This privacy notice lets you know what happens to any personal data that you give to us, or any that we may collect from you or about you. It applies to all our products and services, and any instances where we collect your personal data.
GetplanD Limited is a company registered in England and Wales (registration number 12144298), whose business address is at, TOG, 20 Eastbourne Terrace, London, United Kingdom, W2 6LG. GetplanD Limited is an Appointed Representative of Enterprise Investment Partners LLP who is authorised and regulated by the Financial Conduct Authority with firm reference number: 12901503.
For the purposes of the General Data Protection Regulation (‘GDPR’), GetPlanD Limited (“planD”) is the data controller under the Regulation, which means that we determine the purposes and means of processing personal data. We are registered with the Information Commissioner’s Office with registration number: ZB038268.
Future changes to this privacy notice
We may change this privacy notice occasionally to reflect changes in the law, as well as our privacy practices. While we encourage you to check this notice on our website regularly, we will notify you should any substantial change take place.
Data Protection Officer (DPO)
The Data Protection Officer is Rufus Pearl. You can contact Rufus using the contact details provided above or by sending him an email: firstname.lastname@example.org
What personal information about you do we process?
Personal information that we will process in connection with our products and services includes:
- Personal contact details (e.g., title, full name, current address, and address history)
- Records of your contact with us (including telephone number, e-mail address and IP address)
- Products and services that you hold with us, as well as products and services you have been interested in
- Information about your employment status
- Information about your source of income and source of wealth (to comply with anti-money laundering requirements)
- Payment related information, such as sort code and bank account number and credit or debit card information (to comply with anti-money laundering requirements)
Technical data about how you interact with our services
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. Nor do we collect any information about criminal convictions and offences.
Where does your personal information come from?
We will collect personal information from the following sources:
- From you directly, and any information from family members, associates or beneficiaries of products and services
- Information generated about you when you use our products and services
- From third parties who are seeking to make introductions
- From other sources such as Fraud Prevention Agencies, Credit Reference Agencies, other lenders, HMRC, DWP (Department for Work and Pensions), publicly available directories and information (for example, telephone directory, social media, internet, news articles), debt recovery and/or tracing agents, other organisations to assist in prevention and detection of crime, police, and law enforcement agencies
What do we use your personal data for?
We use your personal data for the following purposes:
- To improve the operation of our business and that of our business partners
- To follow guidance and best practice under the change to rules of governmental and regulatory bodies
- To monitor and to keep records of our communications with you and our staff
- To administer our good governance requirements such as internal reporting and compliance obligations or administration required
- For market research and analysis and developing statistics
- For direct marketing communications
- To comply with legal and regulatory obligations, requirements, and guidance
What are the legal grounds for our processing of your personal information, and when can we share it with others?
We rely on the following legal basis to use your personal data:
Where it is in our legitimate interests to do so, such as:
- To follow guidance and recommended best practice of government and regulatory bodies
- To carry out monitoring and to keep records of our communications with you and our staff
- For market research and analysis and developing statistics
- For direct marketing communications
- Where we need to share your personal information with people or organisations to run our business or comply with any legal and/or regulatory obligations
- Where we have a reasonable business case to do so
To comply with our legal obligations
- We are an authorised representative, and as such may be required to process data to comply with the FCA’s rules. This may mean that we are unable to erase your data in certain circumstances, if to do so would result in a breach of the FCA’s record keeping requirements.
With your consent or explicit consent:
- For some direct marketing communications
When do we share your personal information with other organisations?
We may share information with the following third parties for the purposes listed above:
- Business partners (for example, other entities operating with or affiliated with planD.)
- Persons or businesses to whom we may buy from or sell to or otherwise transact in relation to the whole or part of the business or its assets.
- Organisations to whom we are under a lawful duty to provide your personal data.
- Third party data processors. The following is a list of our major service providers:
- Google Analytics
How and when can you withdraw your consent?
Where we rely upon your consent to process your personal data, you can withdraw this at any time by contacting the Data Protection Officer (details above).
Is your personal information transferred outside the UK or the European Economic Area?
planD is based in the UK, but sometimes your personal information may be transferred outside the European Economic Area. If we do so, we will make sure that suitable safeguards are in place, for example by using approved contractual agreements, unless certain exceptions apply.
How do we share your information with Fraud Prevention Agencies?
We do not share your information with Fraud Prevention Agencies.
What should you do if your personal information changes?
You should tell us as soon as possible so that we can update our records. You can do so via the ‘contact us’ section of our website.
Do you have to provide your personal information to us?
You do not have to provide your personal information to us should you not wish to. However, we are unable to provide you with our products or services if you do not provide certain information to us. In cases where providing some personal information is optional, we will make this clear.
Do we do any monitoring involving processing of your personal information?
In this section monitoring means any: listening to, recording of, viewing of, intercepting of, or taking and keeping records (as the case may be) of calls, email, text messages, social media messages, in person (face to face) meetings and other communications.
We may monitor where permitted by law and we will do this where the law requires it, or to comply with regulatory rules, to prevent or detect crime, in the interests of protecting the security of our communications systems and procedures and for quality control and staff training purposes. This information may be shared for the purposes described above.
How long do we retain your personal information?
Unless we explain otherwise to you, we will hold your personal information based on the following criteria:
- For as long as we have reasonable business needs, such as managing our relationship with you and managing our operations
- Retention periods in line with legal and regulatory requirements or guidance, in conjunction with FCA (Financial Conduct Authority) rules.
What are your rights under data protection legislation?
Here is a list of the rights that all individuals have under data protection laws. They do not apply in all circumstances. If you wish to use any of them, we will explain at that time if they are engaged or not. The right of data portability is only relevant from May 2018.
- The right to be informed about the processing of your personal information
- The right to have your personal information corrected if it is inaccurate and to have incomplete personal information completed
- The right to object to processing of your personal information
- The right to restrict processing of your personal information
- The right to have your personal information erased (the “right to be forgotten”)
- The right to request access to your personal information and to obtain information about how we process it
- The right to move, copy or transfer your personal information (“data portability”)
- Rights in relation to automated decision making which has a legal effect or otherwise significantly affects you
You have the right to complain to the Information Commissioner’s Office which enforces data protection laws: https://ico.org.uk/.
Your right to object
You have the right to object to certain purposes for processing, to data processed for direct marketing purposes and to data processed for certain reasons based on our legitimate interests. You can contact us by going to the Contact Us section of our website to exercise these rights.
What are your marketing preferences and what do they mean?
We may use your home address, phone numbers, email address and social media or digital channels (for example, Facebook, Google, and message facilities in other platforms) to contact you according to your marketing preferences. You can stop our marketing at any time by contacting us using the details below or by following the instructions in the communication.
How can you contact us?
If you have any questions about this privacy notice, or if you wish to exercise your rights or contact our DPO, you can contact us via the methods listed above in the ‘Data Protection Officer’ section.
All individuals have the right to lodge a complaint with the Information Commissioner’s Office (ICO) if they have concerns about how we handle information. Any concerns can be reported via the ICO’s website https://ico.org.uk/concerns/ or over the telephone, by calling 0303 123 1113.