Neroli Mortgages & Finance - Privacy Policy
Melfinco
Limited t/a Neroli Mortgages & Finance are
committed to protecting and respecting
your privacy.
This policy 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 and how we will treat it.
By visiting www.nerolimortgages.co.uk you
are accepting and consenting to the
practices described in this policy.
This privacy policy will applies to you
if you provide your personal information
to us, even if you decide not to go
ahead with any product or service we
offer.
For the purpose of the General Data
Protection Regulation, the data
controller is Melfinco Limited of 1 Mill
Lane, Westhoughton, BOLTON. BL5 2DN.
If you have any questions about how we
may use your personal information you
can contact us at
patrick@nerolimortgages.co.uk
1. Information we collect from you
The information we collect from you
depends on the product or service you
apply for, or the service that we
provide to you. We will only collect
information that we actually need, or
where we’re required to collect the
information to enable us to perform our
legal, regulatory or contractual
obligations necessary to provide you
with the products or services, or where
we have your permission.
This will likely include the collection
of:
• your personal details (e.g. name, date
of birth)
• address details
• contact details (e.g. phone number,
email)
• special personal information* (e.g.
health information)
• financial information
• employment information
• information on how you use our
website(s) and products and services
Special personal information*
Data protection law defines some
personal information as “special
categories of data”. This includes
information about physical or mental
health, sexual life, religious beliefs,
race or ethnic origin, political
opinions, trade union membership or
biometric data. This information may be
necessary to collect when understanding
the reason for your financial
circumstances, or where it may help us
to provide a better service to you. For
example, a period of ill health could
have caused you to fall behind with your
regular payments to your creditors.
Where we need to collect and process
this type of data about you, by
providing this information to us you
give your explicit consent for us and
any other third party to process this
special data as set out in this privacy
policy, unless we have a legal
obligation to process this type of data.
Any personal information about you
relating to criminal convictions or
offences may only be used by us when
authorised by law.
Information about other people
If you provide personal information
about someone else, for example when a
joint application is made, you must do
so with the permission of the other
person. If you enter into a service
jointly with another person (for
example, a joint Debt Management Plan),
your personal information and any
information about the service provided
to you will be shared with the other
person.
We will use the personal information
about the other person in the ways as
described in this privacy policy.
2. How do we collect your personal
information?
We collect your information in a number
of ways.
• When you make an application or
enquiry to us either by phone, email,
our website, by a third party or by any
other means
• By adding reviews or interacting with
us using social media such as Twitter or
Facebook etc
• When we may need to obtain up to date
information about you to meet our legal
or regulatory obligations
• Where you have given permission for
your information to be provided to us
3. How we use your personal information
We can only use your personal
information where it falls into one or
more of the following categories:
1. 1. it is necessary to enter into or
fulfil a contract we have with you;
2. 2. you have provided your consent;
3. 3. we have a legal or regulatory
obligation to do so;
4. 4. it is necessary to carry out a
task which is in the public interest;
5. 5. it is necessary to protect your
vital interests; or
6. 6. it is in our legitimate interest
to do so and it is not against your
rights.
Initial Application/Advice
Where you make an application or enquiry
for one of our products or services
we’ll use your information to provide
you with appropriate information to
recommend a suitable debt solutions and
refer you to our chosen FCA regulated
debt solution provider. If you cannot
provide this information we may not be
able to progress with your application
or enquiry.
We may also use this information to
contact you about and process your
application, for example, sending you an
email, text message or letter to welcome
you to our services.
We will process the personal data we
collect about you for the purposes set
out below.
After you have made you initial
application/enquiry, if you also decide
to go ahead with any of the products or
services that we offer, the sections
below explain how we will also process
your data when we provide that
particular product(s) or service(s).
Debt Advice
If we give you Debt Advice, this will be
provided by Neroli Mortgages & Finance. The table
below specifically explains how and why
your personal data will be used so that
the services can be provided to you.
When providing you with debt advice we
collect and use your personal
information under the lawful basis of
our legitimate interest and is necessary
to enable us to provide you with the
best advice possible.
What personal data will we need to
collect? To be able to provide you with
Debt Advice we need to collect certain
categories of personal data. This will
include:
• • Contact details – so that we can
contact you about and process your
enquiry
• • The people you owe money to and your
property and assets – so we fully
understand your financial situation and
give you personalised advice that’s
tailored to you
• • Your Income and expenditure – - so
that we can accurately work out what you
can afford to pay towards your debts and
make sure the solution we recommend is
the right one for you
• • Personal circumstances – such as
your employment, living arrangements and
financial dependents, so that we can
understand and give you advice about how
each of the available debt solutions
could affect you
• • Special personal information – only
with your permission and where this is
relevant to your financial situation and
how a debt solution needs to work for
you, or where we have a legal right to
do so. With your permission, we may use
information from your credit file to
confirm certain information, including
about your lenders, balances, account
numbers, your account, address and
insolvency history and details of any
county court judgments (CCJ). Your
credit file data could be provided by
one or more of the following credit
reference agencies Callcredit Consumer
Ltd, Experian Limited, Equifax Limited.
