Privacy Policy
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Privacy Policy

1.
INTRODUCTION
1.1
In this Privacy Policy , "LBT", "we", "us", "our" means Lend & Borrow Trust Company Limited. "You" and "your" means visitors to our Website, customers and referrers.
1.2
We are committed to protecting and respecting your privacy. This policy (together with our Terms of Website Use ("Terms of Website Use") and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting www.lendborrowtrust.com or providing us with your personal information, you are accepting and consenting to the practices described in this policy. If you do not, you must cease use of the Website and any services provided by us.
1.3
The data controller is Lend & Borrow Trust Company Limited, a private limited company incorporated in England and Wales with its principal place of business at Advent House, Station Approach, Victoria, St. Austell, Cornwall PL26 8LG, United Kingdom.
1.4
The Website may, from time to time, contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that LBT does not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
2.
LAWFUL BASIS FOR PROCESSING
 
We collect and process your personal data based on one or more of the following reasons:
 
 
(a)
to perform a contract that you have entered into with us, or because it is necessary before entering into a contract;
 
 
(b)
to comply with legal obligations;
 
 
(c)
you have given consent to process your personal data for a specific purpose.
3.
INFORMATION LBT MAY COLLECT FROM YOU
 
We may collect and process the following data about you:
3.1
Information you give to LBT. You may give LBT information about you by filling in forms on the Website www.lendborrowtrust.com (the "Website") or by corresponding with us by phone, email or otherwise. This includes information you provide when you register to use the Website, subscribe to our services including newsletter subscription and when you report a problem with the Website. The information you give to us may include your name, address, email address and phone number, financial and bank account information, date of birth, identity and proof of residency documents.
3.2
Information LBT collects about you. With regard to each of your visits to the Website we may automatically collect the following information:
 
 
(a)
technical information, including the internet protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
 
 
(b)
information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from the Website (including date and time); things you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call LBT.
3.3
Information LBT receives from other sources. LBT may receive information about you from its group, which means its subsidiaries, its ultimate holding company and the holding company's subsidiaries, third parties including, for example, business partners, sub-contractors, market agencies, analytics providers, search information providers and credit reference agencies.
4.
COOKIES
4.1
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as provide information to us. The Website uses a number of cookies which are described in detail on our Cookies page.
4.2
LBT uses the following cookies:
 
4.2.1
Strictly necessary cookies. These are cookies that are required for the operation of the Website. You can block these cookies directly in your browser, but the Website will no longer work properly if you do this.
 
4.2.2
Analytics cookies. These cookies collect information about the use of the Website. By default, analytical cookies are disabled but you can actively enable them.
 
4.2.3
Marketing cookies. These cookies are used to display our Twitter feed on our news page. By default, these cookies are disabled, but you can actively enable them.
4.3
Please note that third parties may also use cookies, over which LBT has no control.
5.
USES MADE OF THE INFORMATION
5.1
LBT collects, stores and uses your information:
 
 
(a)
to carry out its obligations arising from any contracts entered into between you and LBT and to provide you with the information and services that you request from us;
 
 
(b)
to comply with our legal, regulatory and corporate governance regulations and good practice;
 
 
(c)
for investigations by regulatory bodies or in connection with legal proceedings and requests;
 
 
(d)
to verify your identity and other information you have provided to us including your bank account information and (if relevant) the identity of your business associates;
 
 
(e)
for the prevention and detection of fraud or other illegal activity;
 
 
(f)
for keeping and updating records, administration and processing of transactions;
 
 
(g)
to administer the Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
 
 
(h)
to investigate complaints;
 
 
(i)
to provide you and other Website users, with information about goods or services LBT feels may interest you or them. If you do not want LBT to use your data in this way, please contact us as set out below;
 
 
(j)
to notify you about changes to our service;
 
 
(k)
to ensure that content from the Website is presented in the most effective manner for you and for your computer;
 
 
(l)
to allow you to participate in interactive features of LBT's service, when you choose to do so;
 
