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GRPADS WEBSITE PRIVACY POLICY (UK)

Global Response Partners UK Limited (GRP, we, us, our or the Company) act as a consumer credit broker and are authorised and regulated by the Financial Conduct Authority (FCA) for these purposes under FCA firm reference number 746301. This privacy policy has been prepared by us to meet the requirements of the Data Protection Act 1998 (the Act). The Company is registered under the Act with registration number: ZA181843.

This privacy policy (together with our Terms of Use and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data.

1 INFORMATION WE MAY COLLECT

1.1 Information you supply to us:

1.1.1 All correspondence and communications, and a record of them if you initiate or engage in correspondence with GRP or our Broker Partners (as defined in section 3.4 below). This includes emails, the use of mobile devices, and any other form of written or electronic correspondence or interaction

1.1.2 Any interaction with GRP or its Broker Partners via verbal communication, including landline or mobile telephone calls, Skype or any other medium may be recorded both for training and monitoring purposes and the protection of your interests and that of GRP and our Broker Partners

1.1.3 Surveys that we may use for research purposes, which we have asked you to complete.

1.2 Information we collect about you:

1.2.1 Evidence that you have expressed an interest, opted in or agreed to receive further marketing material by GRP or our Broker Partners (this may be in the form of a web link, call to action button, i.e. a “tick box” or “I agree” button)

1.2.2 Evidence that you have agreed to visit a Broker Partner’s direct website to consider their product or service offering (this may be in the form of a web link, call to action button, i.e. a “tick box” or “I agree button”, a website cookie stored on your computer or a pixel fire, which evidences that you have viewed a screen detailing your agreement to interact with the promotion)

1.2.3 Details of your visits to our website(s), including your personal IP address and the resources that you access.

1.3 Information we receive from other sources. We also work closely with third parties (including, for example, Broker Partners, advertising networks, analytics providers, search information providers) and may receive information about you from them where you have provided such third parties with consent to share this information.

2 WHERE WE STORE YOUR PERSONAL DATA

2.1 All information you provide to us is, as far as reasonably practicable, stored on our secure servers. We ask you not to permit anyone to use your name.

2.2 The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things the provision of our services to you. By submitting your personal data, you agree to this transfer, storing or processing. GRP will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

2.3 Unfortunately, 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 website(s); any transmission is at your own risk.

2.4 We will retain your information securely stored for a reasonable period or for as long as the law requires.

3 HOW WE USE YOUR INFORMATION

3.1 The Company collects and processes your data in order to provide you with our services, or that of our Broker Partners.

3.2 We will store and process your information on our computers and in any other way we consider appropriate.

3.3 We use information held about you in the following ways:

3.3.1 to provide your information to a lender, product or service provider for them to assess your suitability if you are applying for a credit product;

3.3.2 to provide you with the best possible service;

3.3.3 to request customer feedback;

3.3.4 to develop, improve and update our products to better meet your needs and preferences;

3.3.5 to ensure that content from the website is presented in the most effective manner for you and for your computer;

3.3.6 to administer the website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

3.3.7 to notify you about changes to our service;

3.3.8 for our record keeping and identification protocols;

3.3.9 to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and

3.3.10 to provide you with information about goods and services which may be of interest to you (where you have provided us with consent to do so), and we may contact you about these by post, telephone, email, SMS, mobile marketing or other reasonable method that you have consented to.

3.4 If you have provided us with consent to do so, we may pass your details to [insert names of companies if possible] OR [include a specific and clear description of the types of organisation you pass data to] (Broker Partners) so that they can provide information and services which may be of interest to you. We will obtain separate consent for each method of communication, they may contact you by post, telephone, email, SMS, mobile marketing or other reasonable methods that you have consented to.

3.5 If you would like to opt out of receiving marketing information from us or to revoke your consent for us to pass your details to third parties, you can do so by:

3.5.1 selecting unsubscribe on an email or mobile marketing message sent by us or our Broker Partners;

3.5.2 emailing us at customerservices@grpads.com; or

3.5.3 writing to us at Global Response Partners UK Limited, Thornfield House, Delamer Road, Altrincham, Cheshire, WA14 2NG.

