1. WHO ARE WE?
1.1. We are Rhea Group Ltd, a company registered in England and Wales under registration number 07443570, (from now on referred to as "Rhea", "we", "us", or "our" in this Privacy Policy). This Privacy Policy applies to both Rhea Professions Finance and Rhea Family Finance which are both trading names of Rhea, as well as any parent and/or subsidiary entity of Rhea Group Ltd (the “Rhea Group”). This Privacy Policy is issued on behalf of Rhea Group so when we mention "Rhea", "we", "us" or "our" in this Privacy Policy, we are referring to the relevant company in Rhea Group responsible for processing your data. We will let you know which entity will be the controller for your data when you purchase a product or service with us. Rhea Group Ltd is the controller and responsible for the Sites (as defined in clause 2.2 below).
1.2. Thank you for your interest in Rhea. Rhea provides funding solutions for both businesses and individuals under two trading styles:
i. Rhea Professions Finance (“RPF”): RPF provide business funding for professional indemnity insurance premiums, tax and VAT liabilities and other working capital requirements.
ii. Rhea Family Finance (“RFF”): RFF provide funding to individuals for the purpose of financing their legal fees and other incidental costs incurred in the course of their matrimonial litigation proceedings.
1.3. Our registered office is Yew Tree House, Lewes Road, Forest Row, East Sussex RH18 5AA.
2. WHAT THIS PRIVACY POLICY IS FOR
2.1. Purpose. Rhea is committed to ensuring that your privacy is protected and to processing your personal data in accordance with the General Data Protection Regulation (EU) 2016/679 ("GDPR"), the Privacy and Electronic Communications (EC Directive) Regulations 2003 and other applicable privacy laws. We will only collect and use your personal data as detailed in this Privacy Policy.
2.2. Do you agree with this Privacy Policy? By continuing to use any of our websites: rheagroup.co.uk, rheaprofessions.co.uk or rheafamily.co.uk (the "Sites"), or by entering into an agreement with Rhea for the provision of financial services (together, the "Services"), you confirm that you have read, understood and agree with our entire privacy policy, which incorporates by reference our website terms (the "Site Terms") (together, our "Privacy Policy") as it is in effect at the time of your use. If you do not agree, then you must not use or continue to use our Services.
2.3. What it covers and what it does not cover. Our Privacy Policy applies to you when you use our Services.
This Privacy Policy gives information about:
a) why we collect, store, share and use personal data (such as information that identifies, relates to or describes
you, or which is capable of being associated with you);
b) what personal data we collect;
c) the choices we offer, including how to access and update your personal data; and
d) our use of cookies and how you may disable such cookies.
It does not apply however to the practices of companies that Rhea does not own or control. You will be subject to the terms and conditions of use and privacy policies of those other websites or companies when you are using them.
2.4. Updates. By accessing or using any part of our Services, you consent to be bound by this Privacy Policy (as it is updated from time to time). We may change and update it from time to time and we show the effective date of the currently applicable Privacy Policy at the beginning of it. Any updates to our Privacy Policy can be found on our Sites. We recommend that you revisit this page regularly to keep up to date and to make sure that you are happy with changes. Updates and changes are legally binding upon you as soon as we post them (superseding any prior policy that may apply) whether or not we provide you any other notice of such changes.
3. WHAT PERSONAL DATA DO WE COLLECT FROM YOU?
We can only provide our services if we collect personal data.
3.1. How we collect personal data. We may collect your personal data when you use our Services. The term "use" includes:
a) making an application for credit or financial services;
b) making an application to provide a guarantee for our customers and prospective customers;
c) obtaining a quote for credit or financial services;
d) undertaking transactions (whether or not on or via the Sites);
e) accessing or browsing the Sites;
f) communicating with us whether by email, telephone or signing up for newsletters or any other forms;
g) completing online or paper forms; and
h) registering an account with us.
We may also collect your personal data from publicly available information such as information on third party websites, from our business partners who have your consent to pass it on or who are authorised by you to authenticate or identify you to us or enable you to sign in to our Sites using their credentials, or from credit reference agencies and other data processors when assessing whether to provide or providing you with Services.
We may also collect your personal data when we monitor and record email and telephone communications with you or between you and others who are using our systems or those of our agents acting on our behalf.
3.2. What personal data is collected? We may collect all or some of the following personal data from or about you:
a) your name, title, gender and date of birth;
b) your company name or affiliation;
c) your contact information including phone/mobile number/fax and email address;
d) your bank account details, credit/debit card information or other payment system information including your billing and delivery postal addresses;
e) your financial details and credit and payment history;
f) other demographic information including your home, business or other addresses and postcode;
g) your communication and purchase preferences and interests;
h) other information relevant to customer surveys and/or offers which we may make available to you;
i) your browsing, online activities and transactions;
j) where you have registered with us, your user name and password; and
k) in the case of Rhea Family Finance only, information about your personal circumstances which could include information about your family, social and domestic life. Some of this data could be very sensitive.
