Privacy policy.

MLN CO. LTD Privacy Policy

Our contact details:

  • Name: Mark Nicholls

  • Address: 85 Great Portland Street, First Floor, London, W1W 7LT.

  • E-mail: data [at] mln-co.com

Why should you read this document?

During dealing with us, we will ask you to provide us with detailed personal information relating to your existing circumstances, financial situation and, in some cases, your health and family health history (Your Personal Data). This document is important as it allows us to explain to you what we will need to do with Your Personal Data and the various rights you have about Your Personal Data.

What do we mean by “Your Personal Data”?

Your Personal Data means any information that describes or relates to your circumstances. Your Personal Data may identify you directly, for example, your name, address, date of birth, and national insurance number. Your Personal Data may also identify you indirectly, for example, your employment situation, your physical and mental health history, or any other information that could be associated with your cultural or social identity.

In the context of providing you with assistance with your Commercial Finance requirements.

Your Personal Data may include:

  • Title, name, date of birth, gender, nationality, civil/marital status, contact details, addresses and documents that are necessary to verify your identity

  • Employment and remuneration information, (including salary/bonus schemes/overtime/sick pay/other benefits), employment history

  • Bank account details, tax information, loans and credit commitments, personal credit history, sources of income and expenditure, family circumstances and details of dependents

  • Health status and history, details of treatment and prognosis, medical reports (further details are provided below expressly about the processing we may undertake about this type of information)

  • Any pre-existing commercial finance products and the terms and conditions relating to these
    The basis upon which our Firm will deal with Your Personal Data

When we speak with you about your commercial finance requirements, we do so because both parties are entering a contract for the supply of services. To perform that contract and to arrange the products you require, we have the right to use Your Personal Data for the purposes detailed below.

Alternatively, in the course of initial discussions with you or when the contract between us has come to an end for whatever reason, we have the right to use Your Personal Data, provided it is in our legitimate business interest to do so, and your rights are not affected. For example, we may need to respond to requests from mortgage lenders, insurance providers and our Compliance Service Provider relating to the advice we have given or to contact you to seek feedback on your service.
Occasionally, we will use Your Personal Data for contractual responsibilities we may owe our regulator, The Financial Conduct Authority, or for wider compliance with any legal or regulatory obligation to which we might be subject. In such circumstances, we would be processing Your Data to meet a legal, compliance or other regulatory obligation to which we are subject.

How do we collect Your Personal Data?

We will collect and record Your Data from various sources, but mainly directly from you. You will usually provide information during our initial meetings or conversations with you to establish your circumstances and needs, and preferences regarding commercial finance requirements. You will provide information to us verbally and in writing, including by email.

We may also obtain some information from third parties, for example, credit checks, information from your employer, and searches of information in the public domain, such as the voter’s roll. If we use technology solutions to assist in collecting Your Personal Data, for example, software that can verify your credit status. We will only do this if we have consent from you for our nominated processor or us to access your information in this manner. With regards to electronic ID checks, we would not require your consent but will inform you of how such software operates and the purpose for which it is used.

What happens to Your Personal Data when it is disclosed to us?

In the course of handling Your Personal Data, we will:

  • Record and store Your Personal Data in our paper files, mobile devices, and our computer systems (email, hard drives, and cloud facilities). Employees and consultants within our firm can only access this information when it is necessary to provide our service to you and perform any administration tasks associated with or incidental to that service.

  • Submit Your Personal Data to Product Providers/Commercial Lenders in paper form and online via a secure portal. Providing this information to a third party is essential in allowing us to progress any enquiry or application made on your behalf and to deal with any additional questions or administrative issues that lenders and providers may raise.

  • Use Your Data to respond to any queries you may have about any commercial finance product you may take out or to inform you of any developments about those products and/or policies of which we might become aware.

  • Sharing Your Personal Data

  • From time to time, Your Personal Data will be shared with:

  • Finance Lenders

  • Third parties who we believe will be able to assist us with your enquiry or application or who can support your needs as identified.

  • These third parties will include but may not be limited to our compliance advisers, product specialists, estate agents, providers of legal services such as estate planners, conveyancing, surveyors and valuers (in each case where we believe this to be required due to your particular circumstances).

In each case, Your Personal Data will only be shared for the purposes set out in this Customer Privacy Notice, i.e. to progress your finance (delete as appropriate) enquiry and to provide you with our professional services. Please note that this sharing of Your Personal Data does not entitle such third parties to send you marketing or promotional messages: it is shared to ensure we can adequately fulfil our responsibilities to you, and as otherwise set out in this Customer Privacy Notice. We do not envisage that the performance by us of our service will involve Your Personal Data being transferred outside of the European Economic Area.

Security and retention of Your Personal Data

Your privacy is important to us, and we will keep Your Personal Data secure by our legal responsibilities. We will take reasonable steps to safeguard Your Data against it being accessed unlawfully or maliciously by a third party.

We also expect you to take reasonable steps to safeguard your privacy when transferring information to us, such as not sending confidential information over unprotected email, ensuring email attachments are password protected or encrypted and only using secure postage methods when original documentation is being sent to us.

Your Personal Data will be retained by us either electronically or in paper form for a minimum period of 6 years following the advice/service you receive from us. However, your data could be held for a longer period, which may be needed to meet the requirements of our regulatory bodies.

Your rights in relation to Your Personal Data

You can:

  • Request copies of Your Personal Data that are under our control

  • Ask us to further explain how we use Your Personal Data

  • Ask us to correct, delete or require us to restrict or stop using Your Personal Data (details as to the extent to which we can do this will be provided at the time of any such request)

  • Ask us to send an electronic copy of Your Personal Data to another organization should you wish
    Change the basis of any consent you may have provided to enable us to market to you in the future (including withdrawing any consent in its entirety)

How to make contact with our Firm in relation to the use of Your Personal Data. If you have any questions or comments about this document or wish to make contact to exercise any of your rights set out within it, please contact:

  • data[at]mln-co.com

If we feel we have a legal right not to deal with your request, or to act differently from how you have requested, we will inform you of this at the time.

You should also make contact with us as soon as possible on you become aware of any unauthorized disclosure of Your Personal Data, so that we may investigate and fulfil our own regulatory obligations. If you have any concerns or complaints as to how we have handled Your Personal Data, you may lodge a complaint with the UK's data protection regulator, the ICO, who can be contacted through their website at https://ico.org.uk/global/contact-us/ or by writing to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AFL