Privacy Policy

Privacy Policy

Last updated September 2023

How we use your personal information

This privacy notice explains how companies within Bowen Investment Holdings Group use and look after your personal information. This includes what you tell us about yourself, what we learn by having you as a client, and your marketing choices. This notice also tells you about your privacy rights and how the law protects you.

This privacy notice will apply to you if you are or have been a client of Bowen Investment Holdings Group . If your personal information has been provided to Bowen Investment Holdings Group , but you are not a client, it may also apply to you. For example, if you have applied for more information or complete our Contact Us Form

There are a range of different products and services throughout Bowen Investment Holdings Group . Each one may have different requirements for the collection and use of your personal information. For this reason, some sections of this notice do not apply to all Bowen Investment Holdings Group  products and services.

Our Privacy Promise

We promise:

· To keep your personal information safe and private.

· Not to sell your personal information.

· To give you ways to manage and review your marketing choices at any time.

· Understanding personal information and the law

This section tells you who we are, what your personal information is, and how we get it. It explains how the law protects you by controlling what is allowed to happen to it.

How The Law Protects You

This section sets out the legal reasons we rely on, for each of the ways we may use your personal information. 

As well as our Privacy Promise, your privacy is protected by law. This section explains how that works.

Data Protection law says that we can use personal information only if we have a proper reason to do so. This includes sharing it outside Bowen Investment Holdings Group . The law says we must have one or more of these reasons:

· To fulfil a contract we have with you, or

· When it is our legal duty, or

· When it is in our legitimate interest, or

· When you consent to it, or

· When it is in the public interest.

When we have a business or commercial reason of our own to use your personal information, this is called a ‘legitimate interest’. We will tell you what that is, if we are going to rely on it as the reason for using your personal information. Even then, it must not unfairly go against your interests.

You have the right to object the use of your personal information in this way. You can do this by telling us anything that we may need to consider, to understand if our use of your personal information is fair.

The law and other regulations treat some types of sensitive personal information as special. This personal information is called ‘special categories of personal information’. We will not collect or use these types of personal information without your consent unless the law allows us to do so. If we do, it will only be when it is necessary:

· For reasons of substantial public interest, or

· To establish, exercise or defend legal claims.

Here is a list of all the ways that we may use your personal information, and which of the reasons we rely on to do so. This is also where we tell you what our legitimate interests are where it is the reason for using your personal information.

We may rely on different reasons for using the same personal information, as this depends on the situation. For example, we may use your personal information to make an automated decision about you. This could be because of a legal duty, or to fulfil a contract we’ve made with you.

What we use your personal information for:

· To manage our relationship with you or your business.

· To communicate with you about our products and services.

· To develop and manage our brands, products and services.

· To develop and carry out marketing activities.

· To detect, investigate, report, and seek to prevent financial crime.

· To manage risk for us and our clients.

· To obey laws and regulations that apply to us.

· To respond to complaints and seek to resolve them.

Who We Share Your Information With

Bowen Investment Holdings Group

We may share your personal information with other companies in Bowen Investment Holdings Group.

Authorities

This means official bodies that include:

· Central and local government

· HM Revenue & Customs, regulators and other tax authorities

· UK Financial Services Compensation Scheme and other deposit guarantee schemes

· Law enforcement and fraud prevention agencies.

· Banking and financial services

Outside companies we work with to provide services to you and to run our business.

Agents, suppliers, sub-contractors and advisers - These are types of firm that we use to help us run accounts, policies and services.

Credit reference agencies such as TransUnion, Equifax and Experian.

Someone linked with you or your business’s product or service - This could mean a joint account holder, trustee or fellow company director.

Other financial services companies - This can be to fulfil a payment or other service as part of a contract with you; or to help prevent, detect and prosecute unlawful acts and fraudulent behaviour.

Agents who help us to collect what is owed to us.

Employers - For instance, to confirm your identity if we ask for a mortgage reference.

Companies whose shares we hold for you in one of our nominee companies - This is usually to do with Share Dealing accounts. This is where we hold shares for you in the name of our nominee company, and that company asks us to share details of the underlying shareholder with them.

Insurers

We share personal information with insurance industry companies to process claims and help reduce fraud. 

Other services and schemes

These are organisations that we may need to share your personal information with, because of what you can do with the product or service you have with us.

If you have a secured loan or mortgage with us, we may share information with other lenders who also hold a charge on the property, such as the other party in a shared ownership scheme.

If a third-party contacts us about fines, penalties or charges imposed on you, we may share this with your employer, or share your details with these third-parties.

General business

Outside companies we use to provide our services, help grow and improve our business.

Companies we have a contractual arrangement, joint venture or agreement with - This could be a store, a manufacturer or a broker who is offering finance deals or other products, services or features through us.

