 – lines are open Monday – Friday 8am to 6pm. Please note that all our calls are recorded and may be monitored.
HOW PERSONAL INFORMATION IS USED
Who we share your personal information with
We may share your personal information with outside organisations such as authorities, third parties which allow us to provide our products and services. This is so we can run our business and obey the rules that apply to us.
The list of authorities which may supply your personal information to are:
- Central and local Government
- UK Financial Services and Compensation Scheme
- Law enforcement and fraud prevention agencies
- Financial Conduct Authority
Financial services which are outside companies we may work with to provide services to you and to run our business include agents, suppliers, sub-contractors and advisors – these are type of firms that we use to help us run accounts, policies and services
Sending date outside the EEA
Armadale Capital may only send your data outside of the European Economic Area (EEA) to:
- Follow your instructions
- Comply with a legal duty
- Work with our suppliers who help us run your accounts and services
If we do transfer your personal information outside the EE to our suppliers, we will make sure that it is protected to the same extent as in the EEA. We’ll use one of these safeguards:
- Transfer it to a non-EEA country with privacy laws that give the same protection as the EEA. Learn more on the European Commission Justice website.
- Put in place a contract with the recipient that means they must protect it to the same standards as the EEA. Read more about this here on the European Commission Justice website,
- Transfer it to organisations that are part of Privacy Shield. This is a framework that sets privacy standards for data sent between the US and EU countries. It makes sure those standards are similar to what is used within the EEA. You can find out more about data protection on the European Commission Justice website.