3.6 We reserve the right to take reasonable steps to authenticate your identity with respect to any such request or other enquiry.

3.7  Any information or statistics relating to our business that we disclose to others shall not identify you personally.

4 DISCLOSURE OF YOUR INFORMATION

4.1 We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.

4.2 We may disclose your personal information to third parties:

4.2.1 to enable lenders, product or service providers to make a decision (where you wish to apply for credit to one of our lender partners);

4.2.2 to prepare or send any communications to you, or to assist us in connection with any of our administrative or business functions, or in the provision of any of our services to you;

4.2.3 if the Company or substantially all of its assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;

4.2.4 to anyone whom we transfer our rights and duties to;

4.2.5 analytics and search engine providers that assist us in the improvement and optimisation of the Website; and

4.2.6 if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation, or in order to enforce other agreements with you; or to protect the rights, property, or safety of the Company , our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

5 IP ADDRESSES AND COOKIES

What are cookies?

Cookies are small text files stored on a user’s computer by their web browser or the website visited, designed to store basic information (such as visitor preferences) to help the browser 'remember' things that you have done in the past.

Our use of cookies

When you visit our website(s) a bar is displayed at the [top/bottom] of the page. This alerts visitors to the fact that our website(s) uses cookies to identify a previous visitor to our website and allows a user to click to find out more information about our use of cookies. By continuing to use our website(s) you are consenting to our use of cookies. Once consent is obtained, it is not necessary to obtain it again for the same user each time the same cookie is used in the future.

Managing cookies

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our website(s). You can find out how to do this here. This site has a guide on how to change the settings for most of the major internet browsers.

Cookies we use

We use [insert number] types of cookie on this Website. None of them stores any information that identifies you personally, such as a name or postal address.

[Insert a list of cookies that you use and a brief description of what each one does].

Web tools

We might also use web tools to collect information about your browsing activities while on our website(s). In this respect the information that is provided is similar to the information supplied by cookies, and we use it for the same purposes.

Third party cookies

Some of our advertisers and Broker Partners may also use cookies or web tools that are set by other people such as advertising agencies, or the businesses to which the advertisements in question relate. We do not have access to any information collected in this way and, if you are concerned, you should contact the advertiser for more information.

6 YOUR RIGHTS

6.1 You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by either not ticking relevant boxes when we collect data from you, or ticking certain boxes (as applicable). You can also exercise the right at any time by contacting us using the details set out in section 3.5 above.

6.2 Our website(s) may, from time to time, contain links to and from the websites of our 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.

6.3  You have the right to access information held about you. Your right of access can be exercised in accordance with the Act by writing to us at Global Response Partners UK Limited, Thornfield House, Delamer Road, Altrincham, Cheshire, WA14 2NG. Any access request may be subject to a small statutory fee to meet our costs in providing you with details of the information we hold about you.

6.4 Calls between us may be recorded and/or monitored for training and compliance purposes.

7 CREDIT REFERENCE AND FRAUD PREVENTION AGENCIES

7.1 Some lenders whom we or our Broker Partners may pass your information to may run a credit check with credit references agencies and fraud protection agencies to make a decision as to whether to provide you with a loan.

7.2  If you apply for a loan or consumer credit product and it is refused by one of our lender or Broker Partners on the basis of information they have received from a credit reference agency, they must inform you of this and provide you with the details of the agency concerned.

7.3 If false or inaccurate information is provided and fraud is identified, details will be passed to fraud prevention agencies.

7.4 Law enforcement agencies may access and use this information.

7.5 We and other organisations may also access and use your information to prevent fraud and money laundering.

7.6 Your data may also be used for other purposes for which you give your specific permission or, in very limited circumstances, when required by law or where permitted under the terms of the Act.

8 CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our privacy policy in the future will be posted on this page.

9 CONTACT

Questions, comments and requests regarding this privacy policy are welcomed at customerservices@grpads.com or Global Response Partners UK Limited, Thornfield House, Delamer Road, Altrincham, Cheshire, WA14 2NG.