Ice Cubed Property Finance Ltd (company number: 10798939) which is an independent Commercial Finance Broker based in Triune Court Monks Cross Drive, Huntington, York, England, YO32 9GZ. We act as a broker for our customers. Ice Cubed Property Finance Ltd is an appointed representative of AFS Compliance Ltd which is Authorised and Regulated by the Financial Conduct Authority. FRN 625035.
Synergy Commercial Finance Limited is the controller and responsible for your personal data (collectively referred to as " Ice Cubed Property Finance Ltd", "we", "us" or "our" in this privacy notice). This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
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.
This version was last updated on 9th May 2018 and historic versions can be obtained by contacting us at gdpr@afsuk.com.
The data protection law in the UK will change on 25 May 2018. Although this privacy notice sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) until May 2018 as we are still working towards getting our systems ready for some of these changes.
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.
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 follows:
We may also collect, store and use the following "Special Categories" of more sensitive personal information:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your location data to calculate the percentage of customers accessing our services in a given geographical location. 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 notice.
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 services). In this case, we may have to cancel service you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
(a) Consent: the individual has given clear consent for you to process their personal data for a specific purpose.
(b) Contract: the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract.
(c) Legal obligation: the processing is necessary for you to comply with the law (not including contractual obligations).
(d) Public task: the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law.
(e) Legitimate interests: the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual�s personal data which overrides those legitimate interests. (This cannot apply if you are a public authority processing data to perform your official tasks.)
The situations in which we will process your personal information are listed below. Please see Schedule 1 to this privacy notice in which we have set out, 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 at funding@ice3.finance 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.
We will process your personal information for the following reasons:
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:
If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.
Many of our funders use auto scoring technology to underwrite deals. You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
We will share your personal information with third parties where required by law, where it is necessary to administer the contractual relationship with you or where we have another legitimate interest in doing so.
"Third parties" includes third-party service providers (including contractors and designated agents) and other entities within our group. The following third-party service providers process personal information about you for the following purposes:
We have a Data Protection regime in place to oversee the effective and secure processing of your personal data. More information on this framework can be found on our website.
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of your personal information are available in our retention policy which is available from gdpr@afsuk.com. 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 requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer an employee, worker or contractor of the company we will retain and securely destroy your personal information in accordance with applicable laws and regulations.
We do not transfer your personal data outside the European Economic Area (EEA).
Under certain circumstances, by law you have the right to:
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact funding@ice3.finance
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
If you wish to raise a complaint on how we have handled your personal data, you can contact our Data Protection Officer who will investigate the matter.
If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the Information Commissioner�s Office (ICO).
Our Data Protection Officer is Tom Frank and you can contact him at tom@ice3.finance
Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
To find the best source of finance based on your circumstances |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
- Contractual - Legitimate Interest: to promote financial products we believe may be of interest to you. |
To undertake credit checks for the purposes of finding the most suitable finance product. |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
- Contractual |
To confirm your affordability for the financial requirement you have proposed to us. |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
- Contractual |
To comply with our anti-money laundering and know your client requirements. |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
- Contractual |
To meet our regulatory responsibilities. |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
- Legal Obligation |