Season Marketing Privacy Policy

Welcome to Season Marketing Limited’s privacy policy.

Season Marketing Limited respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

We take every reasonable precaution to ensure that your information is only used in the way outlines by this Privacy Policy and within compliance of Season Marketing Limited’s Terms and Conditions.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

  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 policy

This privacy policy aims to give you information on how Season Marketing Limited collects and processes your personal data through your use of this website (or any of our trading names), including any data you may provide through website (and any of our trading names) when you submit your request for a loan.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy 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 policy supplements other notices and privacy policies and is not intended to override them.

Season Marketing Limited (including the trading names listed below) is the controller and responsible for your personal data (collectively referred to as "COMPANY", "we", "us" or "our" in this privacy policy).

Trading Names:

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

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: Season Marketing Limited

Data Protection Officer

Email address: dpo@seasonfinance.com

Postal address: 71 - 75 Shelton Street, London, England, WC2H 9JQ

Telephone number: 0203 026 1948

If you have any questions relating to consent of personal data, things like opting out of email or SMS marketing, these can be handled directly by either unsubscribing from our emails using the option at the bottom of the emails we send you or by filling in the form on our website, which can be found here. This applies to both email and SMS marketing communications.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority 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.

If you wish to contact us about anything other than the topics covered in this Privacy Policy you can do so by any of the available contact details on our website.

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

We keep our privacy policy under regular review. This version was last updated on 26th April 2021. Historic versions can be obtained by contacting us.

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.

From time to time we may need to update this Privacy Policy because of changes in regulation/legislation/law, changes in how our services operate, or changes to our company structure etc.

In the event that this Privacy Policy is updated we will do our best to notify all users promptly, this includes having a notification on our website home page or sending you an email informing you that the policy has updated. When there is a change in our Privacy Policy you may be required to agree to the new policy before being able to continue using our service.

Third-party links

This 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 policy of every website you visit.

  1. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

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

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your 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). Nor do we collect any information about criminal convictions and offences.

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 and/or services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

  1. How is your personal data collected?

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

  1. How we use your personal data

When we use your personal data we are required to have a legal basis for doing so. There are various different legal bases on which we may rely, depending on what personal data we process and why.

The legal bases we may rely on include:

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

We may pass your information to third parties for providing the services detailed within this Privacy Policy, including offering you a loan. This data will only be stored with companies that can be confirmed to fully comply with the GDPR.

We do not directly use any form of automated decision making with any data we hold or process, however, third party lenders may make an automated decision about your loan offer. This is a standard part of their processes and cannot be changed. By using our services, third party lenders that receive your information for the purpose of providing a loan will carry out automated decision making when making their decision.

Please remember, you have the right to withdraw consent to marketing at any time by contacting us directly.

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.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
Receiving your application for our loan finding service which you submit by accepting our terms and condition, found here. (a) Identity
(b) Contact
(d) Usage
(e) Marketing and Communications
(f) Technical
(a) Necessary for our legitimate interests (to develop our products/services and grow our business)
(b) Performance of contractual obligations
Once we receive your application, sending it to our panel and of credit brokers, lenders and alternative loan solutions (a) Identity
(b) Contact
(d) Usage
(e) Marketing and Communications
(f) Technical
(a) Necessary for our legitimate interests (to develop our products/services and grow our business)
(b) Consent
To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy This could be by email and/or SMS.
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(a) Necessary to comply with a legal obligation
(b) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Technical
(a) 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)
(b) 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 make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
(a) Necessary for our legitimate interests (to develop our products/services and grow our business)
(b) Consent
To provide information to you that you request from us in relation to our products or services. This could be by telephone, email, SMS, and/or automated voice messaging. (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
(a) Necessary for our legitimate interests (to develop our products/services and grow our business)
(b) Consent
To inform you of any changes to our website, service or good and products. This could be by email and/or SMS. (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
(a) Necessary for our legitimate interests (to develop our products/services and grow our business)
(b) Consent
(c) Necessary to comply with a legal obligation
If you have previously used our services, we may provide to you details of similar services, or other services that you may be interested in (‘Promotional Offers’). This could be by email and/or SMS. Please see more on Promotional Offers below. (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
(a) Necessary for our legitimate interests (to develop our products/services and grow our business)
(b) Consent

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

When you make a loan application through our website you may have the option of choosing to receive marketing information from us either via email or SMS.

Any marketing you receive from us will only contain information about the following products:

You can control your marketing preferences with us on our website at www.st0p.uk or by emailing our DPO at compliance@seasonfinance.com should you have any queries in relation to our site(s).

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this 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 opted in to or have not refused to receive that marketing.

Opting out

You can ask us to stop sending you marketing messages (SMS and/or email) at any time. You can do this by accessing the following link on our website: www.st0p.uk, by following the opt-out links on any marketing correspondence we send you or by contacting us at any time by email to: compliance@seasonfinance.com.

We may also retain your Personal Data where this is required to comply with any relevant UK laws and regulations and/or for the purposes of any relevant investigations by supervisory authorities, such as investigations into personal data breach.