4. WHAT WE DO WITH YOUR PERSONAL DATA
4.1. Why we collect personal data. We (and those acting on our behalf) collect, store and process your personal data for the following reasons:
a) to make our Services available, to customise them, to provide our Services tailored to individual requirements,
b) to understand your needs, and to provide you with improved Services, newsletters and other communications;
c) for purposes related to providing our Services to you, including verifying and authenticating your identity, processing your payments, providing finance, and to complete transactions with us or our business partners;
d) for on-going account maintenance and administrative purposes;
e) to communicate with third party credit reference agencies to perform credit checks on you or on your behalf;
f) to maintain any registered accounts that you may hold with us and to provide you with updates or notifications of changes to your account and our policies and terms;
g) for our internal record keeping requirements including collection of anonymised details about you to compile aggregate statistics or produce internal reports;
h) with your agreement, to contact you about our or our business partners' promotions, products and services or other information which we think you may find interesting, offers, or for customer satisfaction purposes (including contact by email);
i) for market research, analysis, testing, monitoring, risk management and administrative purposes (including diagnosing technology problems which may be reported to us); and
j) for any purposes related to the above or where we have a legal right or duty to use or disclose your personal data (including for abuse, crime and fraud prevention and related purposes).
4.2. E-mail messaging from us and messaging through RFF’s online portal. We may communicate with you by e-mail and, in the case of RFF only, through a messaging function on RFF’s secure online portal in addition to telephone, fax and letter. We may use e-mails and/or the messaging function on RFF’s secure online portal to notify you of the results of credit checks, provide you with updates or important developments relating to our Services or to generally communicate with you regarding our Services.
4.3. Telephone and email monitoring. We may also collect your personal data for quality assurance, compliance and training purposes by monitoring and recording email and telephone communications with you or between you and third parties using our systems or our agents.
4.4. Storing payment details. When you conduct a transaction with us over the telephone, using a paper application form or through our Sites, we may offer to retain your payment details for your convenience to save you having to re-enter these details on a future occasion. If you prefer that we do not maintain these details, you may edit and delete any card or payment system information that we hold about you when using our Sites or ask an agent to remove these details from our systems if communicating with us via telephone.
4.5. Disclosing to others. In terms of sharing, disclosing or transferring your personal data to third parties (each a "Disclosure"), Rhea may disclose any personal data as set out in this Privacy Policy and if:
4.5.1. in the opinion of Rhea reached in good faith (which shall be conclusive and binding), Disclosure is necessary or desirable for Rhea to perform its functions in relation to the Services; or
4.5.2. Disclosure is to any person who provides a service to, or performs a function for, Rhea or who is otherwise appointed by Rhea in connection with the Services or who is acting as Rhea's agent or sub-contractor (including their agents) including without limitation, financial institutions and legal and other professional advisors provided that where Rhea discloses information to any such person Rhea shall ensure that such person uses such information for the same purposes as it was originally supplied to Rhea and/or used by Rhea; or
4.5.3. Disclosure is to other members of Rhea Group in connection with any Service provided to you; or
4.5.4. Disclosure is required to comply with any applicable law or order of a governmental or law enforcement body; or
4.5.5. Disclosure is required to investigate, prevent or take action against suspected illegal activities (including fraud or where the personal safety of another person may be threatened) or any breach of our terms; or
4.5.6. Disclosure is required to establish or exercise our legal rights or defend against legal claims; or
4.5.7. Disclosure is to any third party as a result of any merger, restructure, sale or acquisition of any company within Rhea Group or to anyone to whom Rhea may transfer its rights and/or obligations provided that any recipient uses information for the same purposes as it was originally supplied to Rhea and/or as used by Rhea; or
4.5.8. Disclosure is required for any purpose permitted in accordance with clause 5.
4.6. When disclosing your personal data, we may use email or other methods.
4.7. Keeping your personal data. We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.
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 and regulatory requirements.
4.8. International transfers of data. We may transfer personal data that we collect from you to third party data processors, vendors or hosting partners acting on our behalf located in countries outside of the European Economic Area ("EEA") or to other entities in our group of companies in connection with the purposes set out above. We will only transfer your personal information outside the EEA where either the transfer is to a country which the EU Commission has decided ensures an adequate level of protection for your personal information, or we have put in place adequate safeguards as required by applicable data protection law.
