Ten Forward Finance Limited understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits our website, https://www.tenforwardfinance.co.uk/ (“Our Site”), or engages in a contract for services with Us, and we will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
Who we are?
We are Ten Forward Finance Limited, a limited company registered in England under company number 04254970, of Balfour House, 741 High Road, London N12 0BP. Our VAT number is 911 7736 25. We are regulated by the ICO, and we are a member of ICPA.
What is personal data?
Personal Data means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”).
What information do we collect?
We collect your personal data in the following circumstances:
- You use our site (www.tenforwardfinance.co.uk) see our cookie notice for more info.
- We provide you with a quote or services.
- You complete a Contact Us form
- You contact the office by phone/email
- You send a message via Linkedin, Twitter, Facebook, Instagram or other social media.
- You sign up to our mailing list for newsletters/eBooks/guides.
- You download a resource from our website.
- You sign up for our App
We may collect some of the following information:
Name, contact details ie. Email or phone number, date of birth, gender, business/company name, job title, proof of identity, proof of address, profession, demographic information, financial information, IP address, web browser type and version, operating system, entry point to Our Site.
How do we use personal information?
We use anonymised data collected from the website to improve your services and our Site, we can also ensure we are delivering the best content to you (see cookie notice). To provide goods and/or services, and meet statutory obligations regarding your accounting and financial needs. We communicate with you regarding marketing (if opted in), events, new services you may be interested in, and research or surveys to improve your experience. If you post information for publication on our website or through our services ("publication data"), we may process this information for the purposes of enabling such publication and administering our website and services.
What legal basis do we have for processing your personal data?
Our data is collected under 3 main lawful basis; Contract (Article 6, 1b), Legal Obligation(Article 6, 1c) and Consent (Article 6, 1b).
If you choose to enter into a Contract with Us, or request a Quote from Us, we will need certain amounts of data to comply with that request. We have legal obligations under The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 to verify your identity and report to the governing bodies any suspicious activity. We have Consent checkboxes on the website if you would like to sign up for our mailing lists, and we will request your consent before we share your details with third party organisations.
You can withdraw your consent at any time by contacting us and letting us know. If you are subscribed to Marketing emails and would like to withdraw, please unsubscribe via the button on the email.
When do we share personal data?
We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our holding company and its subsidiaries) when necessary for the purposes, and on the legal bases, set out in this policy. We will only share your personal data to external third parties with your consent; for example, to introduce you to a mortgage broker, independent financial advisor or another professional, and we will ensure that the data is transmitted in a safe way.
We will share data when necessary to provide services, for example with HMRC and Companies House to provide you with Limited Company Accounts or a Self-Assessment Tax Return. Where necessary we may also pass your details to our insurers for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or to exercise or defend legal claims.
We may be legally obliged to share your data, for example: A financial institution relies on the legal obligation imposed by the Part 7 of Proceeds of Crime Act 2002 to process personal data in order submit a Suspicious Activity Report to the National Crime Agency when it knows or suspects that a person is engaged in, or attempting, money laundering.
If we sell all or part of our business, we may pass your personal data to the purchaser. In these circumstances, we will require the purchaser to contact you after completion of the sale to inform you of the identity of the purchaser.
Where do we store and process personal data?
The majority of information we hold is stored locally on UK based servers and UK based cloud backups. We have information held by Microsoft in the US however this is covered by the EU-US Privacy Shield. We use several cloud based services which are hosted by Amazon Web Services in the US; and if you use Dropbox with us, this is also covered by the Privacy Shield. Before we engage with a third party who may hold data on our behalf we review the safety of that information and the location in which it is held.
How do we secure personal data?
We have strict internal IT and security policies and proceudres for all information coming into and leaving our domain, as well as the methods of sharing information. Any information transferred to us via the internet has its risks, and we do not encourage information sent via email or over unsecured networks.
How long do we keep your personal data for?
We only hold data for as long as necessary or as long as we are legally and contractually obligated to hold it. Generally, information will be removed once one of the following conditions is met:
- We are no longer providing services or contractually obligated to hold information
- For certain documents, their legal timeframe has passed (ie. Financial documents need to be held for 7 years).
- You request information to be deleted.
Hard copies of information are destroyed in a secure shredding facility, e copies will be removed from our system and servers. If we hold any subscriptions on your behalf (ie. Xero) the subscription will be transferred to you and it’s your responsibility to remove our access once this has been completed.
Your rights in relation to personal data
We respect the right of you as a data subject to access and control your personal data. You have the following rights under GDPR:
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to data portability
- The right to object
- Rights in relation to automated decision making and profiling.
You may exercise your rights by contacting us on the below details. Depending on your request we may need to verify your identity before we can take action. If for any reason we are unable to fulfil your request we will explain the reasons why.
Use of automated decision-making and profiling
We do not use any automated decision-making processes; however, we do use profiling internally to categorise your business into a sector/group for our own purposes. As an example, we group or tag all our Self Assessment Clients on our CRM system ensure they are all sent their reminder emails on time.
Linking to other websites / third party content
We may occasionally link to external sites/resources/references. We do not take any responsibility for the content(or information contained within the links) once you leave Our Site.
How to contact us?
If you have any questions or concerns about our privacy notice, or any information here please get in touch with us via one of the below methods.
Contact us page: LINK
Write: Data Protection Officer, Ten Forward Finance Ltd, Balfour House, 741 High Road, London, N12 0BP
If you feel we have not met our obligations you have the right to lodge a complaint with our supervisory authority as per article 13.2(d).