Claratus Commercial Finance Limited (‘Claratus’) provides Asset Finance & Alternative Financing to our clients.

Claratus Commercial Finance Limited (reg. no. 9295127) is Authorised and Regulated by the Financial Conduct Authority (FRN 675461).

We need to collect personal data from our clients, introducers, lenders and other contacts to ensure we can provide these services.

Your privacy is important to us and it is our policy to respect the confidentiality of information and the privacy of individuals. This notice outlines how we as a data controller, manage your personal information (‘personal data’). It also details your rights in respect of our processing of your personal data. This Privacy Notice may be updated from time to time.

Claratus has implemented appropriate technical and organisational measures to comply with applicable data protection legislation including; internal data protection policies, staff training, internal audits of processing activities, and reviews of internal HR policies.

What kind of personal data do we collect about you?

We collect information necessary to fulfil our obligations to our clients, introducers and lenders in the course of proving asset and alternative financing solutions.

Some of this data is submitted to us in application or declaration forms and identification documents, and may include the following types of data; name, address and contact details, date of birth and gender, profession and employment details, information about your income or financial statements, asset and liabilities, payment history, bank details, location data and any other similar information.

We may occasionally collect sensitive personal data about you such as racial or ethnic origin. We only collect and further process this type of data, where you have given your explicit consent.

If you provide us with any personal data relating to a third party (e.g. information of your spouse, children, parents), you represent to us by providing the data to us, that you have obtained prior consent from that person.

How do we collect your data?

Generally, we collect personal data in the following ways;

when you submit an application or declaration form in relation to a credit search;
when you interact with our employees, for example, via telephone calls, letters, face-to-face meetings and emails;
when you use some of our services, like our websites
when you request that we contact you, be included in an email or other mailing list;
when you respond to our initiatives or to any request for additional personal data

Do we make automated decisions concerning you?

We do not carry out automated profiling on you; however we may send your details to a credit reference agency that may then use automated profiling. This may be used to determine that the customer is not approved for credit, or the amount applied for, the customer poses a fraud, terrorism or money laundering risk; or the customer has hidden its identity.

You have the right to object to automated profiling and you will be notified prior any automated profiling being carried out.

What legal basis do we have for using your information?

The law on data protection allows us to only process your data for certain reasons:

in order to perform a contract that we are party to,
in order to carry out legally required duties,
in order for us to carry out our legitimate interests,
to protect your interests and,
where something is done in the public interest.

All of the processing carried out by us falls into the first three permitted reasons, for example; for the performance of a contract we have entered into with clients, lenders or introducers or in order to comply with our duties under FCA rules. This includes our obligation to verify the identity of clients and to maintain records of regulated businesses.

For prospective clients, lenders and introducers, and other third parties, our processing is also necessary for our legitimate interests in that we need to collect this information in order to contact these individuals prior to entering into a contract or providing our services.

For example, we may collect information from online enquiries, quotes and referrals. Some of this information is also collected from publicly available information, from market research and purchased data.

Consent

Before undertaking credit reference searches, or before we collect sensitive personal data, you will always be asked for your explicit consent. You have the right to withdraw that consent at any time by contacting us using the contact details below.

If you do not provide the personal data necessary, or withdraw your consent, we may not be able to provide you with the financing or services you are looking for.

How long do we keep this information for?

Your personal data is kept for the minimum time to fulfil the purposes for which it was collected or otherwise to meet statutory requirements.

If we cannot obtain finance for you or we no longer have a relationship with you, we will ensure all data is deleted within 12 months.

Disclosure of your personal data

We may share your data with selected third parties including:

a lender for the purpose of a finance agreement,
a credit reference agency or other verification company to conduct checks on you to verify the information you have provided
third party service providers who process this data on our behalf to help run some of our internal business operations, for example IT services.

Where we share your data with third parties we ensure that your data is held securely and in line with GDPR requirements.

Where your data is sent to a credit reference agency or other verification company, you will be asked for your explicit consent beforehand.

How do we store and protect personal data?

