Privacy Statement
At Hawk Lending Limited (“HLL”), we are committed to protecting and respecting your privacy and have created this Privacy Statement to explain to you what information we collect, why we collect it, how we process your information and who it will be shared with.
Definitions
“We”, “our” or “us” – means HLL.
“You or “your” – means any person using the services of HLL.
Who we are and what we do
The Hawk Group of Companies comprises of HLL and associated Jersey companies, all of which are registered as a data controller under the Data Protection (Jersey) Law 2018.
HLL provides debt and debt-equity solutions to private individuals and corporations alike. HLL specialises in property development loans, commercial loans, bridging finance, and private mortgages.
Changes to the Privacy Statement
We will regularly review and update this Privacy Statement internally as well as to comply with changes in the Data Protection (Jersey) Law 2018 and applicable legislation. We reserve the right to change our Privacy Statement at any time and you should check the Privacy Statement from time to time to ensure that you are happy with any changes. By continuing to submit your personal information to us, you agree to our Privacy Statement.
We strongly urge you to familiarise yourself with our Privacy Statement and let us know if you have any questions by speaking to us or sending an email to dpo@hawkgroupltd.com
What information we collect about you
The personal information we collect about you will depend on the products and services you use. We have set out examples of the types of information, we may collect about you.
- Name
- Address
- Date of birth
- Nationality
- Marital status
- Telephone number (home and mobile)
- Email address
- Professional and employment information
- Financial information
- Professional advisers’ details
- Bank account details
- Your marketing and communication preferences
- Personal data available in the public domain
Why we collect information about you
We need to collect and hold information about you, in order to:
- deal with your enquiry and to provide you with information you need
- process your application
- manage and administer your product
- manage our relationship with you
- carry out RiskScreen/credit reference checks/credit checks
- comply with our legal and regulatory obligations
- obtain professional advice
- carry out arrears and debt collections
- respond to any complaints you make
- defend, pursue, or establish a legal claim
- send direct marketing where we can do so by law
- use for other legitimate business purposes
Sensitive Data
We do not collect any Sensitive Data about you. Sensitive data refers to data that 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. We do not collect any information about criminal convictions and offences. We do not carry out automated decision making or any type of automated profiling.
How we process information about you
We will use the personal information you provide in a way which conforms to the Data Protection (Jersey) Law 2018 and to:
- follow your requests and instructions
- conduct administrative or operational processes within our business
- perform a contract which we have with you
- work with our agents and advisers who we use to help with the services which we provide
- invite you to events
- review and process your application should you apply for an employment position with us
Who will it be shared with
Your personal information will be used by HLL or shared with the Hawk Group of Companies, primarily for business and operational purposes.
We may share your personal information outside HLL and these disclosures may include but not limited to:
- IT and communication service providers
- HLL appointed accountants and advisers
- legal advisers who we may instruct from time to time
- other professional service providers
- counterparties to transactions
- regulators
- law enforcement agencies
- government institutions
- referees should you apply for employment
Your personal information will not be passed to organisations for marketing, sales, or any commercial use without your prior express consent.
If another entity acquires us, all or part of our assets, your personal information will be disclosed to such entity as part of the due diligence process and will be transferred to such entity as one of the transferred assets.
Emails
If you email us, we may keep a record of your email address and a copy of the email for record-keeping purposes.
With security in mind, we suggest that you keep the amount of confidential information you send to us via email to a minimum.
We will not share your email address or your email contents unless it is necessary for us to do so; either to fulfil your request for a service; to comply with a legal and/or regulatory obligation, or where permitted under other legislation.
Telephone calls
We do not record or monitor any telephone calls you make to us using recording equipment, although if you leave a message on our voicemail systems your message will be kept until we are able to return your call or make a note of your message. File notes of when and why you called may be taken for record-keeping purposes. We will not pass on the content of your telephone calls unless it is necessary for us to do so; either to fulfil your request for a service; to comply with a legal obligation, or where permitted under other legislation.
Marketing Communications
Our lawful ground of processing your personal information to send you marketing communications is with your consent or for a legitimate interest.
You can opt out of receiving marketing communications from us at any time. If you wish to opt out, please send an email to dpo@hawkgroupltd.com or send a letter.
If you opt out of receiving marketing communications this opt-out does not apply to personal information because of other transactions, such as products and services provided.
Before we share your personal data with any third party for their own marketing purposes, we will get your express consent.
HLL has a LinkedIn page. LinkedIn is owned by Microsoft and HLL is not responsible for the information that is collected by LinkedIn once you land on the page.
