Last updated: 14 June 2020
Ponte Finance Limited is a company incorporated under the laws of England and Wales, with company number 12238417, with its registered address at IDEALondon, 69 Wilson Street, London, England, EC2A 2BB. Our ICO register number is A8690405.
What data do we collect?
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). When you visit our Site or correspond with us in person or by phone, live chat, e-mail or otherwise you may give us information that would be classed as personal data about you and others you are acting on behalf of. We may collect, use, store and transfer different kinds of personal data about you when you do so which we have grouped together follows:
Identity Data which includes your first name, last name, username or similar identifier, marital status, title, date of birth and gender. We may also collect, use, store and transfer details about your will, executors and beneficiaries dependant on the nature of the service that we supply to you;
Contact Data which includes your billing address, delivery address, home address, email address, telephone numbers and social media account details;
Financial Data which may include your bank account and/or payment card details;
Asset Data including details of the property held by the estate;
Transaction Data which includes details about payments to and from you and other details of services you have purchased from us;
Technical Data which includes your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Site, only if we have your prior consent to obtain this data;
Profile Data which includes your username and password for any accounts set up to access our services, purchases or orders made by you and feedback responses;
Usage Data which includes information about how you use our site, products and services, only if we have your prior consent to obtain this data;
Marketing and Communications Data which includes your preferences in receiving marketing from us and our third parties and your communication preferences, only if we have your prior consent to obtain this data; and,
We may collect Special Categories of Personal Data (as defined in the GDPR) about you. This may include details about your health, race or ethnicity, religious or philosophical beliefs, sex life or sexual orientation. We do not collect any information about criminal convictions and offences.
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with access to our will writing or funeral comparison services). In this case, we may have to cancel a service you have asked us to provide but we will notify you if this is the case at the time.
It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal data changes during your relationship with us.
How do we collect your data?
You directly provide Ponte with most of the data we collect. We collect data and process data when you:
Register on our Site or use any of our products or services;
Voluntarily complete a customer survey or provide feedback on our live chat on our site or via email; and,
Use or view our Site via your browser’s cookies (please see our separate Cookies Policy for more details on the Cookies we collect).
Ponte may also receive your data indirectly from the following sources:
Third parties or publicly available sources such as credit reference agencies, lenders, couriers, third party & partner websites
How will we use your data?
Ponte collects your data so that we can:
Initially engage with you to discuss your requirements including to confirm in which form we may communicate with you and re-engage, for example, when an existing product nears expiry
Process and deliver your application for a loan, to manage our relationship with you & improve our customer service such as customer reviews / surveys
Respond to case enquiries & defend against complaints and
Comply with our legal obligations, administer and protect our business and our Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data), to deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you, to use data analytics to improve our Site, products/services, marketing, customer relationships and experiences
If you agree, Ponte will share your data with our partner companies in order to provide you with products and services:
Selected third parties to assist in your application - Third parties may be lenders (for example, to source and submit applications), credit reference agencies, specialist brokers (if we are unable to service your request), solicitors & surveyors (for example, to check the progress of your application with whom you are interacting).
Licenced Credit Agencies – For the purposes of confirming your identity for fraud prevention; to perform a credit assessment & assess your eligibility as part of an application.
External suppliers – We may also share information with external supplier’s specialist IT system providers to facilitate the sourcing of products, to provide continuing advice, to inform you about relevant products and services, and to request feedback on customer service standards. It may also be necessary to share your personal information with non-affiliated companies who perform support services on our behalf including those that provide professional, legal or accounting advice to Ponte.
Online advertising platforms – We may use third party advertising platform providers such as Google to serve advertisements to you. These third parties may use information about your visits to this and other websites in order to provide you with advertising about products and services that may be of interest to you.
Sometimes there may be links on our Site to third parties who operate other websites (such as social media platforms) so that we can show you relevant advertisements while you are using those websites. This information will be protected so that you can only be identified if the third party already knows you – the information we provide only tells them that you are a Ponte user.
Regulators – Sharing of information may be necessary with the Regulators to fulfil our legal obligations as a regulated profession, for example with the Financial Conduct Authority or the Information Commissioner’s Office. Sharing of information to verify your identity and comply with Anti Money Laundering legislation, and otherwise cooperate with law enforcement, legal proceedings or regulatory authorities.
Others – If a third party introduced you to Ponte, we may pass some of your personal information back to that third party so they know whether or not you took out a credit agreement through us.
We rely on the following legal bases for processing your personal data:
consent: You have given your consent by creating a providing us with your data for us to process your data so that we can provide our services to you (for example, providing marketing services to you);
processing is necessary for our arrangement with you (for example to provide you with our services); and
it is in our legitimate interests (for example, operating and making our services available to you).
How do we store your data?
We are committed to safeguarding your information and use industry standard methods to ensure that all the information you provide is secure. We store this on secure servers so that it can only be viewed by authorised personnel. We will only collect personally identifiable information to the extent deemed reasonably necessary to serve our legitimate business purposes. If we do transfer it outside the EEA, the information may be processed by staff operating outside the EEA who work for us or one or more suppliers. Such staff may be engaged in, among other things, the fulfilment of services, the processing of the application details, and the provision of support services.
Ponte will keep your data for as long as we have a commercial relationship with you or to comply with our legal obligations, resolve disputes, and enforce any other agreements which we might be subject to. Once this time period has expired, if there is no other on-going relationship, your personal data will either be securely deleted or anonymised so that it can be used for statistical purposes but without any method of identifying you individually.
Ponte would like to send you information about products and services of ours that we think you might like, as well as those of our partner companies.
If you have agreed to receive marketing, you may always opt out at a later date.
You have the right at any time to stop Ponte from contacting you for marketing purposes.
If you no longer wish to be contacted for marketing purposes, please click here.
What are your data protection rights?
Ponte would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:
The right to access – You have the right to request Ponte for copies of your personal data.
The right to rectification – You have the right to request that Ponte correct any information you believe is inaccurate. You also have the right to request Ponte to complete the information you believe is incomplete.
The right to erasure – You have the right to request that Ponte erase your personal data, under certain conditions.
The right to restrict processing – You have the right to request that Ponte restrict the processing of your personal data, under certain conditions.
The right to object to processing – You have the right to object to Ponte’s processing of your personal data, under certain conditions.
The right to data portability – You have the right to request that Ponte transfer the data that we have collected to another organisation, or directly to you, under certain conditions.
If you make a request, we have one month to respond to you. For data protection reasons, before we respond to you we will need to verify your identity to ensure that you are who you say you are. If you would like to exercise any of these rights, please contact us at our email: email@example.com
Or write to us: Ponte Finance Limited, IDEALondon, 69 Wilson Street, London EC2A 2BB
Privacy policies of other websites
How to contact us
Email us at: firstname.lastname@example.org
Or write to us: Ponte Finance Limited, IDEALondon, 69 Wilson Street, London EC2A 2BB
How to contact the appropriate authority
Should you wish to report a complaint or if you feel that Ponte has not addressed your concern in a satisfactory manner, you may contact the Information Commissioner’s Office (ico.org.uk/livechat, or call on 0303 123 1113).