Roma Finance: Privacy Notice

Welcome to Roma Finance’s privacy notice.

Roma Finance respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below.

  1. IMPORTANT INFORMATION AND WHO WE ARE
  2. THE DATA WE COLLECT ABOUT YOU
  3. HOW IS YOUR PERSONAL DATA COLLECTED
  4. HOW WE USE YOUR PERSONAL DATA
  5. DISCLOSURES OF YOUR PERSONAL DATA
  6. INTERNATIONAL TRANSFERS
  7. DATA SECURITY
  8. DATA RETENTION
  9. YOUR LEGAL RIGHTS
  10. GLOSSARY

 

  1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy notice

This privacy notice aims to give you information about how we collect and use your personal data, including any data you may provide (through our website or otherwise) when you sign up to marketing communications or purchase a product or service.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

Roma Finance is made up of the following different legal entities: Romaco Limited (Reg No 07232590), Romaco SPV 1 Limited (Reg No 09732416), Romaco SPV 2 Limited (Reg No 10179215), Romaco SPV 3 Limited (Reg No 10518586), Romaco SPV 4 Limited (Reg No 11111729), Romaco SPV 5 Ltd (Reg No 11112580), Romaco SPV 6 Limited (Reg No 11698938),  Romaco SPV 7 Limited (Reg No 12006443), Romaco SPV 8 Limited (Reg No 12358341) and Romaco SPV 9 Limited (Reg No 14240300), all of which are registered in England.

This privacy notice is issued on behalf of the whole Roma Finance group so when we mention “Roma Finance“, “we“, “us” or “our” in this privacy notice, we are referring to the relevant company in the Roma Finance group responsible for processing your data.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Third-party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

  1. THE TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender;
  • Contact Data includes home address, security property address(es), email address and telephone numbers;
  • Financial Data includes bank account details and bank statements;
  • Transaction Data includes details about payments to and from you and details of products and services you have purchased from us;
  • Technical Data includes internet protocol (IP) address, your login data (where applicable), 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 you use to access our website;
  • Profile Data includes your username and password, products supplied to, or enquired about, by you, your interests, preferences, feedback and survey responses;
  • Usage Data includes information about how you interact with and use our website, products and services;
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data. Aggregated data could be derived from your personal data but is not considered personal data as this data will not directly (or indirectly) reveal your identity. For example, we may aggregate individual’s Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time. If this happens, we would not reimburse you for any fees paid to us.

  1. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

  • your interactions with us. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • apply for our products or services;
    • create an account on our website or portal (if applicable);
    • subscribe to our service or publications;
    • request marketing to be sent to you;
    • enter a competition, promotion or survey; or
    • give us feedback or contact us.
  • automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
  • third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out:
    • brokers and/or other introducers who introduce you to us;
    • Technical Data from analytics providers such as Google Analytics based inside the EU;
    • Identity and Contact Data from publicly availably sources such as Companies House, the Electoral Register and LinkedIn;
    • Identity and Contact Data from privately availably sources whom you have authorised us to contact as part of any application you make for products and/or services such as credit reference agencies and fraud prevention agencies based inside the UK. These agencies share personal data about you that is derived from, or used, in credit activity and who provide credit reporting, and/or fraud prevention, services. We use this information help us make the best possible assessment of your overall financial situation and history, to check your identity and to prevent criminal activity;
    • social logins and single sign-on technology.
  1. HOW WE USE YOUR PERSONAL DATA

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases to use your personal data:

  • performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
  • legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law);
  • legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis;
  • consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

 

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

 

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer (a) Identity
(b) Contact		 Performance of a contract with you
To process and deliver, a product for you including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us		 a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications		 Performance of a contract with you
Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey		 (a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications		 Performance of a contract with you
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and manage our loan book as a whole, including obtaining funding (a) Identity
(b) Contact
(c) Financial
(d) Transaction		 Necessary for our legitimate interests (to manage our loan book, obtain funding and for running our business generally)
To enable you to partake in any relevant prize draw, competition or complete a survey (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications		 Performance of a contract with you
Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Technical		 Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical		 Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products / services, marketing, customer relationships and experiences (a) Technical
(b) Usage		 Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To send you relevant marketing communications and make suggestions and recommendations to you about products or services that may be of interest to you based on your Profile Data (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile		 Necessary for our legitimate interests (to carry out direct marketing, develop our products/services and grow our business)
To carry out market research through your voluntary participation in surveys (a) Identity
(b) Contact		 Necessary for our legitimate interests (to study how customers use our products/services and to help us improve and develop our products and services).