Marketing - Third Parties

You may also have the option of choosing to receive marketing information from our trusted partners listed below either via email, SMS or Telephone:

Any marketing you receive from third parties will only contain information about the following products:

Some of our websites application forms may not contain third party marketing options, and in this case, none of your details will be shared with third parties for marketing purposes.

Opting out from third parties

To opt out of third party marketing, you can do so by clicking the unsubscribe link in the message you have received, you can also contact us at compliance@seasonfinance.com letting us know you would like to be removed from third party marketing and we will notify our partners.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see https://www.terms1.co.uk/cookies-policy.php.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

  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 Purposes for which we will use your personal data above.

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 and we enter into controller-processor or controller-controller agreements (whichever is appropriate) with such third parties.

As set out in more detail in Section 4 of this Privacy Policy, we will not disclose your personal data to any other party other than in accordance with this Policy and in the circumstances detailed below:

  1. In the event that we sell any or all of our business to the buyer where the data held will be considered as one of our assets.
  2. Where we are legally required by law to disclose your personal information.
  3. To further fraud protection and reduce the risk of fraud.
  4. Section 4 of this Privacy Policy.
  1. International transfers

In operating our website, it may become necessary to transfer data that we collect from you to locations outside of the European Union for processing, storing, and as part of your loan application.

By providing your personal data to us, you agree to this transfer, storing and/or processing. A recent list of the companies this could include are noted in Section 5 above, for an extensive list of who these companies may be and what their specific roles are please contact our DPO on compliance@seasonfinance.com.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Your data will only ever be transferred via secure methods to ensure that your data is as safe as possible and never knowingly or negligently passed to any unwarranted third parties.

Your data will never be willingly passed to any individual/organisations/companies that do not comply with the GDPR in full even if they operate outside of EEA.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

  1. Data security and storage

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.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We do our upmost to ensure that all reasonable steps are taken to make sure that your data is stored securely and regardless of the companies’ location we will only deal with companies that can prove they are GDPR compliant.

Unfortunately, the sending of information via the internet is not totally secure and on occasion such information can be intercepted. We cannot guarantee the security of data that you choose to send us electronically, however we take every reasonable step possible to ensure your data is safe and encrypted. Be aware that sending such information is entirely at your own risk.

Your data can be stored in multiple ways, we store your data on our website to allow you to use our services. We also store your data on an online secure cloud backup and a local backup to help re-establish all of our user details should we ever suffer a loss of data or data breach to recover any lost or potentially infected data.

  1. Data retention

How long will you use my personal data for?

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. This is usually a period of maximum 12 months, as it allows us to maintain accurate record keeping.

We try our hardest to only keep accurate records of any personal data we store, if you ever need to update any of your information we hold this can be done by contacting our DPO.

When data has not been used for a 12-month period it will be deleted or archived from our active records, along with all backups and archives as we believe after this time data will no longer be relevant or required in providing our services. Your data will be archived in circumstances where it is required to be retained under any other EU laws, when this does not apply the data will be deleted.

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.

We can also delete your data by submitting a request to our DPO. If you have any questions relating to the retention of data, please contact our DPO.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

If you wish to exercise any of the rights set out above, please contact us. See our contact details above.

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 could 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 could 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.

  1. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a "data 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. 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) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

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.

Right in relation to automated decision making: you have a right to object to automated decision making, to express your point of view, ask for human intervention, and to be provided with an explanation of the decision with your option to challenge it. The right is not absolute and is not applicable for the entering into a consumer credit agreement. You can request this by contacting our DPO.

Right to be informed: you have a right to be informed about how your personal data is processed in a concise, transparent, intelligible and easily accessible manner, written in clear and plain language, that is free of charge. This is the purpose of this Privacy Policy.

Withdraw consent at any time where we are relying on consent to process your personal 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.

To withdraw your consent, you can do so via disabling/deleting your account by contacting compliance@seasonfinance.com as without consent to this Privacy Policy we will be unable to provide you with our services. You can also do so by contacting the email account of our DPO detailed throughout this policy.

Right to lodge a complain with a supervisory authority: you have the right to lodge a complaint with us directly and / or with a supervisory authority. In the UK the relevant authority is the Information Commissioner’s Office (ICO). You can find their contact details here: https://ico.org.uk/concerns/.

We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so if you believe we have mishandled your data and would like to complain to us directly, you can do so by contacting our DPO via the email provided above. Our DPO will review your claim and provide you with all the information required. They will aim to respond to your complaint within 2 business days.

Information about us

Season Marketing Ltd registered in England and Wales (Company number 08901402). Season Marketing Ltd’s registered office; Season Marketing Ltd, 71 - 75 Shelton Street, London, England, WC2H 9JQ. Season Marketing Ltd is authorized and regulated with full permission by the Financial Conduct Authority and entered on is the Consumer Credit Register under reference number: 727385. Licensed by the Information Commissioners Office, (registration number ZA285535).