We are Invictus

” i thank what ever gods may be
for my unconquerable soul”

Customer Privacy Notice

Why should you read this document? During the course of dealing with us, we will ask you to provide detailed personal information relating to your existing circumstances, your financial situation and, in some cases, your health and family health history (“Your Personal Data”). This document is important as it explains what we will do with Your Personal Data, and the various rights you have in relation to Your Personal Data.

What do we mean by “Your Personal Data”? Your Personal Data means any information that describes or relates to your personal circumstances.   Your Personal Data may identify you directly, for example your name, address, date of birth, National Insurance number. Your Personal Data may also identify you indirectly, for example, your employment situation, your physical and mental health history, or any other information that could be associated with your cultural or social identity.  In the context of providing you with assistance in relation to your finance requirements Your Personal Data may include:

  • title, names, date of birth, gender, nationality, civil/marital status, contact details, addresses and documents that are necessary to verify your identity
  • employment and remuneration information, (including salary/bonus schemes/overtime/sick pay/other benefits), employment history
  • bank account details, tax information, loans and credit commitments, personal credit history, sources of income and expenditure, family circumstances and details of dependants
  • any pre-existing finance products and the terms and conditions relating to these

The basis upon which our Firm will deal with Your Personal Data When we speak with you about your finance requirements we do so on the basis that both parties are entering a contract for the supply of services.  In order to perform that contract, and to arrange the products you require, we have the right to use Your Personal Data for the purposes detailed below.

Alternatively, either in the course of initial discussions with you or when the contract between us has come to an end for whatever reason, we have the right to use Your Personal Data provided it is in our legitimate business interest to do so and your rights are not affected.  For example, we may need to respond to requests from lenders and our Compliance Service Provider relating to the advice we have given to you, or to make contact with you to seek feedback on the service you received. On occasion, we will use Your Personal data for contractual responsibilities we may owe our regulator The Financial Conduct Authority, or for wider compliance with any legal or regulatory obligation.  In such circumstances, we would be processing Your Personal Data in order to meet a legal, compliance or other regulatory obligation to which we are subject.

How do we collect Your Personal Data? We will collect and record Your Personal Data from a variety of sources, but mainly directly from you. You will usually provide information during the course of our initial meetings or conversations to establish your circumstances, needs and preferences in relation to finance.  You will provide information to us verbally and in writing, including email.  We may also obtain information from third parties, e.g. credit checks, information from your employer, searches of information in the public domain such as the Electoral Register.  If we use technology solutions to assist in the collection of Your Personal Data for example software that is able to verify your credit status. We will only do this if we have your consent for us or our nominated processor to access your information in this manner. Consent is not required for electronic ID checks, but we will inform you of how such software operates and the purpose for which it is used.

What happens to Your Personal Data when it is disclosed to us? In the course of handling Your Personal Data, we will:

  • record and store Your Personal Data in our paper files, mobile devices and on our computer systems (websites, email, hard drives, and cloud facilities). This information can only be accessed by employees and consultants within our Firm and only when it is necessary to provide our service to you or for administrative tasks associated with, or incidental, to that service
  • submit Your Personal Data to commercial lenders, both in paper form and online via secure portals. The provision of this information to third parties is essential to allow us to progress any enquiry or application made on your behalf and to deal with any additional questions or administrative issues that lenders and providers may raise
  • use Your Personal Data for the purpose of responding to queries you may have in relation to any finance agreement you may take out, or to inform you of any developments in relation to those products and/or polices of which we might become aware

Sharing Your Personal Data From time to time Your Personal Data will be shared with:

  • finance Lenders
  • third parties who we believe will be able to assist us with your enquiry or application, or who are able to support your needs as identified. These third parties will include but may not be limited to: compliance advisors, product specialists, providers of legal services such as conveyancing, surveyors and valuers (in each case where we believe this to be required due to your particular circumstances)

In each case, your Personal Data will only be shared for the purposes set out in this notice, i.e. to progress your finance enquiry and to provide you with our professional services.  Please note that this sharing of Your Personal Data does not entitle such third parties to send you marketing or promotional messages: it is shared to ensure we can adequately fulfil our responsibilities to you, and as otherwise set out in this notice. We do not envisage that the performance by us of our service will involve Your Personal Data being transferred outside of the European Economic Area.

Security and retention of Your Personal Data Your privacy is important to us and we will keep Your Personal Data secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard Your Personal Data against it being accessed unlawfully or maliciously by a third party. We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us, such as not sending confidential information over unprotected email, ensuring email attachments are password protected or encrypted and only using secure methods of postage when original documentation is being sent to us. Your Personal Data will be retained by us either electronically or in paper format for a minimum of six years, or, in instances where we have legal right to such information, we will retain records indefinitely.

Your rights in relation to Your Personal Data You can:

  • request copies of Your Personal Data that is under our control
  • ask us to further explain how we use Your Personal Data
  • ask us to correct, delete, restrict or stop using Your Personal Data (details as to the extent to which we can do this will be provided at the time of any such request)
  • ask us to send an electronic copy of Your Personal Data to another organisation should you wish
  • change the basis of any consent you may have provided to enable us to market to you in the future (including withdrawing such consent in its entirety)

How to make contact with our Firm in relation to the use of Your Personal Data If you have any questions or comments about this document, or wish to make contact in order to exercise any of your rights set out within it please contact our Data Protection Officer, Invictus Capital Finance, Unit 1, Twyford Road Industrial Estate, Bishops Stortford,CM23 3YT, or e-mail proposals@invictuscapital.finance.  If we feel we have a legal right not to deal with your request, or to action, it in different way than you have requested, we will inform you of this at the time If you become aware of any unauthorised disclosure of Your Personal Data, you should make contact with us as soon as possible on so that we may investigate and fulfil our regulatory obligations. If you have any concerns or complaints as to how we have handled Your Personal Data you may lodge a complaint with the UK’s data protection regulator, ICO, via their website https://ico.org.uk/global/contact-us/ or by writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.