Who will the data be shared with?
Our regulators , such as the Financial
Conduct Authority, the Information
Commissioner’s Office or any other
regulatory body or authority may request
certain information as part of
supervising us. We have a legal or
regulatory obligation to provide this.
How long will your data be stored for?
If you continue to be our customer and
we give you advice, we will keep a
record of your personal information to
ensure that we provide you with the best
service possible and where we’re
required to keep your data to meet our
legal and regulatory obligations. This
will normally be kept for at least 6
years, starting from the date when we
are no longer providing you with a
service. Telephone calls will be
retained for at least 6 years from the
date the call was made.
If you do not go ahead with any product
or service offered by the Group, your
personal information will normally be
deleted after 2 years (except for any
recorded telephone calls) unless we have
another reason to keep your personal
information, for example, if you have
given your consent to receive marketing
or promotional messages from us.
After this time, we will delete the
information or anonymise the data so
that it cannot be linked back to you.
Other Purposes for processing your
Personal Data
Websites and marketing
To help us understand you better and
provide you with information about other
products which may be suitable and
relevant, we will use your personal
information to create a profile of you
and your circumstances. This allows us
to provide more relevant, accurate and
tailored services to you. For example,
we may assess your income and
expenditure to determine whether you
would be eligible for a debt solution
through us. We believe we have a
legitimate interest to do this and that
it is not against your rights.
However, if you don’t want us to profile
your personal information this way, to
then better enable us to tailor any
marketing communications to you, you can
contact us to let us know that you wish
for your personal data not to be used in
this way.
Legal or Regulatory Obligation
We are required to process your personal
information where we have a legal or
regulatory obligation to do so, for
example, to adhere to anti-money
laundering or our regulatory
obligations.
Responding to complaints or enquiries
If you make an enquiry or complaint with
us, we will use your personal
information to investigate the complaint
and deal with your enquiry. We have a
legal and regulatory obligation to deal
with your complaint appropriately.
Internal Analysis
As part of our legitimate interest to
develop our business and our products we
will use your personal information to
assess our performance as a business and
for statistical analysis. We will use
your personal information to assess our
performance as a business and for
statistical analysis. We will use as
little personal data as we can to
achieve this
4. Who do we share your information
with?
We may also share your personal
information with the following
organisations:
• IT Service Providers who provide IT
platforms or other IT services
• Communication providers (e.g.
telephone line providers, and email and
text service providers)
These companies help us to provide our
services to you. We will have a contract
in place with any provider who directly
provides us with such direct services to
ensure that they comply with their data
protection obligations and ensure that
they have appropriate security measures
in place.
We may also share your personal
information where we have your consent
to do so or where we’re required to do
so under a legal or regulatory
obligation or court order, such as the
police, local authorities or the courts.
5. Fraud Prevention and Law Enforcement
Agencies
The personal information we have
collected from you may be shared with
law enforcement agencies and fraud
prevention agencies who will use it to
prevent fraud, money-laundering and
terrorist financing and to verify your
identity. If fraud is detected, you
could be refused certain services,
finance or employment. Further details
of how your information is used by us
and these fraud prevention agencies, and
your data protection rights, can be
found by contacting us or email us at
patrick@nerolimortgages.co.uk
6. Social Media
We may use publicly available social
media platforms to promote our services,
to provide updates and to share any news
and promotional updates. We may collect
personal information from these social
media platforms, for example, if you
post a message on our Facebook page. By
providing any of your information to us
through these platforms you should be
aware that:
• the social media web pages are
publicly available and you must not
provide any personal or sensitive
information on our pages that are
accessible to the public, such as your
account information. We may ask you for
your account information via a private
message to identify you and to service
any request you make; and
• each social media platform will
process any personal information you
provide through the platform and will be
processed in accordance with its own
privacy policy. The privacy policies are
available to view on each social media
platform.
7. Sharing your information outside of
the EEA
We will only share your personal
information outside the European
Economic Area (EEA), where we have your
consent; to comply with a legal
obligation; or where we work with a
business partner to enable us to provide
you with our services, and they process
information outside of the EEA.
If we do share your information outside
of the EEA we will make sure that it is
protected in the same way as if it was
being used in the EEA to ensure
appropriate safeguards are in place.
This may include putting in place a
contract with the business partner that
means they must protect the personal
data to the same standards as the EEA
(this may include defined model
clauses), or only share the data to a
business partner in a non-EEA country
where the privacy laws provide the same
protection as within the EEA or where
they are part of a Privacy Shield.
More information on this can be found on
the European Commission Justice Website.
8. Security
We take the protection of personal
information very seriously and we will
maintain appropriate measures to
maintain the confidentiality, integrity
and availability of the information you
have provided. Such measures include:
• Company security policies and
standards
• staff security awareness
• role based access controls to prevent
unauthorised access to the information
• encryption and anonymisation
technology
• anti-malware technologoies
• security monitoring
• security testing
• secure archiving and deletion
• compliance with industry regulation
and legislation
9. How we may contact you about the
products and services we provide to you
To help us keep you up to date about the
products and services that we provide to
you, and to ensure that you’re kept
fully informed, we may contact you by
letter, telephone, email, text message,
push notifications, social media or may
send you messages by any online customer
platforms or other electronic means.
