1.2 LBT is committed to protecting and respecting your privacy. This policy (together with LBT’s 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 LBT collects from you, or that you provide to LBT, will be processed by LBT. Please read the following carefully to understand LBT’s views and practices regarding your personal data and how LBT 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 LBT.
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
LBT collects and processes your personal data based on one or more of the following reasons:
(a) to perform a contract that you have entered into with LBT, 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
LBT 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 LBT by phone, email or otherwise. This includes information you provide when you register to use the Website, subscribe to LBT’s service and when you report a problem with the Website. The information you give LBT may include your name, address, email address and phone number, financial and credit card information, date of birth, personal description and photograph.
3.2 Information LBT collects about you. With regard to each of your visits to the Website LBT 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 third parties including, for example, business partners, sub-contractors, market agencies, advertising networks, analytics providers, search information providers and credit reference agencies.
4.2 A cookie is a small file of letters and numbers that LBT stores on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
4.3 LBT uses the following cookies:
4.3.1 Strictly necessary cookies. These are cookies that are required for the operation of the Website. They include, for example, cookies that enable you to log into secure areas of the Website.
4.3.2 Analytical/performance cookies. They allow LBT to recognise and count the number of visitors and to see how visitors move around the Website when they are using it. This helps LBT to improve the way the Website works, for example, by ensuring that users are finding what they are looking for easily.
4.3.3 Functionality cookies. These are used to recognise you when you return to the Website. This enables LBT to personalise its content for you, greet you by name and remember your preferences (for example, your choice of language or region).
4.3.4 Targeting cookies. These cookies record your visit to the Website, the pages you have visited and the links you have followed. LBT will use this information to make the Website more relevant to your interests.
4.5 You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the Website.
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 LBT;
(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 LBT as set out below;
(j) to notify you about changes to LBT’s service;
(k) to ensure that content from the Website is presented in the most effective manner for you and for your computer;
(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 LBT and information LBT collects about you. LBT 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 its 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 them or you;
(b) Its professional advisors;
(c) Analytics and search engine providers that assist LBT 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 LBT 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
7.2 All information you provide to LBT is stored on its secure servers. LBT's 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. LBT asks you not to share a password with anyone.
7.3 The transmission of information via the internet is not completely secure. Although LBT will implement 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 LBT not to process your personal data for marketing purposes;
(c) The right to request LBT corrects 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 LBT to retain such data;
(e) The right to transfer your personal data;
(f) The right to make a complaint with the Information Commissioner’s Office;
(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 at any time by emailing us at firstname.lastname@example.org, 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.
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.
For further information about this policy please contact our Data Protection Lead 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: