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Privacy Policy

Our Firm Information

By ‘We’ or ‘Us’, we mean ‘Owen Froebel Ltd’ Trading Name: By “You” we mean the customer or individual who has accessed our service. we are Registered in England and Wales. Registered Address: Owen Froebel, Suite 4, Bloxam Court, Corporation Street, Rugby, Warwickshire CV21 2DU.

Owen Froebel Ltd’ is registered with the Information Commissioner’s Office, Registration Number: 13971855

Our Contact Information:

Telephone: 02476 013929

Email: hello@owenfroebel.co.uk

Mail: Owen Froebel, Suite 4, Bloxam Court, Corporation Street, Rugby, Warwickshire CV21 2DU

Purpose of this policy

This Privacy Policy sets out how ‘We’, ‘Owen Froebel Ltd’, uses and protects any information that the ‘You’, the user, provides to ‘Us’,  throughout this website and our service.

Where ‘Owen Froebel Ltd’ ask the User, ‘You’, to provide certain information by which the User, ‘You’ can be identified (i.e. Personal Data) after submitting this information, then this information shall only be used in accordance with this Privacy Policy.

information we collect from you

We may collect personal information from you when accessing our service and in order to provide you with our services. We have summarised the categories of data we collect from you, below:

Identity Data: First name, last name, maiden name, marital status, date of birth, a copy of your passport, your National Insurance number, outcome of DBS checks where appropriate

Employment Data: Employment status, time employed, CV, Job references, Job criteria, professional qualification certificates and confirmation of training and CPD courses.

Contact Data: Current address, previous addresses and post codes, email address and telephone number, a CRM log of our communications.

Technical Data: Internet Protocol (IP) address, browser type and version, timer zone setting and location, browser plug-in types and versions, operating systems and platform and other technology on devices you use to access the website

Profile Data: Your preferences, feedback and survey responses.

Usage Data: Information about how you use our website, products and services.

Marketing and Communications Data: This includes your preferences in receiving marketing from us and any third parties, as well as your communication preferences.

Financial Data: Salary Information, Mortgage/Rent costs

Do we collect Special Categories of Personal Data?

We may be required to process and store special category data in the form ‘Health Data’ where any ‘customer vulnerability’ has been identified. We will only record this information where you provided explicit consent for us to do so.

We do not collect information pertaining to criminal convictions and offences; however, it is important to note criminal convictions or offences do not constitute Special Categories of Personal Data.

How do we collect information from you?

We have different methods of collecting data from and about you, including via:

Direct Interactions:

You may provide us with your Identity, contact and financial data by completing online forms or by corresponding directly with us via post, phone, email or otherwise. This includes personal data you provide when you:

Engage our products and services;

Provide us with feedback; or

Request marketing to be sent to you

Automated Technologies or interactions

As you interact with our website, we may automatically collect Technical Data about your equipment, browsing patterns and actions. This will be collated after acceptance of ‘cookie’ and other similar technologies. Please refer to our Cookies Policy for further information.

Third Parties or publicly available sources

Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register, Regulator Registers and Social Media.

Technical data from Analytics Providers

Purposes and lawful bases for processing personal data

Purpose for Processing

Type of Data

Lawful Basis for Processing

Registration as a new Customer

Contact Information

Identity Information

For the Performance of a contract

Special Category (Health)

Explicit Consent

Process application for finance arrangements

Contact Information

Identity Information

Financial information

Employment Information

For the performance of our services

 

Special Category (Health)

Explicit Consent

Marketing

Contact Information

Consent

Recipients of personal data

In providing our services, we may need to disclose your personal information to third parties where we have a legal obligation to do so, or in order to adequately provide our service.

Third Party

Purpose

Basis

Our partnered Lender(s)

Broking for Finance Arrangements

For the Performance of a Contract

 

We may need to disclose your information to any one of the following:

  1. HM Revenue & Customs, the Financial Conduct Authority, The Information Commissioner’s Office, other Regulators and other authorities acting as processors based in the United Kingdom who require reporting of processing activities in certain circumstances.
  2. Accountants, Solicitors, Compliance Consultants and other like-services acting as processors based in the United Kingdom who require the reporting of processing activities in certain legal and compliance circumstances.
  3. Alternatively, we may seek to acquire other businesses or merge with them. If a change in these circumstances occurs, your personal data will be used in the same way as set out within this privacy policy.

International transfers

We do not transfer personal data outside the United Kingdom or European Economic Area (EEA)

Data security

We are committed to ensuring your information is safe and secure. In order to prevent unauthorised access or disclosure, we have implemented and maintained suitable physical, electronic and managerial procedures to safeguard and secure the information collected online. We aim for our customers to be completely confident in using our services, therefore we regularly review our processes and procedures to protect your personal information from unauthorised access, use, accidental loss, destruction or disclosure.

Data retention

How long will we hold your personal data?

