Legal and Privacy Policy

This Privacy Notice sets out how we use and protect the information that you provide to us and the information that we obtain from other sources and generate ourselves.

Who we are

Central Trust is an independently owned specialist secured loan lender. The products and services featured are only available to residents of the United Kingdom aged over 18 and are subject to status. By accessing and using this website you are agreeing to the conditions set out in this Privacy Notice. Telephone calls are recorded for training and security purposes. Central Trust is a trading style of Central Trust Limited.

If users have questions regarding our policies please contact us by e–mailing enquiries@centraltrust.co.uk

Company details:

Central Trust Limited

Registered in England – 07020381
Registered Office – 25-27 Surrey Street, Norwich, Norfolk, NR1 3NX
VAT number – 765353512
Authorised and Regulated by the Financial Conduct Authority under number 739724

How we use your personal information

We will treat all your information as private and confidential (even when you are no longer a customer) in accordance with this privacy notice. Where your application has been introduced to us by a third party, for example a credit broker, we may disclose information concerning the progress of your application to them. We will store the information about you on computer and in other records and will take appropriate measures to keep your data secure. We will only use this information for the purposes registered under Data Protection law.

When we process your personal data we do so primarily with a view to entering into the loan contract or to fulfil a contract we have with you (or for the reasons set out below). Contact may be made with you by telephone (calls may be recorded for training, compliance and evidential purposes), post, email or SMS messaging to help service your account. We may do this ourselves or we may ask someone else to do it for us and we may pass information about you and your account to anyone who services your account and to anyone we ask to help us to enforce the loan agreement, this could include solicitors, field agents or surveyors. If you chose to communicate with us or send information via a third party mobile phone application, how your personal data will be used will be set out in their own privacy policy. We will be able to access the information you provide via the app and will use this information for the reasons set out below.

We may contact you via email to invite you to review any services and products you received from us in order to collect your feedback and improve our services and products. We use an external company, Trustpilot to collect your feedback which means that we will share your name, email address and reference number with Trustpilot for this purpose. If you want to read more about how Trustpilot process your data, you can find their Privacy Policy here.

Legal basis for processing personal data

When we process your personal data we do this for one or more of the following reasons:

• - to progress the loan enquiry;
• - to enter into the loan contract;
• - to record and place on the relevant public registers our interests in respect of any of your property that our loan is secured against;
• - to fulfil a contract we have with you;
• - when it is our legal duty to do so;
• - where we have legitimate interest in doing so (and this doesn’t outweigh your own relevant interests); or
• - when you have given us consent.

Your rights

Your personal data is protected by legal rights, which include your rights to request access to your personal information, object to our processing of your personal data, request that your personal data is erased or corrected, request restriction and data portability. These rights are, however, not always absolute rights as some are subject to some restrictions.

Access to your personal information

Data Protection law gives you the right to request the personal information that we hold about you. You have the right to be informed whether or not we are processing personal data that relates to you, and, if so, to be informed of what we are processing, what we use the data for, who we disclose the data to and how long we will keep it for.

Object to processing

Depending on the legal basis for which we are using your information, you may be entitled to object if you believe there are lawful grounds to do so.

Erasure

You have a right to request deletion or removal of personal data in certain circumstances, in essence where the processing fails to meet the requirements of data protection law.

Correction/rectification

You can ask us to correct personal data we hold about you, if you are able to evidence that the data we hold is inaccurate.

Restriction

You have a right to request that we restrict our use of your personal data. The Company will be required to restrict the processing of personal data in certain circumstances, for example where an individual contests the accuracy of the personal data.

Data portability

You may ask us to provide you with a copy of the personal data you have provided to us in a commonly used electronic format.

Your data - retention periods / how long we keep your data

Customer account records

We will keep your personal data for as long as you are a customer with Central Trust. Once you have paid back the loan, we will keep your data for up to 12 years to enable us to deal with any questions or complaints, to demonstrate compliance with regulations or for legal reasons.

Enquiry

Where you have made an enquiry or application but it has not resulted in a mortgage with us, we will keep your data for 12 months.

Consent for marketing

This is retained until you request for it to be removed or for 12 months after the end of the relationship with Central Trust (the date the loan is paid off).

Complaints

We will keep information relating to any complaint(s) you have made for 6 years after the date on which your relationship with Central Trust ends (the date the loan is paid off), unless we have an overriding obligation to retain your details longer.

Suspicious/fraudulent activity

Where we have detected fraudulent activity, this information will be retained for 5 years from the end of the relationship with Central Trust or 5 years from the date of the suspicion (whichever is later).

