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Octane Capital Limited, Octane Property Finance Limited, Octane Property Finance 3 Limited, Octane Property Finance 4 Limited and affiliated companies (“Octane”) need to collect and use certain types of information about individuals who come into contact with Octane in order to carry on our work. The purpose of this policy is to ensure that Octane:
The General Data Protection Regulations (GDPR) are designed to protect individuals and their personal data, which is held and processed by others. The regulations cover:
(a) Direct from you or via your broker
When you access or browse this website (including when you submit personal information to us through data entry fields on the website), continue to use this website and through our application, verification or servicing processes, we may collect information from you, which may include the following personal information about you and or your client:
(i) your name;
(ii) your current and previous postal addresses;
(iii) your phone, fax and e-mail details;
(iv) your date of birth;
(v) your passwords and security question answers;
(vi) correspondence with us by email and post;
We may also collect:
(viii) financial information (including bank or building society account details and details of debit cards used in relation to our services);
(ix) sensitive information (such as any medical information you disclose to us (although we will always get specific permission from you before recording this type of information);
(ix) information you provide in our application processes (including, if you are a borrower, agent or investor, certain personal, identity, contact and financial information about directors, partners, members, shareholders, beneficial owners and guarantors);
(x) data about your activities using Octane, including information about your computer (for example, your IP address, operating system and browser type).
(b) From third parties
We may also obtain information about you from third parties including credit reference agencies, fraud prevention agencies, insolvency practitioners, debt advisers, tracing agents, commercial databases, marketing databases, public records and other publicly available information sources, including information about your business or company (e.g. previous credit applications, personal credit information, electoral register and fraud prevention information).
(c) From website visits
We may also collect IP address and details about visitors to the website for the purposes of aggregate statistics or reporting purposes and to calculate referral fees. We do this by use of cookies. We may also use this data to trace or deal with any malicious attack on or via our website or systems. You can read our cookie policy here: https://www.octanecapital.co.uk/cookies
If you give us false or inaccurate information and we suspect or identify fraud, we will record this and will pass details on to fraud prevention agencies.
This section of our Privacy Notice relates to Open Banking and should be read in conjunction with the other clauses in our Privacy Notice.In the event of conflict with any other clauses, this clause shall prevail.
What is Open Banking?
Open Banking is the secure way of providing access to your bank or building society account to providers who are registered for this purpose. Registered providers and participating banks and building societies are listed under the Open Banking Directory. Open Banking was set up by the UK Government to encourage more competition and innovation in the financial services sector. As a forward–thinking lender, we support the use of Open Banking as it allows us to process loan applications efficiently, securely and in our consumer’s best interests.
By permitting access to your bank or building society account information we are able to make a better lending decision as we shall be able to verify your income, outgoings and other matters in order to assess what loan terms would be suitable for you based upon what you can reasonably afford to repay.
Further information about Open Banking is available from www.openbanking.org.uk.
How will my personal data be shared and used for the purposes of Open Banking?
By proceeding with your loan application via our website you expressly consent to us sharing your personal, contact and loan application details (“the Shared Personal Data”) with our registered Open Banking partner, Perfect Data Solutions Limited (“PDS”) who are also a credit reference agency. During your loan application we shall safely and securely direct you to PDS’s secure portal (“the Portal”) for the purposes of granting PDS access to your bank or building society account information (“Transaction Information”). As soon as your Transaction Information is received it shall be reported back to us in the form of a completed search in order that we may continue to process your loan application (“the Permitted Purpose”).
Further information about PDS including their registered provider and regulatory status is available from www.lendingmetrics.com.
Is Open Banking secure?
PDS are registered under the Open Banking Directory as an account information service provider and are also regulated by the Financial Conduct Authority as a payment services firm under number 802599. Any data you submit via the Portal will be encrypted and its usage tracked as part of set Open Banking data security standards.
We are responsible for the secure transmission of any Shared Personal Data to PDS, for safely directing you to the Portal and for the safe receipt and usage of your Transaction Information.
You will not be required to share your banking password or log in details with either us or PDS. Once you have given your explicit consent to share your bank account information on the Portal you will be directed to your own bank or building society’s login page where you will enter in your own login details directly.
Save as set out above or elsewhere in this Privacy Notice, we are not responsible for your direct data transmissions with PDS or with your own bank or building society.