 

Direct marketing

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving the marketing.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

Third-party marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

Opting out of marketing

You can ask us to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us at any time.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes.

Cookies

For more information about the cookies we use and how to change your cookie preferences, please see our cookie policy.

  1. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:

  • Internal Third Parties. For these purposes, Internal Third Parties means Pilot Group Services Limited acting as a data processor for Roma Finance. Pilot Group Services Limited is based in the UK and provides HR and IT system administration services, some accounting services and undertakes leadership reporting.
  • External Third Parties. For these purposes, External Third Parties means
    • service providers acting as processors based in the UK who provide HR administration and benefits services, pension administration and IT and system administration services;
    • professional advisers acting as processors including lawyers, bankers, funders, auditors, insurers, surveyors, visit-agents and insolvency practitioners based in the UK who provide consultancy, banking, finance, legal, insurance, accounting and other services;
    • HM Revenue & Customs, regulators and other authorities acting as processors based in the UK who require reporting of processing activities in certain circumstances;
    • credit reference agencies and fraud prevention agencies based in the UK who collect personal data about you that is derived from, or used, in credit activity and who provide credit reporting, and/or fraud prevention, services.
  • 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 this privacy notice.

Fraud prevention

Please specifically note that we may disclose your personal data to credit reference agencies to assist them in the collection and maintenance of personal data about you relating to your payment of debts and general credit worthiness, and with fraud prevention agencies to help prevent fraud and money laundering. They in turn may share this information with other organisations, such as other finance companies that you approach to provide you with products and services. We, and fraud prevention agencies, may also enable law-enforcement agencies to access and use your personal data to detect, investigate and prevent crime.

If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services and financing you have requested, or we may stop providing existing services to you. A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you. You can find out which fraud prevention agencies we use, or ask us any other questions about this, by contacting us.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

The three main credit reference agencies in the United Kingdom, TransUnion (formerly called Callcredit), Equifax and Experian have created an industry-wide notice called the “Credit Reference Agency Information Notice” (CRAIN) which sets out clearly how they use and share personal data they receive about you and/or your business that is part of or derived from or used in credit activity. You can find a copy of this notice at https://www.callcredit.co.uk/legal-information/bureau-privacy-notice.

  1. INTERNATIONAL TRANSFERS

As a rule, we do not transfer your personal data outside the United Kingdom (UK). However, one of our external funders’ head office is based in the United States of America, and some of our external third parties may be outside the UK, so their processing of your personal data may involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are implemented:

  • we will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data;
  • we may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK.
  1. 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. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties 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.

  1. DATA RETENTION

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for anti-money laundering, and tax, purposes.

In some circumstances you can ask us to delete your data: see Request erasure section below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

  1. YOUR LEGAL RIGHTS

You have a number of rights under data protection laws in relation to your personal data. You have the right to:

  • Request access to your personal data (commonly known as a ” subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object. You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see “Opting out of marketing” in section 4 for details of how to object to receiving direct marketing communications).
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

 

  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
    • if you want us to establish the data’s accuracy;
    • where our use of the data is unlawful but you do not want us to erase it;
    • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
    • you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us (see “Contact details” below).

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). 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.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways

Full name of legal entity: Romaco Limited

Name or title of DPO: Wendy Littman

Email address: wendy.littman@romafinance.co.uk

Postal address: 15 Carnarvon Street, Manchester M3 1HJ

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 26th February 2024.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us (such as a new address or email address).