TInt Website Privacy Policy
TInt (collectively referred to as “TInt”, “we”, “us” or “our” in this privacy notice) is the controller and responsible for your personal data.
TInt respects the privacy of every individual who conducts business with us.
Personal information about you may be collected when you visit our website either by the automatic operation of tracking devices (see the section on Cookies below) or when you contact us on the website. You can elect to not subscribe to this data collection.
This Privacy Policy aims to give you information on how TInt collects and processes your personal data through use of this website, including any data you may provide through the website when you purchase a product or service (from either us or one of our partners) or submit an enquiry.
This website is not intended for persons under the age of 18 and we do not knowingly collect data related to such persons.
It is important you read this Policy together with any other TInt data related to privacy or fair processing notice that we may provide on specific occasions when we are collecting or processing data about you so that you are fully aware of how and why we are using this data. This Policy supplements the other notices and is not intended to override them.
We have appointed Mark Winters as the TInt data protection officer (DPO) who is responsible for compliance overseeing questions in relation to this Policy.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Contact details
The Data Protection Officer
Tint Financial Services (Tint)
No 1 Royal Exchange London EC3v 3DG
Email address: mark.winters@tintfs.com
Telephone number: +44 (0) 207 101 4568
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We do, however, take our responsibilities around your data very seriously, and would therefore appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to this Policy and your duty to inform us of changes:
- This version was last updated on 10th March 2023 and we may change it at any time in the future, without notice in order to ensure it remains current and accurate.
- It is important that the data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party Links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you.
We do not control these third-party websites and are not responsible for their privacy statements.
When you leave our website, we encourage you to read the privacy notice of every website you visit.
What information 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).
We collect the following types of personal data:
- Identification data: including title, name, residential address, email address, phone number(s), date of birth, gender
- Financial Data: including bank account information and transactional information from your use of our services and data from 3rd parties such as Credit Reference Agencies
- Technical Data: including 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 our website and app
- Profile Data: including your username and password, preferences, feedback and survey responses
- Biometric data: this may include facial recognition and or similar data to ascertain your identity
- Usage Data: including information about how you use our website, products and services
- Marketing and Communications Data: including your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data, which will be used in accordance with this privacy notice.
We do not collect or process any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic data). Nor do we collect any information about criminal convictions and offences, unless required to do so by law.
At any time you may request access to, or amendment of, any of your personal information that we hold by emailing us at mark.winters@tintfs.com.
If you fail to provide personal data
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 goods or services). In this case, we may have to cancel a product or service you have with us: we will notify you if this is the case at the time.
What we use your information for
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to assess you for eligibility for our services, or those of our partners
- Where we need to perform the contract we are about to enter into or have entered into with you
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
- Where we need to comply with a legal or regulatory obligation
- Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending our and third-party direct marketing communications to you via post, email or telephone. You have the right to withdraw consent to marketing at any time by contacting us at Info@tintfs.com
- We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at Info@tintfs.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity | Type of Data | Lawful basis for processing including basis of legitimate interest |
---|---|---|
To register you as a new company using our or our partners’ services | i. Identity ii. Contact | i. Performance of a contract with you ii. Necessary to comply with a legal or regulatory obligation |
i. To assess whether our, or our partners’ services are appropriate, and the subsequent provision of these services | i. Identity ii. Contact iii. Financial iv. Transaction v. Marketing & Communications | i. Performance of a contract with you ii. Necessary to comply with a legal or regulatory obligation iii. Necessary for our legitimate interests |
To manage our relationship with you which may include notifying you about changes to our terms or privacy policy, asking you to leave a review or take a survey, or helping us recover debt | i. Identity ii. Contact iii. Profile iv. Marketing & Communications | i. Performance of a contract with you ii. Necessary to comply with a legal or regulatory obligation iii. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services, or to recover debts due to us) |
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | i. Identity ii. Contact iii. Technical | i. Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) ii. Necessary to comply with a legal or regulatory obligation |
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | i. Identity ii. Contact iii. Profile iv. Usage v. Marketing & Communications vi. Technical | Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | i. Technical ii. Usage | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
To make suggestions and recommendations to you about goods or services that may be of interest to you | i. Identity ii. Contact iii. Technical iv. Usage v. Profile | Necessary for our legitimate interests (to develop our products/services and grow our business) |
We will use the information held about you to ensure that content on the website is presented in the most effective manner for you and for your computer; notify you about changes to our service and the website; to monitor your use of the website; and to aggregate statistics about users, traffic patterns and related website information in an anonymous form.
If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis for processing your information.