 
(m)
as part of its efforts to keep the Website safe and secure.
5.2
LBT may combine information received from other sources with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information LBT receives).
5.3
LBT will also use any information held about you as required to comply with any legal, regulatory or professional obligations imposed on it.
6.
DISCLOSURE OF YOUR INFORMATION
6.1
LBT may share your personal information with any member of its group, which means its subsidiaries, its ultimate holding company and the holding company's subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
6.2
LBT may share your information with third parties including:
 
 
(a)
Business partners, suppliers and sub-contractors for the performance of any contract LBT enters into with you;
 
 
(b)
Its professional advisors;
 
 
(c)
Analytics and search engine providers that assist us in the improvement and optimisation of the Website.
6.3
LBT may disclose your personal information to third parties:
 
 
(a)
In the event that LBT sells or buys any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
 
 
(b)
If LBT or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
 
 
(c)
If LBT is under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply its Terms of Website Use and other agreements; or to protect the rights, property, or safety of LBT, its customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
7.
WHERE LBT STORES YOUR PERSONAL DATA
7.1
The data that LBT collects from you may be transferred to, and stored at, a destination outside the European Economic Area ('EEA'). It may also be processed by staff operating outside the EEA who work for LBT or for one of its suppliers. Such staff may be engaged in, among other things, the fulfilment of a transaction, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy and the conditions set out in the UK and EU General Data Protection Regulation ('GDPR').
7.2
All information you provide to us is securely stored on an encrypted storage server hosted by Amazon Web Services (AWS). Our Website is protected by an SSL certificate. Where LBT has given you (or where you have chosen) a password which enables you to access certain parts of the Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
7.3
We will keep all customer records and documents for 10 years or 5 years from the end of the customer relationship, after which it will be either erased from AWS or, if in paper format, destroyed.
7.4
The transmission of information via the internet is not completely secure. Although LBT has implemented reasonable measures to protect your personal data, it cannot guarantee the security of your data transmitted to the Website; any transmission is at your own risk. Once LBT has received your information, it will use strict procedures and security features to try to prevent unauthorised access.
8.
YOUR RIGHTS
 
You have the following rights with respect to your personal data:
 
 
(a)
The right to request access to any data held on your behalf;
 
 
(b)
The right to ask us not to process your personal data for marketing purposes;
 
 
(c)
The right to request we correct any personal data if it is found to be inaccurate or out of date;
 
 
(d)
The right to request your personal data is erased where it is no longer necessary for us to retain such data;
 
 
(e)
The right to transfer your personal data;
 
 
(f)
The right to make a complaint about how we use your data with the Information Commissioner’s Office (ICO) the ICO’s address is Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Helpline number is +44 (0) 303 123 1113
 
 
(g)
The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing.
9.
EXERCISING YOUR RIGHTS
 
You can exercise your rights or remove your consent at any time by emailing us at notices@lendborrowtrust.com, calling us on +44 (0) 1726 893017 or by writing to the Data Protection Lead at Lend & Borrow Trust Company Limited, Advent House, Station Approach, Victoria, St. Austell, Cornwall PL26 8LG, United Kingdom.

EEA residents - We value your privacy and your rights as a data subject and have therefore appointed Prighter as our privacy representative and your point of contact. Prighter gives you an easy way to exercise your privacy-related rights. To contact us via our representative Prighter or make use of your data subject rights, please visit: https://gdpr-rep.eu/q/19737934928.
10.
CHANGES TO LBT’S PRIVACY POLICY
 
Any changes LBT may make to this policy will be posted on the Website or otherwise notified to you.
11.
APPLICABLE LAW
 
This policy is governed by English law. You agree and consent to the courts of England having exclusive jurisdiction over any claim arising from or related to this policy.
12.
CONTACT
 
For further information about this policy please contact our Data Protection Lead Hazel Gordon at Lend & Borrow Trust Company Limited, Advent House, Station Approach, Victoria, St. Austell, Cornwall PL26 8LG, United Kingdom or use the following telephone or email address:
 
  • Telephone: +44 (0) 1726 893017
  • Email: notices@lendborrowtrust.com