As the controller of your data, Capital Options Ltd complies with Data Protection laws in the United Kingdom and the EU General Data Protection Regulation (GDPR). This Privacy Policy details how Capital Options Ltd processes your personal data.

The personal data we collect about you

Personal data collected, used, stored and transferred by us may include:

• Identity Data including forenames, last name, maiden name, date of birth, gender, marital status, and username or similar identifier
• Contact Data including home address, email address and telephone numbers
• Financial Data including banks statements, payment card details, savings, debts such as loans and credit cards, income & expenditure, employer & pension benefits, and other assets
• Transaction Data including services you have received from us
• Technical Data including internet protocol (IP) address, 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 used to access the Capital Options Ltd website
• Profile and Usage Data including services provided to you, feedback and survey responses, and how you use our website, products and services
• Marketing and Communications Data including your preferences in receiving marketing from us and our business partners and your communication preferences

How do we collect your personal data?

Personal data is collected by us using the following methods:

• Direct interactions with an adviser in person, by post, phone, email or otherwise when sourcing and applying for finance products, processing Identity, contact and financial categories of personal data.
• Automated technologies or interactions with our website, by using the web enquiry form.

How do we use your personal data?

We use your personal data in the following circumstances and relying on the following lawful basis for processing:

Purpose/Activity

To initially engage with you to discuss your requirements

Purpose/Activity	Type(s) of Data	Lawful basis for processing
To initially engage with you to discuss your requirements	• Identity • Contact	Consent
To process and your deliver your application for a finance product	• Identity • Contact • Financial • Special Category • Transaction • Marketing & comms	Performance of a contract with you. Necessary for our legitimate interests
To manage our relationship with you including: • Notifying you about changes to our terms or privacy policy • Customer reviews/surveys • Re-engagement when existing products nears expiry	• Identity • Contact • Profile & usage • Marketing & comms	Performance of a contract with you. Necessary for our legitimate interests
To respond to case enquiries and input to & defend against complaints	• Identity • Contact • Profile & usage	To comply with a legal obligation. Necessary for our legitimate interests (to ensure that complaints can be responded to accurately)
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data	• Identity • Contact • Technical	To comply with a legal obligation. Necessary for our legitimate interests
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	• Identity • Contact • Profile & usage • Marketing & comms • Technical	Necessary for our legitimate interests
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	• Technical • Profile & usage	Necessary for our legitimate interests

Change of purpose

We will only use your personal data for the purposes stated above, unless we reasonably consider that we need to use it for another reason and it is compatible with the original purpose. Please contact us for an explanation as to how any new processing compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and 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.

Changes to our Privacy Notice

We keep our Privacy Notice under regular review and we will place any updates on this web page.

Marketing communications

You will also have the choice to opt-in to receiving other related marketing information and related products and services.

You can opt-out of receiving these types of communications at any time by contacting our Compliance team at garan@capitaloptions.co.uk or by clicking on the relevant link in email communications you receive from us.

However please note that your personal information will not be passed to any third-party organisation for marketing purposes.

Data Security

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. We also limit access to your personal data to only those Capital Options Ltd staff, appointed representatives, advisers, business partners and suppliers 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.

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.

For more information, please see our Information Security Policy.

Cookies

This site uses cookies – small text files that are placed on your machine to help the site provide a better user experience. In general, cookies are used to retain user preferences, store information for things like shopping baskets, and provide anonymised tracking data to third party applications like Google Analytics. As a rule, cookies will make your browsing experience better. However, you may prefer to disable cookies on this site and on others. The most effective way to do this is to disable cookies in your browser. We suggest consulting the Help section of your browser or taking a look at the About Cookies website which offers guidance for all modern browsers.

Who we disclose personal data to

Your personal data may be shared with third parties for the following purposes:

Lenders and finance product suppliers	To source and submit applications in order to perform/conclude the contract for the finance product application and the ongoing servicing of these contracts. A full list can be obtained by sending us an email at garan@capitaloptions.co.uk
Regulators	Sharing of information may be necessary to fulfil our legal obligations as a regulated profession, for example with the Financial Conduct Authority, to verify your identity and comply with anti-money laundering legislation and otherwise co-operate with law enforcement, legal proceedings or regulatory authorities
Others	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 way as set out in the privacy notice

The companies or organisations are required to ensure appropriate security measures are in place and maintain the confidentiality of your personal data, and to use your personal data only in the course of providing such services and in accordance Capital Options Ltd instructions.

How long is your personal data retained?

We only retain your personal data for as long as necessary for the performance of your contract with us.

Your legal rights regarding your personal data

If there is no other on-going client relationship your personal data will either be securely deleted or anonymised so that it can be used for statistical purposes but without any method of identifying you individually.

Please refer to our Subject Access Request document for your right to erasure.

Questions

If you have any questions or complaints relating to how we use your personal data, or if you wish to exercise any of your rights regarding your personal data, please contact the Information Security & Data Protection Manager by emailing garan@capitaloptions.co.uk or by writing to us. We will respond to you as soon as is possible. The length of time will depend on the type and complexity of the request, but you will receive a response no later than one month from the initial request.

What if I am still not satisfied?

If you are not satisfied with how Capital Options Ltd has responded to your enquiry, you have the right to complain to the Information Commissioner’s Office (ICO), who is the regulator for data protection in the United Kingdom.

Please call us on 0333 939 8405 if you have any queries.