Right Cash Privacy Policy

Right Cash Ltd Privacy Policy

We are a Consumer Credit Business licensed body the FCA Ref number 619665
We are registered with the ICO for Data Protection ref number A8269497

We do not require a Data Protection Officer because we are a small business with relatively small amounts of data stored. The key contact for data protection is Managing Director, Right Cash, Unit 2 Lakeview Stables, Lower St Clere, Sevenoaks, Kent, TN15 6NL
Under FCA SYSC requirements we have a senior manager who takes responsibility for data, their title is Managing Director.

Who’s the Data Controller?
For the purposes of data protection laws, Right Cash ltd is the “data controller” of all personal information that is collected, used and/or otherwise processed under this Privacy Policy.

Why are you collecting my information?
Any information you provide us, either using the internet, in-store or by any other means, is only collected for purposes which are reasonably necessary for, or directly related to, one or more of our business functions, products or activities. Products that require the collection of information include Pawnbroking loans, Buyback, Buys and Laybys.  Please note that third party’ brokers provide their own specific privacy notices.

These purposes include using and processing your information:

  • to provide you with the products and services they request and to monitor, evaluate and improve products and services;
  • to assist you with queries, resolve your complaints, or requests for access to information, or to manage any legal action involving us;
  • to manage customer relationships or accounts and perform other administrative and operational tasks (including risk management, systems development and testing, credit scoring, identity verification, staff training, collecting debts and market or customer satisfaction research);
  • to comply with our legal obligations;
  • to the extent otherwise permitted by law
  • to gather and aggregate information for statistical, prudential, actuarial and research purposes;
  • to develop and implement measures to detect or prevent unlawful activity, fraud, money laundering and credit loss; and
  • any or all of these processes may be automated.

If we undergo re-organisation or are sold to a third party, you agree that any information we hold about you may be transferred to that re-organised entity or third party.
If you choose not to provide information which we require for the above purposes, we may be unable to provide you with the goods and services you request from us.
We will not otherwise transfer, disclose, sell, distribute or lease your personal information to third parties unless we have your permission to do so or are otherwise required or permitted to do so by law.

What data do you collect?
We retain data and relevant information about our customers on the following basis;

Pawnbroking / Purchases / Buybacks– Legitimate Interest- We process – proof of name, address complying with AML requirements. We ask for I.D [eg passport or driving license/ utility bill] for all new customers and apply due diligence as per our AML policy.
Pawnbroking-Marketing soft opt in– We use a soft opt in for marketing. This means that unless the customer ticks the box on contract note 6 of their Pawn Contract we may send them relevant marketing e mails and contact them as per article 22 of the PECR (Privacy and Electronic Communications Regulations), on the basis that;
        we have obtained the contact details in the course of a pawn contract
         we are only marketing their own similar products or services; and
         we gave the person a simple opportunity to refuse or opt out of the marketing, both when first collecting the details and in every message after that.

Website

If you visit our website to read, browse or download information, our system may record the following information which is provided by your browser:

  • the date and time of your visit;
  • the type of browser and operating system you are using;
  • standard internet and website log information to understand our website visitors use;
  • your Internet Service Provider and top-level domain name (for example – .com, .gov, .au, .uk etc);
  • the address of any referring web site (for example – the previous web site you visited) and the website you visit after leaving our site; and
  • your computer’s IP (Internet Protocol) address (a number which is unique to the machine through which you are connected to the internet).

Website data is kept strictly confidential. It is used for internal research purposes and to provide goods and services that you request. It helps us monitor which sections of the site are most popular to give us a clear idea of what type of information and services to include on our site. It also informs us which members and subscribers are using the site so that we can customise the website information and presentation.

When you use one of our web sites, we may send you a “cookie” that gives you a unique identification number. A “cookie” is a packet of information that allows the server (the computer that houses the website) to identify and interact more effectively with your computer. A different identification number is sent each time you use one of our websites. These cookies may be Session cookies which only last until you close your browser, or they may be Persistent cookies which are stored longer term on your computer. Cookies do not identify individual users, although they may identify a user’s browser type and your Internet Service Provider (ISP).