5. CREDIT REFERENCE AGENCIES
5.1. In relation to any of your personal data or personal data in respect of any person other than yourself which you provide to us, you acknowledge, or confirm that you have made the relevant individual aware, that in accordance with this Privacy Policy, we may use or disclose such personal data to our suppliers (including credit reference agencies and fraud prevention agencies) and other organisations may access and use this information to prevent and detect fraud, money laundering and other crimes and to make credit assessments. Examples of circumstances when personal data or information relating to you, your guarantor, partner or other members of you or that person's household may be shared include, but are not limited to:
5.1.1. searching for and checking information and details on applications for credit and credit related and other facilities;
5.1.2. recording any such searches as having been made;
5.1.3. managing credit and credit related accounts or facilities;
5.1.4. recovering debt;
5.1.5. checking details on proposals for financial products;
5.1.6. making enquiries when you ask for any lending products; and
5.1.7. for fraud prevention purposes.
5.2. Any enquiry that Rhea makes at a credit reference agency may be assessed with reference to any 'associated' records. Another person's record may be 'associated' with yours when:
5.2.1. you make a joint application (including in relation to any guarantee);
5.2.2. you advise Rhea of a financial 'association' with another person; or
5.2.3. if the credit reference agencies have existing linking or 'associated' records.
This 'association' will be taken into account in all future applications by either or both you and the person whose record is 'associated' and shall continue until either person applies to the credit reference agencies and is successful in filing a 'disassociation'.
5.3. Credit reference agencies keep a record of enquiries and may record, use and give out information that Rhea gives them to other lenders, insurers and other organisations. If false or inaccurate information is provided or fraud is suspected details may be passed to fraud prevention and credit reference agencies. Law enforcement agencies may access and use this information. The information recorded by fraud prevention agencies may be accessed and used by organisations in different countries. If you wish to receive details of the relevant fraud prevention agencies, you may contact Rhea Group Ltd., 70 Gracechurch Street, London, EC3V 0HR.
6. HOW WE USE COOKIES
Our Sites use cookies.
6.1. What are cookies. A cookie is a small data file which asks permission to be placed on your computer's hard drive or other mobile or handheld device as you browse our Sites or advertisements, videos or other types of content and which ‘remembers’ that your computer or device accesses the Sites. If you accept the cookie, the file is added to your computer's hard drive or other mobile or handheld device. Most web browsers automatically accept cookies but you may modify your browser settings to decline cookies or to be notified of cookies being placed. The cookies do not give us access to any other personal data on your computer or device other than the personal data you choose to share with us.
6.2. Why do we use cookies. Cookies may be used by us to do the following:
a) enable us to respond to you as an individual and to tailor our operations to your needs by gathering and remembering personal data about your preferences;
b) assist the effective operation of our Sites;
c) to re-target advertisements or other content on our Sites so that they are displayed when you use third party websites;
d) enable traffic to our Sites and pages to be logged to identify pages used and browsing and purchasing behaviour of users of our Sites for statistical purposes and to monitor which pages users find useful or not; or
e) identify you as an account holder or user and assist with account or user security (such as by obliging you to re-set passwords if the password has lapsed).
6.3. What to do if you do not want us to use cookies. Rejecting cookies may prevent you from taking full advantage of our Sites and may stop our Sites from operating properly when you use it. You may be unable to complete a transaction with us on our Sites. If you do not consent to use of the cookies, you must: disable the cookies by deleting them or amending your cookie settings on your computer; or stop using the Sites
7. INFORMATION SECURITY
We are committed to ensuring that your personal data is secure.
7.1. What we do to protect your information. In order to minimise the risk that there is unauthorised access to or Disclosure of your personal data, we put in place where practicable appropriate physical, electronic and managerial procedures to safeguard and secure it. Although we take appropriate measures to safeguard the personal data that you provide to us, no transmission over the internet is guaranteed to be secure.
7.2. What you should do to protect your information. For your security, you should:
a) if using a computer in a public location, always log out and close the Sites’ browser when you complete your online session;
b) keep your account details and passwords private;
c) frequently change your password; and
d) avoid using the same password for multiple online accounts.
8. YOUR CONTROL OVER YOUR PERSONAL DATA AND ACCESS TO IT
8.1. Your rights. This clause 8.1 explains the rights you have under data protection laws with respect to how your personal data is held and used by us. If you wish to request to exercise any of these rights, you can contact us using the details set out below.
(a) You have the right to withdraw your consent to us processing your personal data at any time if our processing is based on your consent. This will not affect the lawfulness of any processing of your personal data that we carried out before your withdrawal. If you choose to withdraw your consent to us processing your personal data, we may not be able to perform your contract with us for the relevant service or provide other products or services to you.
(b) You have the right to access the personal data we hold about you, free of charge.