Organisations that introduce you to us - This might be broker who finances deals through us.

Advisers who help us to come up with new ways of doing business - This might be a legal firm, IT supplier or consultancy.

Outside companies you may use

This could include:

Third-party payment providers. For example, if you use an app on your phone to pay for something, then we may share payment and transaction data with them - This includes the amount, type, location, origin and recipients.

Company mergers, and takeovers and transfers of products or services

We may also share your personal information if the ownership of products or services or the make-up of Bowen Investment Holdings Group changes in the future:

We may choose to sell, transfer, or merge parts of our business, or our assets, including products or services. Or we may try to bring other businesses into Bowen Investment Holdings Group - This is sometimes called Mergers & Acquisitions or ‘company takeovers’.

During any such process, we may share your data with other parties involved. We’ll only do this if they agree to keep your data safe and private.

If the change to our Group happens, then other parties may use your data in the same way as set out in this notice.

Credit Reference Agencies (CRA’s)

We carry out credit and identity checks when you apply for a product or services for you or your business. We may use Credit Reference Agencies to help us with this.

We will go on sharing your personal information with CRAs for the duration of your relationship with us. From time to time, we may also search information that the CRAs have to help us manage your accounts.

We will share your personal information with CRAs and they will give us information about you. The data we exchange can include:

· Name, address and date of birth

· Credit application

· Details of any shared credit

· Financial situation and history

· Fraud prevention information

We’ll use this data to:

· Assess whether you or your business is able to afford to meet any financial obligations

· Make sure what you’ve told us is true, correct and up to date

· Help detect and prevent financial crime

· Manage your relationship with us

· Trace and recover debts

This will include details of money going into the account, and the account balance. If you borrow, it will also include details of your repayments, and whether you repay in full and on time. 

When we ask CRAs about you or your business, they will note it on your credit file. This is called a credit search. Other lenders may see this and we may see credit searches from other lenders.

If you apply for a product with someone else, we will link your records with theirs. We’ll do the same if you tell us you have a spouse, partner or civil partner – or that you are in business with other partners or directors.

You should tell them about this before you apply for a product or service. It’s important that they know your records will be linked together, and that credit searches may be made on them.

CRAs will also link your records together. These links will stay on your files unless one of you asks the CRAs to break the link. You’ll normally need to give proof that you no longer have a financial link with each other.

You can find out more about the CRAs on their websites, in the Credit Reference Agency Information Notice (CRAIN). This includes details about:

· Who they are

· Their role as fraud prevention agencies

· The data they hold and how they use it

· How they share personal information

· How long they can keep data

· Your data protection rights.

Here are links to the information notice for each of the three main Credit Reference Agencies:

· TransUnion

· Equifax

· Experian

We use these agencies mainly with UK, Isle of Man or EEA products and customers. For non-UK, Isle of Man or EEA products and customers, we may not use these agencies. We may instead use other regional CRAs.

Fraud Prevention Agencies (FPA’s)

This section deals with information we share outside our group to help fight financial crime. This includes crimes such as fraud, money-laundering and terrorist financing.

We may need to confirm your identity before we provide products or services to you or your business. This may include carrying out fraud checks at the point of sale.

Once you have become a client of ours, we will share your personal information as needed to help combat fraud and other financial crime. The organisations we share data with are:

· Registered Fraud Prevention Agencies

· Other agencies and bodies acting for the same purpose

· Industry databases used for this purpose

· Insurers

Throughout our relationship with you, we and these organisations exchange data to help prevent, deter, detect and investigate fraud and money-laundering.

We and these organisations can’t use your personal information unless we have a proper reason to do so. It must be needed either for us to obey the law, or for a ‘legitimate interest’.

When we have a business or commercial reason of our own to use your personal information, this is called a ‘legitimate interest’. We will tell you what that is, if we are going to rely on it as the reason for using your personal information. Even then, it must not unfairly go against your interests.

We will use the personal information to:

· Confirm identities

· Help prevent fraud and/or money-laundering

· Fulfil any contracts you or your business has with us.

· We or an FPA may allow law enforcement agencies to access your personal information. This is to support their duty to prevent, detect, investigate and prosecute crime.

These other organisations can keep personal information for different lengths of time, up to six years.

These are some of the kinds of personal information that we use:

· Name

· Date of birth

· Residential address

· Contact details, such as email addresses and phone numbers

· Financial data

· Whether you have been a victim of fraud

· Data about your or your business’s products or services

· Employment details

The right to withdraw consent

You have the right to withdraw your consent for us to use your personal information at any time. This will only affect the way we use personal information when our reason for doing so is that we have your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. If this is so, we will tell you.