Safeguarding the privacy of your data is important to us, whether you interact with us personally, by phone, mail, over the internet or any other electronic medium.

We hold personal data in a combination of secure computer storage facilities and paper-based files and other records, and take steps to protect the personal data we hold from misuse, loss, unauthorised access, modification or disclosure. We have a detailed data protection policy and procedure in place and conduct relevant training to employees to ensure that all employees understand their obligations.

We have adequate IT Security arrangements in place to ensure your personal data is held securely. However, the internet is an open medium and we cannot guarantee that any data you send to us by email or via our sites will not be intercepted or tampered with; any transmission is at your own risk.

Where you have opted out of receiving marketing communications we will hold some of your details on our suppression list so that we know you do not want to receive these communications.

Your rights as a data subject

The law on data protection gives you certain rights in relation to the data we hold on you. These are:

the right to be informed. This means that we must tell you how we use your data, and this is the purpose of this privacy notice
the right of access. You have the right to access the data that we hold on you. To do so, you should make a subject access request
the right for any inaccuracies to be corrected. If any data that we hold about you is incomplete or inaccurate, you are able to require us to correct it
the right to have information deleted. If you would like us to stop processing your data, you have the right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it
the right to restrict the processing of the data. For example, if you believe the data we hold is incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the data is correct
the right to portability. You may transfer the data that we hold on you for your own purposes
the right to object to the inclusion of any information. You have the right to object to the way we use your data where we are using it for our legitimate interests
the right to regulate any automated decision-making and profiling of personal data. You have a right not to be subject to automated decision making in way that adversely affects your legal rights.

Transfers outside the EEA

We may transfer your personal information outside the European Economic Area (EEA), but this should only be to countries which have been deemed to provide an adequate level of protection for personal data by the European Commission. We may also pass your details onto Lenders who may transfer your data outside of the EEA. The data protection policy of the particular lender will be visible on their website and will either be provided in advance of an application for finance, once an application has been made or you will be able to contact the lender directly to obtain if required.

Access to personal information about you

As mentioned above you have the right to request a copy of the personal data we hold about you. If you would like a copy of some or all of this data you may contact us by telephone on 0207 294 7500 or you may write to us at: Claratus Commercial Finance Limited, Hilden Park House, 79 Tonbridge Road, Hildenborough, Tonbridge, TN11 9BH.

Contact Us

If you have any queries regarding privacy issues or the content of this privacy notice, you can email us on info@claratus.com or write to us at: Claratus Commercial Finance Limited, Hilden Park House, 79 Tonbridge Road, Hildenborough, Tonbridge, TN11 9BH or call us on 0207 294 7500.

What if you have a complaint?

If you have a concern about any aspect of our privacy practices, you can make a complaint. This will be acted upon promptly. To make a complaint, please contact us via one of the methods set above. If you are not satisfied with our response to your complaint, you have the right to lodge a complaint with our supervisory authority, the Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.

Website & Cookies Policy

This policy should be read in conjunction with our Company Privacy Notice, which can be found above.

How we use your information
This privacy and cookies notice policy has been prepared to meet the requirements of the UK’s Data Protection Act 1998 and The Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011. The policy tells you what to expect when Claratus Commercial Finance Ltd collects personal information. It applies to information we collect about:

visitors to our websites
complainants and other individuals in relation to a data protection or freedom of information complaint or any other enquiry
people who use our services, eg those who subscribe to our newsletter or place an enquiry
people who notify under the Data Protection Act
job applicants and our current and former employees

Visitors to our websites
When someone visits https://claratus.com we collect standard internet log information, such as location data and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. We collect this information in a way which does not identify anyone personally. We do not make any attempt to find out the identities of those visiting any of our websites (Claratus Commercial Finance group of companies). We will not associate any data gathered from this site with any personally identifying information from any source. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.

Use of cookies by Claratus Commercial Finance Ltd
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.
The table below explains the cookies we use and why.