How we protect your information
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. Please remember however that no transmission using our app or website can ever be guaranteed as secure, therefore, please note that we cannot guarantee the security of any personal information which you transfer via our app or websites.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
The use of cookies
Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your web browser (if you allow) that enables the sites or service providers’ systems to recognise your browser and capture and remember certain information. If you disable cookies part of our website may become inaccessible or not function properly.
We use cookies to compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. For information please see the Cookies Policy section.
Credit reference agencies and fraud prevention agencies.
We may search, use and share records held by domestic and international credit reference agencies and fraud prevention agencies, as well as our own internal records to:
- Confirm your identity and prevent fraud or money-laundering
- Check your credit history and income details for affordability
- Check details on applications for credit and credit related to other facilities
Credit reference agencies may check your details against any particulars on any database (public or otherwise) to which they have access in order to verify your identity.
Credit reference agencies keep a record of all searches, including those used to confirm your identity. Credit reference agencies also keep a record of whether or not your application is successful and whether you’ve missed any payments. Missing payments can negatively impact your credit rating so it is best to discuss this with us first before you make an application.
We may inform the credit reference agency if you miss or are late on any payments. The agency may then make your personal information available to other organisations so that they can make a decision about you or the account holder.
In addition to credit checks undertaken as referred to above, and before we provide services or financing to you, we undertake checks for the purposes of preventing fraud and money laundering and to verify your identity.
If we, or a fraud prevention agency, determine that you pose a fraud or money-laundering risk, we may refuse to provide the services or financing you have requested or we may stop providing existing services to you. A record of any fraud or money-laundering risk will be retained by the fraud prevention agency and may result in others refusing to provide services, financing or employment to you. We, and fraud prevention agencies, may also enable law enforcement agencies to access and use your personal data to investigate and prevent crime.
Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.
Marketing:
We aim to provide you with choices regarding uses of personal data, particularly around marketing.
Promotional offers from us:
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on which of our, or our partners’ products, are most appropriate for you, so as to ensure you receive the best service from us possible.
If you have not opted out of receiving marketing messages from us, you will receive communications from us either around already purchased services, or services we think would be appropriate for you.
Opting out:
You can ask us to stop sending you marketing messages and activity at any time by:
- logging onto your account and checking or unchecking relevant boxes to adjust your marketing preferences (where present on the website)
- or by following the opt-out links on any marketing message sent to you
- or by contacting us at Info@tintfs.com at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions. We will therefore continue to contact you regarding the products or services you are currently taking from us.
Disclosure of your personal data:
We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information, except in specific circumstances where we will share your data with partners, as follows:
- Third parties acting on our behalf, including our service providers and agents who help us manage our products and services;
- Credit referencing agencies to check your credit rating;
- Relevant government bodies, authorities and regulatory bodies in order to comply with our regulatory and reporting obligations;
- IT providers/hosted IT solution providers to enable us to provide our products and services to you;
- Debt collection agencies in the event we need to collect arrears from you or your company;
- Other financial service companies to help prevent, detect and prosecute unlawful acts and fraudulent behaviour;
- Our professional advisors (lawyers, accountants and consultants);
- Any other parties connected with your account e.g. guarantors, joint account holders, fellow company directors;
- Market research companies to assist us in improving our products and service delivery;
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same was as set out in this privacy policy; and
- Anyone else where we have your consent, you ask us to share it or where it is required by law.
We require all Third Parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We require third parties to respect the security of your data and to treat it in accordance with UK data protection legislation or such legislation as may apply where we operate globally and those restrictions are stricter.
Change of purpose:
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
International Transfers
Some of our suppliers who process your data in accordance with this privacy policy may be outside the UK and the European Economic Area (“EEA”). Whenever we transfer your personal data out of the UK or the EEA, we ensure a similar degree of protection is afforded to it by having a contract in place to make sure the recipient protects the data to the same standard as is required in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
Regulatory requirements dictate that we should retain your personal information for at least seven years following the termination of your customer relationship with us. However, in certain circumstances we will have to store this date for a longer period. We may in some circumstances anonymise your personal data (i.e. so that it can no longer be linked to you), for analytic purposes, in which case we may use this data indefinitely.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us by emailing at mark.winters@tintfs.com. You can find more information about your rights at the Information Commissioner’s website: www.ico.org.uk
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond:
We try to respond to all legitimate requests within one month.
Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Online Privacy Policy
This online privacy policy applies only to information collected through our website and not to information collected offline.
Your Consent:
By using our site, you consent to our privacy policy.
Glossary
CATEGORIES OF DATA
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes correspondence/billing address, email address and telephone numbers.
- Financial Data includes bank account and payment details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes 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 website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.