International data transfer
If we do transfer personal data outside the European Economic Area (“EEA”), we will make sure that it is protected in the same way as if it were being used in the EEA. We will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data.
We may transfer your personal data to countries that the EEA have approved as providing an adequate level of protection for personal data by; or
if we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place; or
where we use certain service providers who are established outside of the EEA, we may use specific contracts or codes of conduct of certificate mechanisms approved by the EEA which give personal data the same protection it has in Europe.
If none of these safeguards are available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
Data Security
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data to those employees who have a business need to know such data.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.
Data Retention
We will endeavour to keep your information accurate and up to date and for as long as the purposes for which the personal information was collected for, in order to satisfy any legal, accounting, or reporting requirements and as required by data protection laws and any other applicable laws or regulatory requirements. The secure destruction of electronic data will be in co-ordination with our IT service provider and confidential hard copy data will be shredded.
Please let us know if at any time your personal information changes.
Your Rights
You can ask us to stop processing your information
You have the right to request that we stop processing your personal data in relation to any of our services. However, this may cause delays or prevent us delivering a service to you. Where possible we will seek to comply with your request, but we may be required to hold or process information to comply with a legal and/or regulatory requirement.
You can withdraw your consent to the processing of your information
In the few instances when you have given your consent to process your information, you have the right to withdraw your consent to the further processing of your personal data. However, this may cause delays or prevent us delivering a service to you. We will always seek to comply with your request, but we may be required to hold or process your information in order to comply with a legal and/or regulatory requirement.
You can ask us to correct or amend your information
You have the right to challenge the accuracy of the information we hold about you and request that it is corrected where necessary. We will seek to ensure that corrections are made not only to the data that we hold but also any data held by other organisations/parties that process personal data on our behalf.
You request that the processing of your personal data is restricted
You have the right to request that we restrict the processing of your personal information. You can exercise this right in instances where you believe the information being processed is inaccurate, out of date, or there are no legitimate grounds for the processing. We will always seek to comply with your request, but we may be required to continue to process your information in order to comply with a legal requirement.
You can ask us for a copy of the information we hold about you
You are legally entitled to request a copy of any personal information that we hold about you which is commonly known as a data subject access request. You will not have to pay a fee to access your personal information, but we do reserve the right to charge a reasonable fee if your request for access is clearly unfounded or excessive.
Who can I contact?
If you have any questions in respect of the Privacy Statement or wish to exercise any of your rights, please send your request by email to dpo@hawkgroupltd.com or alternatively by post to The Director, Hawk Lending Group Limited, Hawk House, 22 Esplanade, St. Helier, Jersey. JE1 1 HH.
If you are dissatisfied with our response and you wish to make a formal complaint, the contact details are as follows:
Office of the Information Commissioner
2nd Floor, 5 Castle Street, St. Helier, Jersey. JE2 3BT.
Complaints procedure:
Hawk Lending Limited is committed to providing a high-quality service to everyone we deal with.
Our policy is to treat as a complaint any expression of dissatisfaction with our service which calls for a response. We listen to your complaints, treat them seriously, and learn from them so that we can continuously improve our service.
A complaint is an expression of dissatisfaction, whether justified or not.
We want to help you resolve your complaint as quickly as possible and we treat all complaints seriously.
How to report a complaint:
If you have a complaint, you can contact the Managing Director by email kiri@hawkgroupltd.com or put in writing to the Managing Director, Hawk Lending Limited, Ground Floor, Hawk House, 22 Esplanade, St. Helier, Jersey. JE1 1HH. Alternatively, you can call 01534 708760.
How we deal with any complaint that is referred to us
We will provide in writing, within 5 business days, unless expressly agreed by the complainant to the contrary, an acknowledgment that their complaint has been received and confirm that the complaint is being considered.
We will investigate the complaint and determine the outcome in writing. The final response will be sent promptly but usually within 8 weeks of first receiving the complaint and, in any event, within 3 months of first receiving the complaint.
If the complaint is upheld, the investigation will also determine what, if any, redress, or remedy is appropriate.
Your rights:
If you remain dissatisfied with the final response or at least 90 days has passed since you first made the complaint which remains unresolved, you can refer the complaint to the Channel Islands Financial Ombudsman Further details can be found on their website: https://www.ci-fo.org/about/how-we-work/
CIFO contact details:
Email address: enquiries@ci-fo.org
By telephone: +44 (0) 1534 748610
By mail to:
Channel Islands Financial Ombudsman (CIFO)
P O Box 114
Jersey, Channel Islands
JE4 9QG
