TREASURE TOWER LIMITED
Treasure Tower Limited is strongly committed to protecting personal data.
This privacy statement describes why and how we collect and use personal data and provides information about individuals’ rights. It applies to personal data provided to us, both by individuals themselves or by others.
We may use personal data provided to us for any of the purposes described in this privacy statement or as otherwise stated at the point of collection.
Personal data is any information relating to an identified or identifiable living person.
Rico Pieroni & Treasure Tower Limited collection, lawful basis of processing, use, disclosure, and retention periods for each purpose may differ. When collecting and using personal data, our policy is to be transparent about why and how we process personal data. To find out more about our specific processing activities, please go to the relevant sections of this statement.
What information do we gather?
To be able to provide you with the best service possible, we will need to gather certain personal information from you when you contact or interact with us. We will also use this information for security, identification and verification purposes. We will only ever collect information that helps us provide our services to you.
We will keep your information for as long as is needed and only for the following purposes:
- legitimate business activities
- statutory or legal obligations
- MLR compliance and regulatory purposes When you make an enquiry with us about any of the services we offer, we’ll ask you to provide some contact This may include some or all of the following:
- full name
- current home address
- date of birth
- landline and mobile phone number
- email address
If you give personal information about someone else (such as a joint applicant), you must have their permission to do so.
If there is a change to any of your personal information and you notify us, we will update your records.
Where we have introduced you to another organisation, we are unable to update your details with them and you will need to contact them personally to notify them of these changes.
If you give personal information about someone else (such as a joint applicant), you must have their permission to do so. Once we have gathered information from you and you subsequently make contact with us, we will use specific pieces of your information to help us identify you and verify that we are dealing with the right person.
Throughout your relationship with us, we will hold your personal information securely. This will include any information provided by you or others (for example, if you’re making a joint application) in various ways, including (but not limited to):
in applications, emails and letters, during telephone calls and conversations in our offices, when registering for services, in customer surveys, when using our website, and during fact find reviews and interviews.
Sometimes we may pass your information on to third parties such as Estate Agents, Solicitors and Financial Advisors/Brokers. When we do this it is on the understanding that they care for your information as carefully as we do, keep it confidential and use it only for the agreed purposes above.
Using our website
Please remember, that whilst we have security measures in place to protect your personal information, the internet is not 100% secure. We cannot therefore guarantee the security of any information you send us online. We are also not responsible for any loss or damage you or others may suffer as a result of losing the confidentiality of your information.
How do we use your personal information?
We use your personal information in various ways. We will use it to confirm that you are who you say you are when you contact us. We will use it to verify your name by accepting certified copies of your personal ID and also will confirm your address by recently utility bills copies and/or credit cards/bank statements.
The law requires us to comply with a number of regulations. Where necessary, we use your personal data to allow us to fulfil our legal and regulatory requirements.
If we have your consent, we will use your information to identify other products and services we offer that we believe you might want to know about. However, we usually only contact you with information that we think may of benefit to you.
Resolving complaints and disputes
If we are informed that you may be dissatisfied with the service or advice we have provided you, we will use the information we have about you to help us resolve things for you.
Opting Out: If you do not wish to receive information from us as explained above, you can update your preferences by contacting us as below:
- In writing via email: firstname.lastname@example.org
- You can opt out from our mailing list by clicking on the unsubscribe link button at the bottom of each promotion email.
If we ever have to use your personal information for any purposes that we haven’t described in this policy, you’ll hear from us. We’ll let you know exactly what we’ll use it for before we go any further and, where appropriate, obtain your consent.
Please note this policy does not cover companies, services or applications that we do not own or control, or people that we do not employ or manage, including (without limitation) third party websites or applications (e.g. from “social media” platforms such as Facebook or Twitter). Also, it does not cover certain pages and services provided which are hosted, managed and operated by other parties. These services, applications and third parties may have their own privacy policies and/or terms and conditions of use, which we recommend you read before using any such services.
These third parties and services are wholly independent of us and are solely responsible for all aspects of their relationship with you and any use you may make of such services.
What is the legal basis for handling personal information?
Data protection laws require that, to process your personal data, we must meet at least one prescribed basis for it. We rely on the following basis for the activities we carry out.
- Helping to prevent and detect crime such as fraud and money laundering
- Complying with legal and regulatory requirements
- Ongoing service
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.
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.
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.
How do we keep your personal information secure?
At Treasure Tower Ltd we understand how important it is to keep your personal information secure. We use a variety of technologies and procedures to protect your private data from being accessed, used or disclosed in any way it shouldn’t be.
The security arrangements we’ve put in place include physical, organisational, and technological measures and controls.
Together, they help to protect the personal information we hold from risks.
How long do we keep your personal information for?
We’ll keep your personal information securely stored for as long as we need it to provide you with the services you want from us.
We also keep it to comply with our legal and regulatory obligations, as also to help us to resolve any issues or disputes that may arise.
Depending on what information we hold and what products or services you are signed up to, we may need to retain certain details for longer than others.
In every case, we regularly reassess whether we need to hold your personal information and securely
dispose of any information that we no longer need.
Changes to this privacy statement
We recognise that transparency is an ongoing responsibility and will therefore keep this privacy statement under regular review. This privacy statement was last updated on 17 June 2020.