Privacy Policy

Ashman Finance Limited (Ashman) is a company registered in England and Wales (company number 10907522) and its registered office is: 2nd Floor Rutland House, 148 Edmund Street, Birmingham, England, B3 2FD.

Ashman take the protection of your personal data very seriously and strictly adhere to the rules laid out by data protection laws and the General Data Protection Regulation (GDPR-UK).

This Privacy Policy gives you information on how we collect and process your personal data through your use of this site and any data you may provide if you contact us regarding our products and services.

We have appointed a Data Protection Officer (DPO) who is responsible for monitoring and providing guidance with our GDPR status. If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact us using the contact information in section 16 of this Privacy Policy.

This document is dated October 2023.

This policy applies to website www.ashmanfinance.com and any sub-domains.

We collect your personal data for one of the following purposes:

• To manage communications between you and us.

• Where we need to perform the contract we have entered into with you.

• To provide you with information you have requested or which we may feel may be of interest to you .

• To ensure the safe operation of our website and to monitor the performance of our website.

• For marketing and advertising purposes.

We only collect and use personal information about you when the law allows us to. Most commonly, we use it where:

• The data subject (you) has given consent to the processing activity taking place.

• If the processing is necessary for the performance of a contract.

• If the processing is necessary for compliance with a legal obligation to which the controller is subject.

• If the processing in necessary for the purpose of the legitimate interest pursed by us or our partners.

Where legitimate interest is identified as a lawful basis, we will undertake a legitimate interest assessment which is a three-part test covering:

The purpose test – to identify the legitimate interest.

Necessity test – to consider if the processing is necessary for the purpose identified.

Balancing test – considering the individual’s interests, rights or freedoms and whether these override the legitimate interests identified.

We collect personal information from you, for example, if you register to our website, request product information, call us or use any of our services. The categories of personal information that we may collect, store and use about you include:

• Name, address, address history, telephone number, email.

• Tax residency status, tax returns, marital status.

• Bank details, National Insurance number, Financial details

• Financial information, credit history, source of income, household expenses.

• IP address, type of devices and technology.

• Country of birth, right to work, nationality.

• Date of birth, utility bill and gender.

• Passport details, driving licence.

• Health information, employment history, employment references.

We may also collect your data through Third Parties such as

• Agents appointed to work on our behalf.

• Brokers.

• Comparison websites.

• Credit reference agencies.

• Data aggregators.

• Government and law enforcement agencies.

• Land agents.

• Market researcher organisations.

• Social networks.

• Solicitors, lawyers, valuers, panel managers, insurers.

• Trade Associations.

• Payment and transaction data.

• Public information sources such as Companies House.

We pride ourselves on ensuring that your personal data is only retained for the period that we need it for, or in accordance with laws, regulations and professional obligations that we are subject to. All personal information collected has a defined retention period, which is in-line with our retention policy. If you would like to find out how long your information is being retained, please see "additional information", section 17 of this policy.

We take the responsibility for protecting your privacy very seriously and we will ensure your data is secured in accordance with our obligations under the Data Protection laws. We have in place technical and organisational measures to ensure personal information is secured and to prevent your personal data from being accessed in an unauthorised way, altered or disclosed. We have in place a robust access control policy which limits access to your personal data to those employees, contractors and other third parties who only have a business need to know. The processing of your personal data will only take place subject to our instruction.

We have policies and procedures to handle any potential data security breaches and data subjects, third parties and any applicable regulators will be notified where we are legally required to do so.

We have ensured that all employees have had information security and data protection training. If you would like more details of the security we have in place, please see "additional information", section 17 of this notice.

We do not knowingly collect information on children. If we have collected personal information on a child, please contact us immediately using the details in section 16, so we can remove this information without any undue delay.

In this Section, we have summarised the rights that you have under General Data Protection Regulation. Some of the rights are complex, and not all the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

Your principal rights under General Data Protection Regulation are:

• Right to Object

• Right of Access

• Right to be informed

• Right to Rectification

• Right to Erasure

• Right to Restrict Processing

• Right to Data Portability

The right to object

You can exercise this right if

• Processing relies on legitimate interest.

• Processing is for scientific or historical research.

• Processing includes automated decision making and profiling.

• Processing is for direct marketing purposes.

The right of access

• You or any third party acting on your behalf with your authority may request a copy of the personal data we hold about you without charge.

• We will ask to verify your identity or request evidence from the third party that they are acting on your behalf before releasing any personal data we hold about you.

The right to be informed

• We are required, to provide clear and transparent information to you about how we process your personal data. This Privacy Policy addresses this right.

• The right of rectification

• If you believe the personal data we hold about you is incorrect or incomplete you have the right to correct this and you may exercise this right along with the right to restrict processing until these corrections are made.

The right to erasure

• If there is no legal basis or legitimate reason for processing your personal data, you may request that we erase it.

The right to restrict processing

• You may ask us to restrict the processing of your personal data. This means we will still hold it but not process it. This is a conditional right which may only be exercised when:

• Processing is unlawful.