We will only retain your personal data for as long as is necessary to fulfil our obligations under the provision of our service as well as any purposes necessary to satisfy any legal, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk, of harm of unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, including applicable legal requirements.

Details of retention periods for different aspects of your personal data are available upon request. By law we have to keep certain information about our customers and this data will be held solely and securely for those legal purposes.

Your legal rights

You have the following ‘Rights’ available to you regarding the processing of your personal data. Not all rights are absolute.

Your Right to Access

 

the right of access, commonly referred to as subject access, gives individuals the right to obtain a copy of their personal data as well as other supplementary information. it helps you to understand how and why we are using your data, and to check we are using it lawfully.

your right to Rectification

 

you have the right to have inaccurate personal data rectified. you may also be able to have incomplete personal data completed – although this will depend on the purposes for the processing. this may involve providing a supplementary statement to the incomplete data.

Your Right to Erasure

 

under certain circumstances you have the have the right to have personal data erased. also known as ‘the right to be forgotten’. the right is not absolute.

Your Right to Restrict Processing

 

under certain circumstances you have the right to request the restriction or suppression of your personal data, and as like the right to erasure, it is not absolute. restriction of processing means we are permitted to store your personal data; we are unable to use it.

Your Right to Data Portability

 

you have the right to obtain and reuse your personal data for your own purposes across different services. this eases the copying or transferring of personal data easily from one it environment to another, safely and security, without affecting the usability of the data.

Your Right to Object

 

under certain circumstances you have the right to object to the processing of your personal data, however you do have the absolute right to object to direct marketing.

Your Right to Be Informed

 

you have the right to be informed about the collection and use of your personal data. your right to be informed forms part of this policy, and provides the purposes for processing your data, our retention periods and who it will be shared with.

The right to withdraw consent

If you have given us consent to process your personal data you have a right to withdraw that consent at any time, including but not limited to the removal of consent to be contacted for marketing purposes. You can request this using the following contact details:

Our Contact Information:

Telephone: 02476 013929

Email: hello@owenfroebel.co.uk

The right to complain to the information commissioner’s office

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. Please see our Complaint Policy. https://www.owenfroebel.co.uk/complaints

This website includes links to third-party websites. Clicking on these links or enabling these connections may allow third parties to collect or share data about you. We do not control these third-party websites and are thus not liable nor responsible for their privacy statements or data usage. We encourage navigation to any third-party websites Privacy Policy to ensure understanding of how your data is affected.

Cookies

We only use cookies that are strictly necessary to the functioning of the website. Without these cookies, our website will not function properly. We are not required to obtain consent from you for these cookies alone

For more information on our use of Cookies, please see our Cookie Policy

Subject access requests

You have the right of access to your personal information. Also known as a Subject Access Request (SAR). This means you are entitled to obtain the following information about yourself:

Confirmation that we are processing their personal data;

A copy of their personal data; and

Other supplementary information;

A third party may make a request on your behalf. This will often involve a solicitor acting on your behalf. We will require evidence from the third party as to evidence this entitlement. This may take the form of a written authority or be a more general power of attorney.

How do we provide you with the data you have requested?

If you make a request electronically (via electronic means), we will provide the information in a commonly used electronic format unless you have specified otherwise. Please note, we may extend the time to respond by a further two months if the request is complex or you have made multiple requests. As you have the right to be informed, we will always ensure you are notified within one month of receiving the request, accompanied by an explanation.

How Long do we have to comply with a request?

We must act on your subject access request without undue delay and at the latest within one month of receipt. This is calculated as beginning from the day following receipt of the request until the corresponding calendar data the following month. We may request your identity to satisfy the request, however this will be proportionate to the request itself and if we have doubts of the authenticity of identification.

Will it cost you anything?

For the vast majority of requests, we cannot charge you a fee. Where the request is manifestly unfounded or excessive, we may charge a reasonable fee to cover the administrative costs of complying with the request. This also applies in the event that you request further additional copies of data following your initial request. This will again be charged as an administrative cost.

Updates to this Policy

We may make changes to this privacy policy from time to time. You should check this page regularly to see our most up to date policy. We will tell you about any changes to this privacy policy by showing the date of the changes in the “Last updated” section above.

The information about you we may collect, hold and process is set out below.

(1) Below is the Information that we hold and collect that will be processed for finding you a suitable role:

Your full name

Your full address

Your email address (s)

Your telephone number (s)

CV/work history

Job References

Job criteria including role, location areas and salary

All other work related information, for example, education or training certificates

(2) We may also hold further personal Information in respect to individuals that have worked for us previously or may work for us is as follows:

Medical Information where necessary

Your National insurance number

Copy of Passport Information

Job References

Date of Birth

The Full details of job offers and placements

The Outcome of CRB checks and security clearance sometimes required for certain roles.

Sometimes Financial information (including payroll details and terms, pensions schemes, court orders and stat payments, HMRC data)

A CRM log of our communications by telephone and emails.

 

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