CUSTOMER PRIVACY NOTICE

Last updated september 23, 2024

CONTACT DETAILS
 
Post: 1 Bolton Street, London, Other, W1J 8HY, GB 
Telephone: +44 203 911 6451 
Email: contact@nlc.co.uk  
 
WHAT INFORMATION WE COLLECT, USE, AND WHY
 
We collect or use the following information to provide and improve products and services for clients
 
  • Names and contact details
  • Occupation
  • Usage data (including information about how you interact with and use our website, products and services)
  • Information relating to compliments or complaints
  • Website user information 
 
We collect or use the following personal information for the operation of client or customer accounts
  • Names and contact details
  • Addresses
  • Account information, including registration details
  • Information used for security purposes
  • Marketing preferences
  • Technical data, including information about browser and operating systems 
 
We collect or use the following personal information for the prevention, detection, investigation or prosecution of crimes
  • Names and contact information
  • Client accounts and records
  • Identification documents
  • Client account information
  • Any other personal information required to comply with legal obligations
  • Financial information eg for fraud prevention or detection 
 
We collect or use the following personal information for information updates or marketing purposes
  • Names and contact details
  • Marketing preferences
  • Website and app user journey information
  • IP addresses 
 
We collect or use the following personal information for research or archiving purposes
 
  • Names and contact details
  • Purchase or client account history 
 
We collect or use the following personal information to comply with legal requirements
  • Name
  • Contact information
  • Identification documents
  • Client account information
  • Any other personal information required to comply with legal obligations
  • Criminal offence data  
 
We collect or use the following personal information for recruitment purposes
  • Contact details (eg name, address, telephone number or personal email address)
  • Date of birth
  • National Insurance number
  • Copies of passports or other photo ID
  • Employment history (eg job application, employment references or secondary employment)
  • Education history (eg qualifications)
  • Right to work information
  • Details of any criminal convictions (eg Disclosure Barring Service (DBS), Access NI or Disclosure Scotland checks ) 
 
We also collect or use the following information for recruitment purposes
  • Health information

We collect or use the following personal information for dealing with queries, complaints or claims

  • Names and contact details
  • Account information
  • Purchase or service history
  • Witness statements and contact details
  • Relevant information from previous investigations
  • Customer or client accounts and records
  • Information relating to health and safety (including incident investigation details and reports and accident book records)
  • Correspondence
  • Location data
 
LAWFUL BASES AND DATA PROTECTION RIGHTS
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website. 
 
Which lawful basis we rely on may affect your data protection rights which are in brief set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website: 
 
 
If you make a request, we must respond to you without undue delay and in any event within one month. 
 
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice. 
 
Our lawful bases for the collection and use of your data 
Our lawful bases for collecting or using personal information to provide and improve products and services for clients are: 
 
  • Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object. 
  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability. 
 
Our lawful bases for collecting or using personal information for the operation of client or customer accounts are: 
 
  • Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object. 
  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability. 
 
Our lawful bases for collecting or using personal information for the prevention, detection, investigation or prosecution of crimes are: 
 
  • Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object. 
  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability. 
 
Our lawful bases for collecting or using personal information for information updates or marketing purposes are: 
 
  • Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are: 
 
    • Being able to carry out internal and external audits on our processes to ensure quality and consistency across our portfolio. 
    • Preventing fraud and money laundering as well as protecting our business and that of our Affiliates more generally. 
    • If you are a company or an individual working for a company, sending you select direct marketing communications using your business contact details to market our products and services to you. You have the right to opt out of receiving marketing communications we may send you at any time and can do so by selecting the ‘unsubscribe’ option contained at the bottom of the emails we send to you.  
 
Our lawful bases for collecting or using personal information for research or archiving purposes
 
  • Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object. 
  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability. 
 
Our lawful bases for collecting or using personal information to comply with legal requirements: 
 
  • Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object. 
  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability. 
 
Our lawful bases for collecting or using personal information for recruitment purposes are: 
 
  • Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object. 
  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability. 
 
Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are: 
 
  • Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object. 
  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability. 
 
 
WHERE WE GET PERSONAL INFORMATION FROM
  • Directly from you
  • Regulatory authorities
  • Publicly available sources
  • Previous employment
  • Suppliers and service providers 


HOW LONG WE KEEP INFORMATION

How long we hold your personal data for will vary. The retention period will be determined by various criteria including: 
 
  • the purpose for which we are using it – we will need to keep the data for as long as is necessary for that purpose; and 
  • legal obligations – laws and regulations may set a minimum period for which we have to keep your personal data. 
 
If you require specific information about how long your information will be held, or for support in exercising any of your data subject rights in respect of the personal data held about you, please contact us using the details in the “Contact details” section above. 
 
 
WHO WE SHARE INFORMATION WITH
Data processors 
 
Our Affiliates 
 
Any of the personal data we collect about you may be transferred to our Affiliates to be stored and processed in the ways and for the purposes set out in this privacy notice. 
 
Institutional Investors 
 
Any of the personal data we collect about you may be transferred to our institional investors to be stored and processed in the ways and for the purposes set out in this privacy notice. Any such disclosure will be subject to confidentiality requirements and third parties will be contractually obligated to use your personal data in accordance with applicable data protection laws. 
 
Rating Agencies 
 
Any of the personal data we collect about you may be transferred to our rating agencies to be stored and processed in the ways and for the purposes set out in this privacy notice. Any such disclosure will be subject to confidentiality requirements and third parties will be contractually obligated to use your personal data in accordance with applicable data protection laws. 
 
Others we share personal information with:
 
  • Debt collection agencies
  • Other financial or fraud investigation authorities
  • Insurance companies, brokers or other intermediaries
  • Professional or legal advisors
  • Insolvency practitioners
  • Regulatory authorities
  • External auditors
  • Organisations we’re legally obliged to share personal information with
  • Previous employers
  • Suppliers and service providers
  • Professional consultants
  • Potential third party buyers and their advisors
  • Potential third party acquirers and their advisors 
 
 
SHARING INFORMATION OUTSIDE THE UK
 
Where necessary, we may transfer personal information outside of the UK. When doing so, we comply with the UK GDPR, making sure appropriate safeguards are in place. 
 
 
HOW TO COMPLAIN
 
If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice. 
 
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO. 
 
The ICO’s address:            
 
Information Commissioner’s Office 
Wycliffe House 
Water Lane 
Wilmslow 
Cheshire 
SK9 5AF 
 
Helpline number: 0303 123 1113 
 
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