Provira Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits www.provira.com (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
- Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
|“Cookie”||means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 14, below; and|
|“DPA”||means the Data Protection Act 2018 the UK General Data Protection Regulation and all other UK legislation governing the acquisition and use of personal information;|
|“FCA”||means the Financial Conduct Authority;|
|“ICO”||means the Information Commissioner’s Office.|
2. Information About Us
Our Site is operated by Provira Limited, a UK company registered in England under company number 12938037. We are registered with the ICO as a data controller with registration number ZA809102. Our registered address is 50 Weymouth Mews, London, W1G 7EH.
We are an authorised representative of Funeral Safe Ltd (the Lender), which is authorised and regulated by the FCA for lending activities with FCA reference number 765110. We act as a consumer credit broker and we introduce customers to the Lender for the purposes of obtaining probate advances.
3. What Does This Policy Cover?
4. What is Personal Data?
Personal data is defined by the DPA as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
5. What Are My Rights?
Under the DPA, you have the following rights, which we will always work to uphold:
a) The right to be informed about our collection and use of your personal data.
b) The right to access the personal data we hold about you. See section 13 for information on how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have.
e) The right to restrict (i.e. prevent) our processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) Where we process your personal data on the basis of your consent, you have the right to withdraw this consent at any time. Also, where you have agreed to receive direct marketing, you can change your mind at any time by contacting us or following the directions in each marketing message. Please allow a few days for us to action your request.
h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
i) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in section 15.
6. What Data Do We Collect?
- Basic personal information such as your name, title, date of birth and/or age;
- Contact details such as your email address, postal address and telephone number;
- Information about the probate advance you wish to obtain, such as the amount you wish to borrow;
- Information about the inheritance estate you are due to receive, including your relationship with the deceased;
- Information from credit reference agencies or fraud prevention agencies;
- Information about your visits to Our Site, and the device used to access the Site;
- Other personal details that you choose to provide to us.
We may collect such personal data from third parties, such as:
- The Lender;
- Credit reference agencies and fraud prevention agencies; and
- Search engines and other websites via which you access Our Site.
7. How Do You Use My Personal Data?
Under the DPA, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data will be used for one of the following purposes:
- Providing and managing our relationship with you;
- Providing the application process, and assistance with completing this, for a probate advance from the Lender;
- Referring you to the Lender, and providing your data to them so that they may assess your suitability and considering entering into an agreement with you;
- To prevent fraud and anti-money laundering;
- Providing and managing your access to Our Site;
- Personalising and tailoring your experience on Our Site;
- Communicating with you about our services and your application to the Lender, or to notify you of changes to our service.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email with information, news, and offers on our products/services. You will not be sent any unlawful marketing or spam. You will always have the opportunity to opt-out or receiving such information.
Third parties whose content may appear on Our Site from time to time may use third-party Cookies. Please refer to section 14 below for more information on Cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.
8. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
- Where a loan is successfully issued, we will anonymise your personal data 5 years from the date the loan is settled;
- Where no loan is issued, we will anonymise your personal data 5 years from the application date.
- Where you have consented to us using your details for direct marketing, we will keep such data for 5 years from the date of your latest consent or until you notify us otherwise and withdraw your consent.
9. How and Where Do You Store or Transfer My Personal Data?
We will only store or transfer your personal data in the UK. This means that it will be fully protected under the DPA.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
- We use secure socket layer (SSL) encryption technology and limit employee access on a need-to-know basis;
- We store data in encrypted form on computers and control access via secure web pages;
- We employ firewalls and other security technologies to protect our servers from external attack;
- Our security systems meet or exceed industry standards and we constantly monitor technologies to ensure our systems evolve as required. We also test our systems regularly to make sure our security mechanisms are up to date.
10. Do You Share My Personal Data?
We may disclose your personal information to certain third parties in the following circumstances:
- To enable the Lender to make a lending decision (where you wish to apply for a probate advance) and in order to enter into a loan agreement with you;
- If Provira, or substantially all of its assets, are acquired by a third party;
- To any party to which we transfer our rights and duties;
- To credit reference agencies and fraud prevention agencies;
- To professional service providers, such as lawyers, for the purpose of receiving advice;
- If we are legally required to share your personal data in respect of legal proceedings, or to comply with our legal obligations, a court order, or the instructions of a governmental authority;
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s legal obligations.
11. How Can I Control My Personal Data?
11.1 In addition to your rights under the DPA, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details and by otherwise contacting us).
11.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
12. Can I Withhold Information?
You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
13. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request without undue delay and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
By using Our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on Our Site for the purposes of analytics. For more details, please refer to the table below. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
All Cookies used by and on Our Site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. You will be given the opportunity to allow only first-party Cookies and block third-party Cookies.
Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
The following first-party Cookies may be placed on your computer or device:
|Name of Cookie||Purpose||Strictly Necessary|
and the following third-party Cookies may be placed on your computer or device:
|Name of Cookie||Provider||Purpose|
|Google Analytics||Site Analytics|
Our Site uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Site is used. This, in turn, enables us to improve Our Site and the products and or services offered through it.
The analytics service(s) used by Our Site use(s) Cookies to gather the required information. You do not have to allow us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable us to continually improve Our Site, making it a better and more useful experience for you.
In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
15. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Bradley Shirras):
Email address: [email protected]
Telephone number: 0 203 813 6400.
Postal Address: 50 Weymouth Mews, W1G 7EH, London, UK.
You also have the right to complain to the ICO at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF; telephone number: 0303 123 1113.
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business operations.