How will my Shared Personal Data and Transaction Information be used?
PDS shall, subject to their own terms and conditions and privacy policy, and, if your bank or building society is registered to provide access under the Open Banking Directory, obtain your Transaction Information and submit this back to us for the Permitted Purpose. By way of example, the Transaction Information that we shall receive is likely to include information relating to your income, outgoings and credit worthiness.
PDS shall be entitled to re-access your Transaction Information for up to 90 days from the date of your original search result in order to refresh the search results, obtain a snapshot of your data or gather additional data.
PDS shall hold the Shared Personal Data and the Transaction Information they receive and retain according to their own terms and conditions and privacy policy, available on the Portal, which you will be required to read and consent to once directed there via our website.
As PDS are also a credit reference agency they may also share and keep a record of your Shared Personal Data and Transaction Information.
Will you use my Transaction Information data for any other purpose?
The Transaction Information we receive about you will only be used for the Permitted Purpose. We do not sell or share Transaction Information with any third party.
Save as set out above the information contained in the rest of this Privacy Notice deals with how we collate, use, transfer, store, delete and other terms applicable to your personal data including Shared Personal Data and Transaction Information.
Do I have to provide you with my consent to proceed?
Where your bank or building society have already permitted access to your Transaction Information you shall need to contact them directly in order to withdraw your consent under their particular Open Banking terms and conditions.
Are any of my other rights under this Privacy Notice affected?
Your individual data protection and privacy rights including the right to access, correct, delete, object, restrict, withdraw consent, request transfer and/or make a complaint, continue to apply to relevant personal data we control or process and are dealt with elsewhere in this Privacy Notice.
Under Open Banking as your personal data is shared by your bank or building society and accessed by PDS you may also be able to exercise your individual data protection and privacy rights against either of them pursuant to their own terms and conditions and privacy policies.
We will use your information for:
Our legitimate interests to:
For legal purposes to:
You can find out details of how the credit reference agencies use your personal and business data here
Please contact us for details of fraud prevention agencies.
By consent
We may use your contact information to market to you when you have consented to receiving marketing material from Octane and associated companies either directly or via a marketing service about our products and services. We do not share or sell your information with unrelated third parties.
If you want to opt out of marketing you may use the unsubscribe box on any emails you may receive or write to the Managing Director of Octane Capital, 152 West End Lane, London NW6 1SD. Once this notice has been received Octane will comply with the request within a reasonable time. In normal circumstances electronic communications should stop within 28 days of receiving the notice, and postal communications should stop within two months.
Where you provide information about other people, e.g. information about directors, partners, members, shareholders or beneficial owners or occupiers other than yourself then you confirm that they are aware that you will be providing this information and that they have had a copy of this Privacy Notice, including how we may use such information.
We will retain information for our legitimate interests and legal purposes as follows:
Where you have consented to marketing, will retain your contact information for marketing purposes until such time as consent is withdrawn.
It may sometimes be necessary to transfer personal information overseas. In these circumstances, personal information will be transferred as follows:
You have the right to ask us to delete and/or correct data held by Octane if it is proven to be inaccurate, excessive or out of date. If an individual is concerned about the accuracy of the data Octane holds on them they should contact Octane via the website or write to the Managing Director of Octane Capital, 152 West End Lane, London NW6 1SD. Octane will consider whether the data is incorrect and if so if it should be corrected or deleted.
You are also able to exercise your right to be forgotten. This does not mean we will have to automatically delete all information held on you as we may still need to keep appropriate information in order to meet our legal obligations and for our legitimate interests.
All individuals who are the subject of personal data held by Octane are entitled to be:
If an individual or appropriately authorised person on their behalf contacts Octane requesting this information, this is called a data subject access request. Data subject access requests from individuals should made in writing to the Managing Director of Octane Capital, 152 West End Lane, London NW6 1SD.
We will provide the relevant data promptly and within 20 calendar days.
You have the right to complain about the way in which we process your data. If you wish to complain you may do so by writing to The Managing Director, 152 West End Lane, London NW6 1SD.
You also have the right to complain to the Information Commissioners Office. You can make a complaint to them via their website www.ico.org.uk or by calling them on 0303 123 1113.
This section of our Privacy Policy relates to Open Banking and should be read in conjunction with the other clauses in our Privacy Policy. In the event of conflict with any other clauses, this clause shall prevail.
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