Cookie	Purpose	More information
Google Analytics (& Bing Analytics)	Google sets these performance cookies, which These cookies are used to collect information about how visitors use our site. Google stores the information collected on servers in the United States. Google may transfer this information to third parties where required to do so by law, or where third parties process the information on Google’s behalf. Google state that they will not associate your IP address with any other data held by them.	Click here for an overview of privacy at Google
Content Management System cookie	This cookie is set by our content management system. It tracks when the user is logged in and enables a profile. This cookie is essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website.	We do not actively use the data or export for marketing purposes, it is purely for website functionality.
Online Shopping Cart	Some sections of the site may have a shopping cart functionality. During the selection process through to Checkout the user is tracked by profile to enable a complete booking to be placed in our CRM system. This is an automated process.	The purchase details are stored in the website database for an audit trial of purchase. This information is not exported and never distributed.The payment is processed by a third party eg.Paypal or Google checkout and we do not have access to this part of the payment or any associated information other than the basic requirements for us to process a booking and register it in our CRM system.
Web Chat Software	This cookie is a functionality cookie which tracks the page and visitor trail through the site, and the IP location to enable rapid response. This cookie remembers your choices in order to improve your experience. No personal detail is taken without request.	The web chat has a non-mandatory login. If the viewer chooses to input their details they are stored on their cookies for future recognition so we can quickly identify any previous enquiries.

How to disable cookies
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visitwww.allaboutcookies.org.

You have the ability to accept or decline cookies by modifying the settings in your browser. For example, in Internet Explorer, you can go to Tools and Internet Options, where there is the option to change your settings to disable cookies. However, you may not be able to use all the interactive features of our site if the cookies are disabled. You also have the ability to delete cookies that have been installed in the cookie folder of your browser. To do this you should search for “cookies” in your “Help” function for information on where to find your cookie folder.

Unless you have adjusted your browser settings so that it will refuse cookies, our system will issue cookies when you log on to our Site. To prevent Google Analytics cookies being set, you may install the Google Analytics Opt-Out Browser Add-On by clicking on this link –http://tools.google.com/dlpage/gaoptout and following the instructions.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visitwww.allaboutcookies.org.

YouTube cookies
We embed videos from our official YouTube channel using YouTube’s privacy-enhanced mode. This mode may set cookies on your computer once you click on the YouTube video player, but YouTube will not store personally-identifiable cookie information for playbacks of embedded videos using the privacy-enhanced mode. To find out more please visit YouTube’s embedding videos information page: http://support.google.com/youtube/bin/answer.py?hl=en-GB&answer=171780

People who place an enquiry with us
When you place an enquiry with Claratus Commercial Finance either directly or indirectly through an intermediary, such as an online broker we store information that you have supplied regarding your contact information and business requirements. This information is stored in a secure CRM system. We use this information to store account history and contact you via email or phone during and after the sales process based on the requirements you have given us. We have a clear ‘do not contact’ field that stops information being passed through to sales and marketing. We do not pass on information to third parties and only use the information to market based upon the enquiry that was freely given to us. You can be removed from our CRM system by contacting info@claratus.com.

We purchase data from certified professional agencies to market our products. This data is not held within our CRM system, and is only available to the marketing department. All emarketing has a clear ‘unsubscribe’ mechanism that prevents further messages.

People who call our helpline
When you call Claratus Commercial Finance’s sales/helpline we collect Calling Line Identification (CLI) information. We use this information to help improve its efficiency and effectiveness.

However, there may be situations where you do not want us to collect CLI information. The simplest way to deal with this is to dial 141 before dialling our number. Always dial the 141 first, in front of any other numbers. However, if you are dialling from an extension on a business switchboard system, where you have to dial (typically) 9 for an outside line, you should dial 9 first, then 141 and then the outside number.

When you dial 141, this is described as ‘blocking your CLI’. As mentioned above, it stops us from knowing your number. You should note, however, that your phone company and their operators can always see your number should they need to.

People who make a complaint to us
When we receive a complaint we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.
We will only use the personal information we collect to process the complaint and to check on the level of service we provide. We do compile and publish statistics showing information like the number of complaints we receive, but not in a form which identifies anyone personally.

