Wallet Warriors is a trading style of Fountain Finances Limited.
This privacy policy sets out how Fountain Finances Limited (FFL), collects, uses and protects your information when you use this website or our services, in accordance with the Data Protection Act 2018 and the General Data Protection Regulation 2016 (GDPR).
FFL is the controller and is responsible for your personal data. We are committed to ensuring that your privacy is protected. By using our website, you may be providing us with some of your personal information and we want to make sure that we do not use your data in a way that you would not expect. FFL assure you that your personal information will only be used in accordance with this privacy policy and in compliance with the latest privacy regulations.
FFL may change this policy in future by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 15/06/2023.
Personal Information We Collect
Personal information is any information about an individual from which that person can be identified. It does not include data which has been anonymised.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Contact information: Name, current and previous addresses (including postal, email and IP addresses) and telephone numbers.
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Financial Data: includes information on your financial circumstances, the lenders or financial institutions used by you, the financial products you have taken out and the details and status of those financial products.
- Usage Data includes information about how you use our website, products and services. This may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Special Category Data: We will only process special category data where you have provided this to us and given your explicit consent to store it or we have a legal/regulatory obligation to. This includes race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.
This list may not include all the information we require when providing our service/s. The information we ask you for will relate to your specific enquiry and will only consist of the information we need to carry out our service. If you contact us other than via our website, we may keep a record of that correspondence and a copy of call recordings.
Method of collection
- Direct interactions: By you filling in forms on our website or social media or by corresponding with us by post, phone, email or otherwise.
- Third parties or public sources: We may receive information about you from various reputable third-party lead providers, from our regulators or from publicly available data. We will always inform you where we have obtained your information from if requested by you.
The basis on which we process your information
The legal grounds for processing your personal information depend upon the nature of our relationship with you and the context of processing and are as follows:
- Processing is necessary for the performance of a contract with you, or to take steps prior to entering into a contract with you.
- Processing is necessary for the purposes of your legitimate interests or our legitimate interests, where your fundamental rights and interests do not override those interests. In order to determine this we shall undertake a Legitimate Interests Assessment and balancing test.
- Processing is necessary for compliance with mandatory legal or regulatory obligations to which we are subject
- Processing is undertaken after you have given us your express consent.
What we use your personal information for
| We collect/store or use your information to… | Legal basis |
| provide the service you have requested | Contract |
| send to our partner claims management companies, financial advice firms, solicitors/law firms or insolvency firms | Consent |
| send to our service provider/contractor partners | Contract and/or Legitimate Interests |
| to enforce or apply our terms and conditions and/or other agreements | Legitimate Interests |
| send you information or marketing about our products and services | Legitimate Interests and/or Consent |
| provide annual statistics to our regulator | Legal obligation |
| resolve complaints against us or the establishment, exercise or defence of legal claims | Legitimate Interests and/or Legal Obligation |
| gather feedback to enable us to improve our website, products and services | Legitimate Interests |
| verify your identity where we receive requests to access or change the information we hold about you | Legal Obligation |
| maintain our accounts and records | Legal Obligation |
| comply with legal and regulatory obligations | Legal Obligation |
| research and analyse trends to better understand how users are using our website and services in order to improve them | Legitimate Interests |
| inform you about changes in our services and important service related notices, such as security and fraud issues | Legal Obligation |
| maintaining insurance coverage, managing risks, or obtaining professional advice | Legitimate interests and/or Legal Obligation |
Providing your personal data to others
We may disclose your data to one or more of our selected third party claims management companies, financial advice firms, solicitor/law firms or insolvency firms, upon your consent to do so, for the purpose of enabling them to contact you so that they can offer, market and provide relevant services to you. Each such third party will act as a data controller in relation to the data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party’s use of your personal data.
We may disclose your personal data to our insurers and/or professional advisers in so far as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
We may disclose personal data to our suppliers or subcontractors, such as external printers, admin companies, call centres, compliance consultants and legal advisers.
Any external processors, who process your data on our behalf, are subject to a data processing agreement to ensure the safety and protection of your data. None of our processors are allowed to use your data for any other purposes than instructed by us.
In addition to the specific disclosures of personal data set out in this Section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
Marketing
You are provided with choices regarding marketing and we record your preferences in relation to this and how we communicate with you.
We may rely on consent when we use your personal information for direct marketing. This will be where you have specifically consented to us or a third party that you are happy to receive marketing contact from us.
We may also rely on legitimate interests for our direct marketing. Our legitimate interests are to inform individuals about products or services which may be of interest to them. Our legitimate interest may also be our commercial interests in operating our business, which includes acquiring new customers, providing additional services to existing or previous customers that are similar or aligned with previous products or services and, expanding our operations.
You may also receive marketing communications from us if you have previously enquired about or purchased similar goods or services from us and, in each case, you have not opted-out of receiving that marketing. This is known as a ‘soft opt-in’.
Such marketing communications may be in relation to claims management, debt advice, financial advice and legal services which could be done by post, email, SMS or telephone.
To opt out of receiving future marketing under any lawful basis, or under soft opt in, in which we intend to rely on for direct marketing, please opt-out using the contact details provided in this Privacy Policy.
If you require any further information about the lawful basis we have relied on to send direct marketing to you, please do not hesitate to contact us.
How long do we keep your personal information
We retain your information for as long as is necessary for the purpose for which it was originally obtained.
We have some legal and regulatory obligations to hold certain pieces of information for specific timeframes for example, we are required to keep a copy of telephone call recordings for a period of 12 months after our last contact with you.
Where we have provided a service to you, we will hold all information relevant to this for 6 years to enable us to defend any claims/complaints made about our service. Information relating to any complaints will be held for a further 3 years.
We also need to keep some of your information for our accounting and reporting requirements.
Your contact details will be held for the purposes of direct marketing for 6 years, this is to enable us to let you know about new products or services that may be of interest to you as detailed above.
Your Rights
You have the following rights in accordance with the GDPR and the DPA:
- To know that your data is being processed
- To access your personal data free of charge
- To have your information corrected if inaccurate (Including ensuring any third party puts right any inaccuracy)
- To request that your data be erased
- To restrict processing
- To request transfer of your data
- To object to processing and;
- To rights relating to automated decision making
You may request that we to provide you with any personal information we hold about you. Where you send us a request to access your data, this will usually be free of change and sent to you within one month (unless your request is complex). 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.
We may need to request specific information from you to help us confirm your identity before we are able to process your request.
We may withhold personal information that you request to the extent permitted by law.
You may instruct us at any time not to process your personal information for marketing purposes.
If at any point you wish to raise a complaint regarding our data handling then you have the right to complain to the Information Commissioner’s Office (ICO) the supervisory authority for data protection issues in the UK whose information is available at www.ico.org.uk. However, we would appreciate to opportunity to deal with any concerns directly with you in the first instance.
Security
FFL recognise the personal nature of the information we collect, process and store. As we are committed to ensuring that your information is secure, we have put in place suitable physical, electronic and managerial procedures to prevent loss, unauthorised access, misuse or disclosure and to make sure that your information is safe and secure. If password access is required for certain parts of our website/application, you are responsible for keeping this password confidential.
Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which may be collected or you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
General
You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.
If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
If you have any queries relating to our Privacy Policy or the personal data we hold about you, or you wish to invoke any of your legal rights, you can contact us by:
Emailing: info@fountain-finances.co.uk
Telephone: 0161 974 4121
Write to us at: 1D MacLaren House, Talbot Road, Old Trafford, M32 0FP