If you start an application for a
product or service through us we will
attempt to contact you shortly after if
you were unable to complete your
application for whatever reason.
If you do not want to be contacted in a
particular way then you can request this
at any time, but if we are providing a
service to you, we do need to be able to
send you communications. This can often
be due to a legal or regulatory
requirement.
It is important that you keep us up to
date when you change your contact
details to ensure that we use your up to
date contact information.
10. Your Rights
Access to your personal information
You have the right to request from us a
copy of the personal information that we
may hold about you. This is often called
a “Data Subject Access Request”. You can
request this information by contacting
us as set out below. Before providing
this information to you or to another
person or company where you have
requested this personal information to
be sent to, we may ask for proof of
identity or ask sufficient questions to
enable us to locate the information and
ensure that we’re only providing it were
you have given your agreement.
Right to have your personal information
corrected
If the personal information we hold
about you is incorrect you have the
right to request that we correct this.
Right to stop or limit the processing of
the data we carry out
You may request that your personal
information is deleted or that we stop
processing the information if we’re no
longer entitled to process it. There may
be occasions where we are unable to
delete the data due to our legal or
regulatory obligations. We will however
discuss this with you if you request for
your information to be deleted.
Portability
In some cases you may be able to request
for your information to be provided to
you or to another company in a format
that can be processed electronically by
you or the other company. If you want to
request this you’ll need to contact us.
11. How long do we keep your personal
information for?
Whilst you continue to be our customer,
we will keep a record of your personal
information to ensure that we provide
you with the best service possible and
where we’re required to keep your
personal information to meet our legal
and regulatory obligations. The product
specific information above sets out how
long your personal information will
normally be kept for. Telephone calls
will be retained for at least 6 years
from the date the call was made.
If you do not go ahead with any product
or service offered by the Group, your
personal information will normally be
deleted after 2 years unless we have
another reason to keep your data, for
example, if you have given your consent
to receive marketing or promotional
messages from us.
12. How we may contact you about other
products or services that we may offer
If you have provided us with your
consent or where we are legally entitled
to do so, we may contact you to let you
know about other offers, products and
services that we provide which we think
you may be interested or that may
benefit you. We may do this through
post, emails, text messages, telephone,
push notifications, social media or
other electronic means.
You can easily let us know at any time
if you would no longer like to receive
these messages. You can contact us using
the details below, emailing us at
patrick@nerolimortgages.co.uk or
unsubscribing using the link or
information within the message.
13. Other types of advertising
When you visit our website or similar
websites Google may use our
advertisements promoting our products
and services which may appear on other
third party websites you visit across
the internet for remarketing purposes,
including cross-device remarketing.
Google and other third parties will use
cookies to tailor advertisements for
website users based on their previous
visit to our website. More information
about cookies can be found below.
We do not have any control over the
advertisements you see on other third
party websites however you can request
to opt out or customise these
advertisements by using the Google Ads
Preference Manager.
14. Recording Calls
We record any telephone calls you make
to us or we make to you or any other
third party. This is for training,
monitoring and quality purposes and to
meet our legal and regulatory
obligations. Some telephone calls may be
observed by staff for training and
development purposes.
We may keep a copy of the telephone
calls for up to 6 years from the date
the telephone call was made.
15. Contact us
If you have any questions or queries
about how we use your personal
information you can contact us or our
Data Protection Officer using the
address or email below:
Neroli Mortgages & Finance
1 Mill Lane
Westhoughton
BOLTON
BL5 2DN
Email: patrick@nerolimortgages.co.uk
If you are not happy with how we process
your personal information you should
contact us in the first instance. If
you’re not happy with how we have dealt
with your complaint you have the right
to lodge a complaint with the
Information Commissioner’s Office. You
can find their details on their website
at https://ico.org.uk.
16. Updates to this privacy policy
Any updates to this privacy policy will
be found on this page. If we make any
important or significant changes to the
way we may collect and use your personal
information we will endeavour to notify
you of this change.
17. Cookies
When using this website, some
information may be collected
automatically using 'cookies'. These are
small text files that facilitate the
processing of your data and enable us to
analyse how the website is being used.
Cookies can be temporary or permanent.
Temporary cookies form part of the
security process while you are using the
website; permanent cookies identify the
link you used to find our website, check
your browser so that we can make sure
that our website and services work well
with your computer and to help us
monitor traffic on our website.
Why are cookies used?
They help visitors. Cookies allow sites
to do things like provide personalised
content and remember their log-in
details and settings. You can turn them
off - this won't stop a website from
working, but it might mean it won't work
as well as it could, or that you have to
do the same thing more than once.
They help website owners. Cookies tell
website owners things like: what search
engine a visitor used to find the
website, how often they've visited it,
how long they've spent on it, and so on.