You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. Please refer to your browser instructions or help screens to learn more about these functions. If you reject all cookies, you may not be able to use our websites or certain website functions may not work properly or at all.

Collection via Email
If you decide to complete an online form, we will collect the information that you enter into the online form and the IP address of your computer. If you cancel your application prior to submission, any information entered on the current screen which has not yet been submitted, will be automatically deleted. Information you have already submitted to us prior to you cancelling your application may be used to contact you about your application, after which it will be automatically deleted. The deletion referred to above will happen within a reasonable period of time but in any event, no longer than 30 business days.

Other activities

[For marketing through third parties and for CRAs (Credit Rating Assessments) we specifically request Consent of the customer, and they must opt in by signing our privacy statement ]

CCTV- is retained as part of the legitimate process of preventing crime. Footage is shared with the relevant authorities on request to help ongoing investigations.

 

Every customer is able to view privacy notice before any pawn or buyback transaction via a printed privacy notice on the Counter or on a contract. Since the basis for processing data is Legitimate Interest ( a pawn contract) the customer is not required to sign this.

Every contract has a Data Processing Clause (no. 6 on back of pawn contract)

This is a shortened version of the privacy notice but also has a soft opt in for marketing.

Your Rights

You may request details of personal information which we hold about you under the GDPR at any time (a Data Subject Access Request or DSAR). No fee will be required, although reasonable fees can be charged for manifestly unfounded or excessive requests. Your request will be responded to within one calendar month or any earlier time limit prescribed by law.

You have the following rights:

  • to make changes or corrections to your information to make sure it is accurate and up to date;
  • ask us to stop or limit our use or processing of your information or delete your information (we are not obliged to do this in relation to information we need as part of our contractual relationship or for compliance with other laws, such as taxation or accounting laws);
  • receive a copy of the information we hold about you;
  • withdraw consent you have previously provided;
  • transfer your information to a third party; and
  • the right to lodge a complaint about us to the UK Information Commissioner’s Office (https://ico.org.uk/) or the relevant authority in your country of work or residence.

Please note that we reserve the right to retain certain information for our own record-keeping (for example, to ensure that you do not receive marketing communications that you have opted-out of receiving) and to defend ourselves against any claims. We may also need to send you service-related communications relating to the goods or services that we provide to you even when you have requested not to receive marketing communications.

You can exercise these rights by contacting us using the contact information on this Privacy Policy. Please be aware that we may need you to provide additional information in order to process your request, such as to confirm your identity and/or to confirm what information you wish to access.

Acceptance and Changes to Privacy Policy

You acknowledge and accept that your use of Right Cash ltd’s website or of products which direct you to this Privacy Policy indicates your acceptance of our website terms of use and of the use and disclosure of information provided for under this Privacy Policy.
This is the current Privacy Policy. If we make changes to this Privacy Policy, we will revise the “Last Updated” date on the final page of this Privacy Policy. You accept that by doing this we have provided you with sufficient notice of any variation.If we make any changes that we think are material in the way we collect, use, and/or share your Personal Information, we will notify you by sending an email to the email address you most recently provided us in your account or registration (unless we do not have such an email address
We recommend that you check our website from time to time to inform yourself of any changes in this Privacy Policy or any of our other policies.

Contact Information
If you have question, want to exercise your rights or make a complaint, please contact us
If we cannot resolve your complaint, you may contact the Financial Ombudsman Service at:

Financial Ombudsman Service,

Exchange Tower,

London,

E14 9SR,

Tel: 08000 234 567.

You also have the right to complain to the Information Commissioner’s Office at

Wycliffe House,

Water Lane,

Wilmslow,

Cheshire,

SK9 5AF.

www.ico.org.uk.

We may contact you by post, email, SMS or telephone for the purposes of marketing our products and services; please tick the box in note 6 / 8 on your contract if you do not wish to receive such marketing.

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