Telephone calls

All telephone calls will be kept for a maximum of up to 15 years from the date of the call.

Contact

For more information or to exercise your data protection rights, please contact us at legalandprivacy@centraltrust.co.uk, phone us on 01923 280 322 or write to us at:

Data Protection Officer
Central Trust Limited
Office 1, 1st Floor, Building 2, Axis,
Rhodes Way,
Watford,
Hertfordshire,
WD24 4YW

Marketing

If you choose to receive marketing material from us, we may contact you by letter, phone or electronic mail to offer other products which we feel may be of interest to you. If you do not wish to be contacted by us, please write to the Data Protection Officer at the address above, or e-mail your name and address (including postcode) to unsubscribe@centraltrust.co.uk. You may also update your marketing preferences on our website: www.centraltrust.co.uk/existing-customers/

Enquiry Form

We may request information from you on our contact form. A user must provide contact information (such as name, email address, phone number etc). This information is used in consideration of your loan application and to contact you regarding your application. By submitting the enquiry form you are confirming that the information given is accurate and that you consent to its use as defined in this privacy notice.

Live chat

We use a third party platform to deliver our Live Chat service to handle customer enquiries in real time. The software is provided by a company called Click4Assistance.

When you interact with the Live Chat interface, the following details may be recorded by the Click4Assistance live chat service:

• - Any data added to the Chat window
• - IP Address (An IP address is a number sequence that identifies a device (not a user) that is connected to the internet. Some IP addresses are the same each time they connect to the internet, "Static IP" and some change each time “Dynamic IP”.)
• - Language
• - User Agent (technical data which includes device, browser etc.)
• - Referral Site, Search Engine, Search Keywords if you visited our Website from one of these types of web page
• - Number of visits
• - Number of pages visited
• - Device/Operating System/Browser
• - Country, Region, City, Longitude/Latitude,
• - ISP/Domain (all based on IP lookup)
• - Any data you choose to send in attachments
• - Any data you choose to send on any forms (pre-chat, survey, offline etc.)

If you use the Live Chat service and you request to speak to a member of our team we may ask you for your name, telephone number and email address in order to arrange contact with our team. This is optional.

The details of your Live Chat conversation reside on Click4Assistance servers. Click4Assistance servers are based in the UK. Your data will not pass outside the UK at any point, as a result of using the Click4Assistance live chat service via our Website. Click4Assistance may use “sub-processors” (third parties) to help them in the conduct of providing their service.

Wherever and however your data is processed, Click4Assistance adheres to processes and measures necessary to adequately protect your data.

For information on how Click4Assistance secures the data that exists on the Live Chat platform, visit these pages of their website.

Your Live Chat details will also be passed to the relevant team so that they understand the nature of your enquiry. As a result, your details may be recorded within client records on our internal systems. This is so that we have a full picture of our work with you, this data is subject to our standard data retention periods (see “Your data - retention periods / how long we keep your data”).

When using the chat option our staff will never ask you for any bank account or card payment details.

SMS

We use Text Anywhere to provide SMS/text messages should we need to contact you, details of how they process personal data can be found here.

Credit searches: The Borrower

When you enquire, our initial credit search, which is used to generate your loan quote, is a ‘soft’ search (enquiry search) and does not leave a footprint on your credit file. The search should not impact upon your credit rating and cannot be seen by other people making searches in the future.

If you decide to proceed with the loan application, a ‘hard search’ (application search) will be carried out against you. This hard search will be recorded by the credit reference agency (CRA) and will be seen by other people searching in the future.

Credit reporting: The Borrower

In order to process your application, we will perform credit and identity checks on you with one or more CRA’s. Where you take financial services from us we may also make periodic searches at CRAs to manage your account with us.

To do this, we will supply your personal information to CRAs and they will give us information about you. This will include information from your credit application and about your financial situation and financial history. CRAs will supply to us both public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information.

We will use this information to:

• - assess your creditworthiness and whether you can afford to take the product;
• - verify the accuracy of the data you have provided to us;
• - prevent criminal activity, fraud and money laundering;
• - manage your account(s);
• - trace and recover debts; and
• - ensure any offers provided to you are appropriate to your circumstances.

We will continue to exchange information about you with CRAs while you have a relationship with us. We will also inform the CRAs about your settled accounts. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt. This information may be supplied to other organisations by CRAs.

When CRAs receive a search from us they will place a search footprint on your credit file that may be seen by other lenders.

