“Secretcommission.claims” is a trading style of “Financial Claims Management Ltd”, FCM, (“We”) are committed to protecting and respecting your privacy.
If you have any questions about this policy or our treatment of your personal data, please contact us:
- by email at: firstname.lastname@example.org
- by post to: The Data Protection Officer, Secretcommission Claims, 49 Piccadilly, Manchester, M1 2AP
Our data protection registration number is ZA778696
THE DATA SUBJECT ‘YOU’
We may collect and process the following data about you:
- Information that you provide by filling in forms on our site www.secretcommission.cliams;
- Records of correspondence with you;
- We may also ask you to complete surveys that we use for research purposes and send you relevant marketing information;
- Details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data and the resources that you access;
- Calls made to or from us may be recorded for training purposes and to monitor customer service and regulatory compliance.
Why we require your data
When you provide your data to us, you consent for us to use your personal information to:
- Contact you about the Claim Services we offer via the contact methods you have provided, which could include telephone, text message (SMS), email and/or post;
- Administer our website, including ensuring that we can enable your use of the services on our website (including enquiries and complaints about our website) and improve your browsing experience by personalising the website
We will keep your contact details following an enquiry for a maximum period of six years.
All information you provide to us is stored on secure servers.
The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we use strict procedures and security features to try to prevent unauthorised access.
How we will process your data
During the provision of our services, you agree for us to process your personal information through signing our Letter of Authority which means you agree to our Terms of Engagement, to allow us to:
- Refer you to one of our legal partners;
- Provide you with updates (if relevant) via telephone, text message (SMS), email and post where such contact details have been provided;
Withdrawing your consent
You can withdraw your consent for us to contact you by telephone, text message (SMS), email and/or post at any time. You are able to withdraw consent verbally via telephone or in writing via email or post using the contact details at the beginning of this policy. Additionally, every email, letter and text message (SMS) we send to you will include a way to opt-out.
We have a Legitimate Interest in keeping customers updated about any further services offered by us which may be of interest to you, including communication of any developments that may have an impact on the original service you engaged with us about (e.g. a change in the law that will make additional services available to you) and/or similar products and services. In these instances we may also provide a referral to a solicitor within our legal panel with your consent, including our legal partner(s).
‘Legitimate Interest’ means the interests of our company in conducting and managing our business [to enable us to give you the best service/products and the best and most secure experience].
For example, we have an interest in making sure our marketing is relevant for you, so we may process your information to send you marketing that is tailored to your interests. It can also apply to processing that is in your interests as well.
When we process your personal information for our legitimate interests, we make sure to consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Should you no longer wish to receive information about similar products and services, you can always withdraw your consent to receive marketing communications from us and we will stop processing your data for marketing purposes. You are able to withdraw your consent verbally via telephone or in writing via email or post using the contact details found at the beginning of this policy.
RECIPIENTS OF YOUR DATA
We control the use of your data as you have directed. We do not sell your data to third parties in any circumstances.
To allow us to provide our services to you, the following third parties provide critical functions to our business and will process your personal information as directed by us and in accordance with strict data security arrangements:
- Our legal partners: Due to the complexity of the claims, we use a specific panel of legal partners that specialise in these types of claims. For the purposes of progressing your claim we will also provide a referral to a solicitor within our legal panel with your consent.
- Our Sign up Agents: We may use third party firms who provide essential sign up services.
- Our Regulators: We may be required to provide your data to our Regulators, who include the Financial Conduct Authority, the Financial Ombudsman Service and the Information Commissioner’s Office.
- Our Professional Services: We use professional legal, consultancy and accountancy services to help us fulfil our legal obligations and help us improve our business.
We have carefully selected our third parties due to their commitment to keeping your data safe. If you request for us to stop processing your data, we will also communicate this to the relevant third parties if they are processing this on our behalf. If you have any concerns about the above third parties, please let us know and we can provide advice and support to help you manage your data preferences.
YOUR DATA RIGHTS
As a data controller, if you request the rectification, erasure or restriction of your data, we will also communicate this to any third party who your data has been disclosed to.
In exercising any of your rights, we will take action within one month. However, should the request be complex we can extend this by a further two months. We will inform you of this in this event. We will need to confirm your identity before completing any action on your behalf, and reserve the right to not complete action until we are satisfied that you are making the request. If we cannot complete your request, we will inform you within one month and explain why.
You can access your data at any time by submitting a Subject Access Request (“SAR”). We will confirm what data is being processed and provide you with a copy of your data in addition to confirming your data rights. We will provide this free of charge. However, if you make repetitive requests, we will charge an administrative fee of £10.
You can make this request using reasonable means, including by telephone, post or email. If you make the request by email, we will provide your information in a commonly used electronic format unless you instruct us otherwise
If you wish to amend any inaccurate data that we hold, please notify us specifically by telephone, post or email, or during the course of the provision of our services. We will make the amendment as soon as possible. If any data held is incomplete, you can complete this at any time. We may require this to be completed to allow us to provide our Claims Services.
We can delete or “forget” your data when requested by you in the following circumstances:
- We no longer require your data (when we have finished providing any Claims Services requested by you and are no longer subject to any legal or Regulatory requirements, such as accounting requirements and complaints handling);
- You withdraw your consent and there is no other reason for us to hold your data;
- You object to the processing, as described below;
- You believe your data has been unlawfully processed; or
- There is a legal obligation to erase your data.
You can make this request using reasonable means including by telephone, post or email. If you request for your data to be deleted, we will confirm whether this can take place and the next steps that we will take. If we cannot delete your data, we will explain why and confirm any actions required to allow us to do so.
You can restrict us from processing your data in the following circumstances:
- You believe your data is inaccurate;
- You believe your data has been unlawfully processed but do not want us to delete your data;
- We no longer need your data but it is required by you for making or defending a legal claim; or
- You object to the processing, as described below, but we are verifying this.
If you make a restriction request, we will still store a copy of your data but cannot use this. We will inform you if the restriction needs to be lifted. You can make this request using reasonable means including by telephone, post or email. If you request for your data to be restricted, we will confirm whether this can take place and the next steps that we will take. If we cannot restrict your data, we will explain why and confirm any actions required to allow us to do so.
Object to data processing
You can object to the processing of your data at any time. If you object, we will no longer process your data unless we have a compelling and legitimate reason not to do so. In this case, you will be informed why we cannot stop processing your data.
You can always object to receiving marketing from us and we will stop processing your data for marketing purposes at any time.
You can request your data in a commonly used electronic format, and for us to transfer this to another entity or person, where we are processing your data with your consent or in accordance with a contract. This will only apply to information which is processed by automated means (e.g. by a computer). Where feasible, we will send your data directly to another entity or person.
We may be required to use your data due to a legal requirement which is placed upon us; this includes our regulatory requirements such as financial record keeping, staff training and monitoring, in addition to complaint handling. In these circumstances, we may be required to keep your data by law. We will always inform you if this is the case.
We may disclose information about you to any of our employees, officers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes as set out in this policy.
In addition, we may disclose information about you:
- to the extent that we are required to do so by law;
- in connection with any legal proceedings or prospective legal proceedings; and
- in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
If you would like to make a complaint in relation to the way we process your personal information, please email email@example.com.
We will endeavour to resolve any issues as soon as possible, however if we are unable to do so to your satisfaction, you can contact the Information Commissioner’s Office (ICO) (www.ico.org.uk, Tel: 0303 123 1113).