Optima property Funding Limited are Property Finance Brokers based at 16 Upper Woburn Place London WC1H 0AF.
Company Registration No. 06602590
Financial Conduct Authority (FCA) Ref. No. 723931
Full members of the NACFB (national Association of Commercial Finance Brokers)
Registered with the Information Commissioner’s Office (ICO), Data Protection No. Z1494879
Registered Data Controller, Gary Walsh, Director
- Collection of data.
- Sharing of data.
- Marketing to you.
- Your rights and complaints procedure.
Collection of data:
The GDPR rules allow us to collect and use your data under one or more of the following categories:
- To fulfil a contract we have with you.
- Where we have a legal duty to do so.
- Where you consent to it.
- Where it is in the legitimate interest of both you and us to do so. A legitimate interest is where there is a business/commercial benefit.
You will instruct us, both verbally and in writing, to source appropriate finance for your property related projects. To enable us to fulfil this instruction we will need to collect (and share with lenders and associated professional services firms) both business data (which is not covered by GDPR) and personal data.
Listed below are examples (but not limited to) of categorises of data we may collect from you:
Names/Date of Birth/Address/Gender/Marital Status/Dependents/Occupation/Career History/Business History/Nationality/Telephone Numbers/E Mail Addresses/Web Site Addresses/Passport Number/Driving Licence Number/Bank Account Details/ Income & Expenditure/Assets & Liabilities/Financial Accounts/ HMRC Tax Data/Credit Reference Agency Data.
We collect data from a number of sources including (but not limited to) the following:
Telephone/E Mail Correspondence/Written Correspondence/ Web Site Data Capture Forms/ Website Cookies/Internet Marketing/Direct Mail Marketing/ Social Media Marketing/Your Website/Your Social Media Pages/Finance Application Forms/Companies House/Land Registry/Local Authority Planning Portals/Other Data Collection Platforms/Credit Reference Agencies/ Third Party Introducers/Your Professional Advisors (e.g. Solicitor, Accountant).
Sharing of Data:
Who will we share your data with?
We may require to share your data with some or all (but not limited to) of the following;
- Our employees and officers.
- Lenders and Investors.
- Professional Services Firms relevant to a specific funding project (e.g. RICS Valuers, Project Monitoring Surveyors).
- Other Finance Brokers (if required to source appropriate funding).
- Solicitors acting for a Lender or Investor.
- Your Solicitor.
- Your Accountant.
- Credit reference Agencies.
- Fraud Prevention Agencies.
- Third party organisations, if we are legally bound to.
- Third parties that introduce you to us.
- Third parties that we introduce to you.
- Third parties that you request us to share your data with.
We will never share your data to a third party unless it is specifically relates to sourcing finding for a project or as a general introduction of you by us to them.
We will never sell your data to a third party.
We will not share your data outside of the E.E.A, unless we are legally bound to do so.
Marketing to you:
We may periodically keep you informed of market information that we consider to be of use to you. This may include (but not be limited to) finance product updates, case studies, industry news. The information supplied will generally have been compiled by us but may also include sharing of information provided by third parties, e.g. articles from industry publications.
We may provide market information by one or more of the following mediums:
- E Mail.
- Direct Mail.
We communicate market information to you under the GDPR legitimate interest category.
You may opt out of receiving market information from any or all of these mediums and we will remove you from our database.
You may request to opt out as follows:
- E Mail – by clicking on Unsubscribe.
- Direct Mail – by sending an e mail to the Data Controller (details in first paragraph, above).
- SMS – by following the STOP instructions.
- Telephone – by sending an e mail to the Data Controller (details in first paragraph above), or making a verbal request over the phone.
Storage and security of data:
Where and how will we store your data?
- Your data may be held in (but not limited to) one or more of the following formats:
- Paper in a file in your name, or the name of your business.
- CRM (Customer Relationship Management) software– on a PC hard drive.
- CRM (Customer Relationship Management) software– in a cloud.
- In a folder in your name within My Documents – on a PC hard drive.
- In a folder in your name within My Documents – in a cloud.
- In Microsoft Office Applications (Outlook, Word, Excel etc.) in a cloud (Office 365).
- In E Mail Marketing Database software – in a cloud
- Data held in cloud format may be accessed via various hardware devices including PC Desktop, lap top, mobile phone, tablet.
- Paper records will be stored in secure locked cabinets within an office which can only accessed by the Data controller, or authorised persons. The office and cabinets are locked when the office is vacated.
- Access to hardware devices is password protected.
- Data held in a cloud is encrypted and held on secure severs within the E.E.A
- All electronic data is backed up daily and saved by a third party data storage facility in a server located in the E.E.A
How long will we retain your data?
We are required to retain data for a number of reasons including (but not limited to) Financial Conduct Authority (FCA) regulations, under the term of our Professional Indemnity Insurance, UK Money Laundering regulations, HMRC guidelines, NACFB guidelines and best practices for treating customers fairly, record keeping and complaints handling.
How long we keep your data depends upon our relationship with you which we define as follows:
- We classify you as a client if we have engaged with and you become a client of a lender (i.e. borrow from the lender) we introduce you to. You will have agreed to and signed both our Terms of Business and GDPR consent documentation.
- As a client, we are required to keep your records indefinitely.
- We classify you as a prospect if we have engaged with you and have introduced you to a lender(s) but you have not become a client (as defined above). You will have agreed to and signed both our Terms of Business and GDPR consent documentation.
- As a prospect we are required to keep your data for a period of 6 years.
- We classify you as a Contact if we have engaged with you but we have not introduced you to a lender.
- As a Contact, we are required to keep your data for a period of 3 years.
Your rights and complaint procedure
As a Data Subject, you have the following rights:
- The right to request a copy of all personal data we hold about you.
- The right to request correction of personal data we hold about you if it incorrect or incomplete.
- The right to deletion of personal data we hold about you where there is no compelling reason for us to continue to hold it.
- The right to restrict our data processing activities.
- The right to request transfer of your personal data to a third party.
- The right to file a complaint with the ICO.
Should you wish to trigger any of your rights, or make a complaint please contact Gary Walsh, Data Controller at firstname.lastname@example.org
The ICO (Information Commissioner’s Office) contact details are:
- Commissioner’s Office, Wycliffe House, Water lane, Wilmslow, Cheshire SK9 5AF