If you are making a joint application, or tell us that you have a spouse or financial associate, we will link your records together, so you should make sure you discuss this with them, and share with them the information in this notice, before lodging the application. CRAs will also link your records together and these links will remain on your, and their, files until such time as you or your spouse or financial associate successfully files for a disassociation with the CRAs to break that link.

The identities of the CRAs, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRAs are explained in more detail at www.equifax.co.uk/crain, www.experian.co.uk/legal/crain & www.transunion.co.uk/crain

Information sharing with brokers

If you are introduced to us by a broker or another intermediary, we will inform them about the progress of the loan application and whether you have been successful. The broker or other intermediary will not be informed about the performance of the loan (whether you are paying or not) once funds have been released.

FAIR PROCESSING NOTICES FOR THE PURPOSES OF FRAUD PREVENTION AND DETECTION

General

Before we provide services, or financing to you, we undertake checks for the purposes of preventing fraud and money laundering, and to verify your identity. These checks require us to process personal data about you.

We may use personal data that you have provided, that we have collected from you and that we may have received from third parties to prevent fraud and money laundering and to verify your identity.

Details of the personal information that will be processed may include name, date of birth, address, contact details, financial information, employment details and device identifiers including IP address.

We and fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime. We process your personal data on the basis that we have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the services or financing you have requested.

Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.

Consequences of processing

If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services and financing you have requested or we may stop providing existing services to you.

A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you. If you have any questions about this, please contact us on the details above.

Data Transfers

Fraud prevention agencies may allow the transfer of your personal data outside of the UK. This may be to a country where the UK Government has decided that your data will be protected to UK standards, but if the transfer is to another type of country, then the fraud prevention agencies will ensure your data continues to be protected by ensuring appropriate safeguards are in place.

Complaints

You should find your dealings with us to be prompt, efficient and friendly. Our aim is to provide you with a world class, professional and confidential service. If you have a complaint about any aspect of the service you have received our staff will be happy to help resolve your concerns. Please bring your concerns to our attention as soon as possible – the sooner we know about it the sooner that we can resolve it. We have a formal complaints procedure to ensure that your complaint is handled quickly, fairly and efficiently.

For further information or to make a complaint, please contact our Compliance Team:

Compliance Team – Central Trust Limited
Office 1, 1st Floor, Building 2, Axis,
Rhodes Way,
Watford,
Hertfordshire,
WD24 4YW
Tel: 01923 280 434

If we are unable to resolve your complaint to your satisfaction you may have the right to refer your complaint to the Financial Ombudsman Service, free of charge. We may provide personal data of applicants, borrowers and others in response to requests from the Financial Ombudsman Service. For further information you can write to:

Financial Ombudsman Service (FOS)
Exchange Tower
London E14 9SR

Phone: 0800 023 4567
Email: complaint.info@financial-ombudsman.org.uk
Website: www.financial-ombudsman.org.uk

You also have the right to complain to the Information Commissioner’s Office (ICO). The ICO is an independent body responsible for making sure that organisations comply with Data Protection law. The ICO also deals with concerns raised by members of the public about the way in which organisations look after personal information. If you need to raise a concern, you can do so by using the following link:

www.ico.org.uk/concerns

Security Information

How We Protect Your Information

To ensure that your card details remain secure, you will only be able to make online payments if you have Internet Explorer 7.0 or above installed on your PC. Internet Explorer 7.0 supports Secure Socket Layer (SSL) technology, which is an industry standard for internet payments. This means all of your personal and card details are protected using 128 bit encryption when your details are transmitted over the Internet. This makes it virtually impossible for anyone else to discover and use your details.

Check You Are Using A Secure Site

Check your browser encryption strength by using your mouse to hover over a padlock icon in the bottom right hand corner of your browser window (it should be a closed padlock). When you do this, it should tell you that it is SSL Secured 128 bit.

Storing Your Card Details

We do not store your credit/debit card details, this information is processed by our chosen Payment Merchants.

Mastercard Securecode and Verified by Visa

Verified by Visa and Mastercard Securecode are online security services for Visa and Mastercard cardholders.

These schemes enable you to register an additional password to your card. By doing this you will help prevent unauthorised transactions on your debit card which means that you can add security and peace of mind to on-line transactions.

When you confirm your payment, if your bank is participating, you will be asked to register for either scheme. Simply follow the online instructions.

Some banks do offer an option to sign up later but others will insist that you sign up to the scheme immediately before completing your transaction. Like chip and pin, Verified by Visa and Mastercard Securecode will soon become compulsory.

If you have any further questions, please contact your card issuer.

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