Privacy Policy

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Hera Financial understands your rights to privacy and has put in place systems and controls to ensure your rights are protected. 

Hera Financial undertakes to meet its obligations under the Data Protection Act 1998/2018, the Privacy and Electronic Communications Regulations 2003 and the EU General Data Protection Regulation (GDPR).

WHO WILL PROCESS YOUR PERSONAL INFORMATION?

Your personal information will be initially processed by Hera Financial Limited. Your personal data will be further processed by Brooklands Commercial Finance Limited our principal. 

WHY IS YOUR PERSONAL INFORMATION REQUIRED?

Your personal information is needed in order to assess your needs and make suitable recommendations. We will request information in regards to your assets, liabilities, bank accounts, ID’s amongst other. This information is also required in order to undertake money laundry checks and fraud in accordance with the rules set by the Financial Conduct authority (FCA) and other legal and regulatory bodies.

WHAT HAPPENS IF WE WANT TO PROCESS YOUR INFORMATION FOR OTHER REASONS?

If your information is required for any other purpose, we will inform you of that reason and use and ask your permission to do so. 

WHAT ARE THE CONSEQUENCES IF YOU DO NOT PROVIDE YOUR PERSONAL INFORMATION?

If your information is not provided to us, we may not be able to assist with your transaction. 

KEEPING YOUR INFORMATION UP TO DATE

As part of our services, we review our clients files in order to ensure their needs are fully covered, we will therefore communicate with you and request up to date information if required.

WILL YOUR INFORMATION BE SECURED?

We have secured systems in place to ensure your information is secured to prevent any possible alteration, disclosure or damage of such information. Our principal Brooklands Commercial Finance will also store copies of your information for compliance purposes.

WILL WE SHARE YOUR INFORMATION WITH ANYONE ELSE?

We may share your information with:

· Other member of staff for administrative purposes

· Banks, financial institutions and insurance companies

· The Financial Conduct Authority

· Credit referencing agencies

· Our compliance department

WILL WE TRANSFER YOUR INFORMATION OUTSIDE THE EUROPEAN UNION?

We will not 

WILL WE CONTACT YOU TO INFORM YOU OF SERVICES AND NEWS?

You may opt out at any time of our marketing list.

CONVERSATION RECORDINGS

We do record some conversations depending on the type of transaction we are discussing. You have the right to oppose to the recording. 

HOW LONG WILL WE KEEP YOUR INFORMATION FOR?

We follow the Financial Conduct Authority requirement in regards to information and how long it should be kept. We will not keep your information for longer than is necessary.

YOUR RIGHTS

You have the right to ask us not to process your personal data for marketing purposes. You can exercise the right at any time by contacting us by using the contact details below. Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Under Data Protection regulations individuals have a number of rights. These are as follows:

Right to be informed

Individuals have the right to be informed about the collection and use of their personal data.
We do this in our Privacy Policy.

Right of access

Individuals have the right to access their personal data and supplementary information. Individuals have the right to obtain:

· Confirmation that their data is being processed

· Access to their personal data

· Other supplementary information

We will not charge for initial requests to provide information, but may charge a fee if requests for further copies of the same information are made. We will provide the requested information to you within a month of receiving your request, unless the request is complex or numerous in which case we may extend this period by up to a further two months.

Where a request is manifestly unfounded or excessive, particularly if it is repetitive we may charge a fee to provide the information requested or refuse to respond. In these instances, we will inform you and explain our reason.

Before we proceed with any request, we will take steps to verify the identity of the person making the request.

Right to rectification

Individuals have the right to request that inaccurate personal data is rectified, or completed if it is incomplete. If you make such a request, we will takes steps to verify whether the data is accurate. Where we accept that the information is inaccurate, we will take steps to rectify it. If we believe that the information is accurate and does not require rectification we will notify you and explain our reason.

Right to erasure (known as the “Right to be forgotten”)
Individuals have the right to have their personal data erased if:

· the personal data is no longer necessary for the purpose which it was originally collected

- we rely upon consent as our lawful basis for holding the data and you      withdraws that consent

- we rely upon legitimate interests as our basis for processing and you objects      to the processing of your data and there is no overriding legitimate interest to continue this processing

- we are processing your personal data for direct marketing purposes and you      object to that processing

- we have processed your personal data unlawfully

- we have to do it to comply with a legal obligation

The right to erasure does not apply where processing is necessary for one of the following reasons:

· to exercise the right of freedom of expression and information

· to comply with a legal obligation

· for the performance of a task carried out in the public interest or in the exercise of official authority

· for archiving purposes in the public interest, scientific research historical research or statistical purposes where erasure is likely to render impossible or seriously impair the achievement of that processing

· for the establishment, exercise or defence of legal claims

As an example, we are regulated by the FCA and are required to retain records that demonstrate the advice we provide to our customers. These records contain personal information and data that enables us to formulate our advice. We will not remove or delete any personal information or data until such time as our regulatory obligation has been fulfilled in respect of each transaction or piece of advice.

Where a request is manifestly unfounded or excessive, particularly if it is repetitive we may charge a fee to remove the information or refuse to deal with the request. In these instances, we will inform you and explain our reason.

Right to restrict processing

Individuals have the right to restrict the processing of their personal data in certain circumstances. This means that an individual can limit the way that an organisation uses their data in the following circumstances:

· you contest the accuracy of your personal data and we are verifying its accuracy

· the data has been unlawfully processed and you oppose erasure, requesting restrictions instead

· we no longer need the personal data but you need us to keep it in order to establish, exercise or defend a legal claim

· you have objected to us processing your data and we are considering whether our legitimate grounds override your request

If you choose to exercise this right, we may not be able to proceed with a transaction or provide you with our advice. This may mean that we are unable to submit or progress an application with a lender or product provider. In these instances we will notify you of the impact your request.

Where a request is manifestly unfounded or excessive, particularly if it is repetitive we may charge a fee to restrict the information or refuse to deal with the request. In these instances, we will inform you and explain our reason.

Right to data portability

The right to data portability allows individuals to obtain and reuse their personal data for their own purposes across different services. The right to data portability only applies:

· to personal data you have provided to us

· where the processing is based on your consent or for the performance of a contract

· where processing is carried out by automated means

When responding to such a request, we would provide the personal data in a structured, commonly used and machine readable form, typically a .CSV file. We will provide this to you within one month of receiving your request. If your request is complex or requires more time, we may extend this period by up to a further two months. We will contact you and inform you why it will take longer.

Right to object

Individuals have the right to object to:

· Processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling)

· Direct marketing (including profiling)

· Processing for purposes of scientific/historical research and statistics.

If you exercise your right to object, we will stop processing your personal data unless: 

· There are compelling legitimate grounds for us to continue to process, which override your interests, rights and freedoms.

· The processing is for the establishment, exercise or defence of legal claims

You can exercise your right to object at the first point of contact with us or at any other time by contacting us a detailed below. If exercising your right to object affects or prevent us from being able to provide you with one or any of the services we offer we will inform you.

Access to information

The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.

To exercise any of your rights please see below the person you can contacted:
Data Protection Office:

Write to: International House, 24 Holborn Viaduct, London, EC1A 2BN
Telephone: 0203 488 0284

Email: Laura.rodriguez@herafinancial.co.uk

If you feel your complaint has not been resolved, you may also contact the regulator:

Write to: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Telephone: 0303 123 1113
Email: casework@ico.org.uk
Website: https://ico.org.uk/for-organisations/report-a-breach/