We usually have to disclose the complainant’s identity to whoever the complaint is about. This is inevitable where, for example, the accuracy of a person’s record is in dispute. If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis.

We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for four years from closure in a secure environment.

Similarly, where enquiries are submitted to us we will only use the information supplied to us to deal with the enquiry and any subsequent issues and to check on the level of service we provide.

When we take enforcement action against someone, we may publish the identity of the defendant in our Annual Report or elsewhere. Usually we do not, identify any complainants unless the details have already been made public.

People who use Claratus Commercial Finance services
Claratus Commercial Finance offers various services to the public. For example, we send out publications and distribute an electronic newsletter. We use third party software to distribute our emarketing material.
We have to hold the details of the people who have requested the service in order to provide it. However, we only use these details to provide the service the person has requested and for other closely related purposes. For example, we might use information about people who have made a sales enquiry or attended an event. When people do subscribe to our services, they can cancel their subscription at any time and are given an easy way of doing this.

People who ‘notify’ under the Data Protection Act 1998
Claratus Commercial Finance puts technical measures in place to prevent the bulk down-load of our data. When businesses fill in forms or make an enquiry, they are asked to provide the contact details of a relevant member of staff. Claratus Commercial Finance will use this for its own purposes only.

Job applicants, current and former Claratus Commercial Finance employees
When individuals apply to work at Claratus Commercial Finance, we will only use the information they supply to us to process their application and to monitor recruitment statistics. Where we want to disclose information to a third party, for example where we want to take up a reference or obtain a ‘disclosure’ from the Criminal Records Bureau we will not do so without informing them beforehand unless the disclosure is required by law.
Personal information about unsuccessful candidates will be held for 12 months after the recruitment exercise has been completed, it will then be destroyed or deleted. We retain de-personalised statistical information about applicants to help inform our recruitment activities, but no individuals are identifiable from that data.

Once a person has taken up employment with Claratus Commercial Finance, we will compile a file relating to their employment. The information contained in this will be kept secure and will only be used for purposes directly relevant to that person’s employment. Once their employment with Claratus Commercial Finance has ended, we will retain the file in accordance with the requirements of our retention schedule and then delete it.

Complaints or queries
Claratus Commercial Finance tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.

This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of Claratus Commercial Finance’s collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below.

Your right to access to personal information
Claratus Commercial Finance tries to be as open as it can be in terms of giving people access to their personal information. Individuals can find out if we hold any personal information by making a ‘subject access request’ under the Data Protection Act 1998. If we do hold information about you we will:

give you a description of it;
tell you why we are holding it;
tell you who it could be disclosed to; and
let you have a copy of the information in an intelligible form.

To make a request to Claratus Commercial Finance for any personal information we may hold you need to put the request in writing addressing it to our Corporate department, or write to the address provided below.
If you agree, we will try to deal with your request informally, for example, by providing you with the specific information you need over the telephone.

Any access request will be subject to a fee of £10 to meet our costs in providing you with such information.

Disclosure of personal information
In many circumstances we will not disclose personal data without consent. However when we investigate a complaint, for example, we will need to share personal information with the organisation concerned and with other relevant bodies. You can also get further information on this by contacting our Corporate department.

Links to other websites
This privacy notice does not cover the links within this site linking to other websites. We encourage you to read the privacy statements on the other websites you visit. We do not accept any responsibility or liability for these policies.

This policy was last updated in June 2012. We recommend that you check this page regularly to ensure that you have read the most recent version and that you are happy with the changes.

Interactive areas of our Site
Information that you post via social networking sites, including but not limited to Facebook, Twitter and Linked In, is generally accessible to and maybe collected by others. This may result in unwelcome communications. For your own safety and security, you should not provide any information on the aforementioned sites, that you would not want others to see.

If you do provide any information via social networking sites, we do not accept any responsibility or liability for any breach of privacy, loss, damage, effect on your reputation or otherwise, whatsoever.

Contact
Questions, comments and requests regarding this policy are welcomed and should be addressed to info@claratus.com.