(c) You have the right to ask us (and third parties to whom we transfer your personal data) to rectify your personal data if it becomes inaccurate. In order for us to do so, you must inform us of any changes to your personal data so that we can keep it up to date.
(d) You have the right to ask us to erase your personal data where there is no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions. We may not be able to perform your contract with us for the relevant service or provide other products or services to you if you ask us to erase your personal data.
(e) You have the right to restrict our further processing of your personal data. Where processing is restricted, we can still store your personal data, but we may not use it further.
(f) You have the right to object to certain types of processing by us of your personal data. Please contact us as noted below, providing details of your objection.
(g) You have the right to 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.
If you believe our processing of your personal data does not comply with data protection laws, you can make a complaint to the Information Commissioner’s Office: ico.org.uk.
8.2. Your choice to consent. You have the choice to restrict our collection or use of your personal data in the following ways:
a) when you are asked by us to accept a cookie or to fill in a form on our Sites, look for your cookie settings and the area that you can click to indicate your preference as to use of your personal data for marketing or other purposes; and
b) if you have previously agreed to accept a cookie, then you may change your mind at any time disabling or deleting the cookie or amending your cookie settings.
You have the choice as to whether we use your personal data to send you promotional or other information about third parties or us. If you consent but later change your mind to receiving such communications, you may contact us and we will cease such activity.
8.3. How to get in touch.
a) Write to us at Rhea Group Ltd, 70 Gracechurch Street, London, EC3V 0HR or customer.services@rheagroup.co.uk; or
b) indicate your consent or withdrawal of your consent to marketing communications by writing to or emailing us at the above address.
9. THE MEANING OF TERMS USED IN THIS PRIVACY POLICY
9.1. In this Privacy Policy the following expressions have the meaning set out in the GDPR: "personal data", "process", and "data processor".
Legal Disclaimer
Rhea Group Ltd uses reasonable care to make sure that the information appearing on this Website is accurate and up-to-date. However, errors and omissions do occur and the user should not take the accuracy of the information for granted but should check directly with Rhea Group Ltd. None of the material contained in this Website is to be relied upon as a statement or representation of fact.
Rhea Group Ltd shall not be liable for any loss of profits or contracts or any direct, indirect or consequential loss, business interruption or loss of data or programs arising out of or in connection with the use of the information either contained within this site or from any of its Hyper link connections, other than death or personal injury to the extent that this is caused by the negligence of Rhea Group Ltd.
Rhea Group Ltd may also make improvements and/or changes to the content of this information at any time without notice. All services, product and product price specifications contained within Rhea Group Ltd Website are subject to change without notice.
INFORMATION PROVIDED ON THE WWW.RHEAFAMILY.CO.UK, WWW.RHEAGROUP.CO.UK AND/OR WWW.RHEAPROFESSIONS.CO.UK WEBSITES ARE PROVIDED "AS IS" WITHOUT ANY WARRANTY OF ANY KIND, EITHER EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, OR NON-INFRINGEMENT, AS SUCH EXCLUSIONS OF IMPLIED WARRANTIES SHALL APPLY PURSUANT TO APPLICABLE LAWS AND REGULATIONS.
Links to Third Party Sites
Rhea Group Ltd cannot and has not reviewed all pages of the Websites linked to the Sites and therefore cannot be liable for their content. Users link to other Websites at their own risk and use such sites according to the terms and conditions of use of such sites.
Rhea Group Ltd provides links to you only as a convenience, and the inclusion of any link does not imply endorsement by
Rhea Group Ltd or the Website.
Copyright
No part of this Website may be copied or imitated in whole or in part. No logo, graphic, sound or image from this Website may be copied or re-transmitted unless expressly permitted in writing by Rhea Group Ltd. (These prohibitions are without limitation to the legal rights of Rhea Group Ltd.)
Any information provided to Rhea Group Ltd in connection with its Website shall be provided by the submitter and received by Rhea Group Ltd on a non-confidential basis. Rhea Group Ltd shall be free to use such information on an unrestricted basis. In particular, we may transfer information between our subsidiary companies in different countries both inside and outside the European Economic Area.
Trademarks
The trademarks and logos (the Trademarks) used and displayed on the Sites are registered and unregistered trademarks of Rhea Group Ltd, and others. They may not be used in any advertising or other publicity materials in relation to the distribution of any information or materials obtained from this Website without the prior written consent of the Trademark owner. (These prohibitions are without limitation to the legal rights of Rhea Group Ltd.)
Governing Law
Any dispute or claim concerning or arising from this Website shall be determined in accordance with the law of England and Wales, and the courts of England and Wales shall have exclusive jurisdiction in determining such disputes or claims.