• We no longer need the personal data, but it is required for a legal process.

• You have exercised your right to object to processing and require processing to be halted while a decision on the request to object is made.

• If you are exercising your right to rectification.

The right to data portability

• You can request that your personal data is transferred to another controller or processor in a machine-readable format if:

• Processing is based on consent.

• Processing is by automated means (i.e. not paper based).

• Processing is necessary for the fulfilment of a contractual obligation.

If you have any question about these rights, please see "additional information", section 17 of this policy.

Where you have given consent for processing, or explicit consent in relation to the processing of special category data, you have the right to withdraw this consent at any time, but this will not affect the lawfulness of processing based on consent before its withdrawal.

Where we need to collect personal data by law or in order to process your instructions or perform a contract, we have with you and you fail to provide that data when requested, we may not be able to carry out your instructions or perform the contract we have or are trying to enter into with you. In this case, we may have to cancel our engagement or contract you have with us, but we will notify you if this is the case at the time.

Our website uses cookies. Please see our Cookies Policy for full details of the cookies used.

Ashman may disclose your personal data, listed in section 4 to some third parties to help us deliver our services/products. All third parties are contractually bound to protect the personal data we provide to them. We may use several or all of the following categories of recipients:

• Business partners, suppliers, contractors for the performance of any contract we enter into with them or you.

• Companies we have a joint venture or agreement to cooperate with where necessary for administrative purposes and to provide services to you.

• Third parties that support us to provide products and services e.g. credit reference agencies, fraud prevention agencies, IT support, cloud-based software services, providers of telecommunications equipment).

• HM Revenue and Customs, regulators and other statutory bodies and authorities.

• UK Financial Services Compensation Scheme and the Financial ombudsman Service.

• Funding for Lending Scheme, British Business Bank and similar industry bodies

• Insurers, loss adjustors and receivers.

• Trustees, guarantors, beneficiaries, administrators or executors associated with your account.

• Direct Debit Scheme, if you use direct debit.

• If you have a secured mortgage with us, we may need to share information with other lenders who also hold a charge on that property.

• Marketing services providers.

• Payment service providers.

• Recruitment service providers.

• Professional advisors e.g. lawyers, auditors.

• Web analytics and search engine provider to ensure the continued improvement and optimisation of our website.

If you apply for a new product or service from us, we will perform credit and identity checks on you with one or more credit reference agencies (“CRAs”). We may also make periodic searches at CRAs to manage your account with us and to detect and prevent fraud.

To do this, we will supply your personal information to the CRAs and they will give us information about you. The information shared 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 a product.

• Verify the accuracy of the information you have provided to us.

• Confirm identities.

• Prevent criminal activity, fraud and money laundering.

• Manage your account(s).

• Trace and recover debts.

• 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 organisations. The type of footprint left is dependent upon the search that is conducted.

Once you have become a customer, we will also share your personal information as needed to help detect fraud and money-laundering risks. CRAs are used to assist with this.

We or a CRA (in their fraud prevention role) may allow law enforcement agencies to access your personal information. This is to support our/their duty to detect, investigate, prevent and prosecute crime.

The identities of the CRAs, their role also as fraud prevention agencies, the information they hold, the ways in which they use and share personal information, information 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/crain www.transunion.co.uk/legal/privacy-centre

In this section, we provide information about the circumstances in which your personal data may be transferred and stored in countries outside the United Kingdom (UK).

We may share personal information with third parties outside of the UK. Any personal information transferred will only be processed on our instruction and we ensure that information security at the highest standard would be used to protect any personal information as required by the Data Protection laws.

Where personal data is transferred outside of the UK to a country without an adequacy decision, we will ensure appropriate safeguards are in place prior to the transfer. These could include:

Standard Contractual Clauses plus UK Addendum.

International Data Transfer Agreement.

An exception as defined in Article 49 of the EU GDPR.

For more information about transfers and safeguarding measures, please contact us using the information in section 16.

We take any complaints about our collection and use of personal information seriously.

If you think that our collection or use of personal information is unfair, misleading, or inappropriate, or have any other concern about our data processing, please raise this with us in the first instance.

Where we make an automated decision which has a legal or substantially similar effect, you have the right to speak to us and we may then review the decision, provide a more detailed explanation and assess if the automated decision was made correctly.

To make a complaint, please contact us by email: complaints@ashmanfinance.com

Alternatively, you can contact us by post: 2nd Floor Rutland House, 148 Edmund Street, Birmingham, England, B3 2FD.

Your trust is important to us. That is why we are always available to talk with you at any time and answer any questions concerning how your data is processed. If you have any questions that could not be answered by this Privacy Policy or if you wish to receive more in-depth information about any topic within it, please contact us at info@ashmanfinance.com.

We keep this Policy under regular review. This Privacy Policy was last updated on 17/10/2023.

We reserve the right to update this Privacy Policy at any time, and we will provide you with a new Privacy Policy when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.