Privacy Policy

Walmer Finance Ltd

1. Introduction

This is our privacy policy. It tells you how we collect and process data received from you, including how we process data in relation to our clients, potential clients, suppliers, business contacts and visitors of our site. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

This policy applies to Walmer finance ltd and its website https://walmergroup.com/

If you have any comments on this privacy policy, please email them to [email protected]

2. Who We Are

Here are the details that the retained version of the General Data Protection Regulation (UK GDPR) says we have to give you as a ‘data controller’:

• Our site address is https://walmergroup.com/
• Our company is Walmer Finance Limited, registered in England with its registration number 12444849 and registered address at184 Shepherds Bush Road, Hammersmith, W6 7NL, London
• Our Data Protection contact can be contacted via [email protected]
• We are registered with the Information Commissioner’s Office under registration number ZB205229

3. What information we collect

We collect and process the following data about you:

• Identity data, including name, username, job position and similar identifiers.
• Contact data, including email address, postal address, LinkedIn account information and telephone numbers.
• Financial data, including limited information such as last 4 digits of payment cards and bank accounts as a reference for future support from payment providers who collect all the necessary payment details directly.
• Transaction data, including details about payments to and from you and other details of products / services you have purchased from us or products/ services we have purchased from you.
• Technical data, including IP address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology you use to access our site.
• Profile data, including your interests, preferences, feedback and survey responses.
• Usage data, including information on event logs generated from actions taken by the users (clients) on our system, how you use our website and products and services that you purchase from us.
• Marketing and communication data, including your preferences in receiving marketing from us and your communication preferences.

We also collect, use and share Aggregated data such as statistical or demographic data. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage data to calculate the percentage of users accessing a specific website feature.

We will not specifically collect any Special Categories of Personal Data about you (this 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.

Under UK GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:

1. you have given consent to the processing of your personal data for one or more specific purposes;
2. processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
3. processing is necessary for compliance with a legal obligation to which we are subject;
4. processing is necessary to protect the vital interests of you or of another natural person;
5. processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
6. processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our credit card payment processing, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data.

4. Cookies

We use cookies – please see our Cookie Policy for further information.

5. How we use what we collect

We use information about you to:

• Present site content effectively to you.
• Provide information and services that you request, or (with soft opt-in following your registration, your consent or if we have another lawful basis, such as legitimate interest) which we think may interest you.
• Carry out our contracts with you.
• Tell you our charges.

If you are already our client, we will only contact you electronically about things similar to what was previously sold to you and you will be given an opportunity to opt-out and unsubscribe from further communications.

If you don’t want us to use your personal data for any of the reasons set out in this section 5, you can let us know at any time by contacting us using unsubscribe links that we include with our every marketing communication or by emailing [email protected], and we will delete your data from our systems or mark accordingly. However, you acknowledge this may limit our ability to provide our services or relevant information to you.

In some cases, the collection of personal data may be a statutory or contractual requirement, and we will be limited in the products and services we can provide you if you don’t provide your personal data in these cases.

Please find below further information as to the purposes and lawful basis of the personal data that we collect and process. Information on how we process personal data collected using cookies is contained in our Cookie Policy.

Type(s) of data subject	Categories of personal data	Purpose of processing	Lawful basis
Clients, their employees and contractors	Contact information, including: Name, address, telephone number and e-mail address Communication data including e-mail communication, text and other messaging services Financial data including some limited bank account and payment card details Transaction data including details about payments to and from clients	Provision of services Transactional and security purposes	Necessary for the performance of a contract
Clients, their employees and contractors	Contact information, including name, address, telephone number and e-mail address	Marketing communications	Consent OR Soft opt-in in case of existing or previous clients and those enquiring about our services
Suppliers, partners, subcontractorsand their employees	Contact information, including name, address, telephone number and e-mail address; bank details	To enable compliance with obligations under relevant contracts, includingprocessing order, refunds, logging and payment of invoices.	Necessary for the performance of a contract
Business contacts and potential clients	Contact information, including name, company name, job position, address, telephone number and e-mail address, including those available in the public domain, such as via business networking websites including LinkedIn and others	Business networking and marketing	Legitimate interests of all parties 1. Our and our business contacts’/ potential clients’ legitimate interests in order to network in the context of business and provide some marketing information. 2. It is necessary to exchange, keep and otherwise process contact information in order to network in the context of business and provide marketing information. 3. There is normally a positive action taken by all parties to provide their contact details during networking with the expectation that such contact details, including personal data, may be used by the recipient for business networking. For marketing – using personal data made by the data subject in his or her business capacity public by placing their personal data in the public domain the data subject may reasonably expect a certain amount of marketing material. If we collect personal data for marketing purposes in this way, we will always provide a link to our privacy policy and give an opportunity to object to receiving further marketing from us with our every marketing communication.

6. Where we store your data

We will generally store your personal data within the UK or the European Economic Area (EEA) and we may transfer your collected data to storage or companies based outside of the UK and EEA. It may be processed outside the UK and EEA as may be necessary to provide our products and/or services to you, to deal with payment, or if we have your consent.

We will only transfer your data to countries that are deemed to have an adequate level of protection of personal data by the European Commission; or we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe, such as the relevant version of the Standard Contractual Clauses.

By giving us your personal data, you agree to this arrangement. We will do what we reasonably can to keep your data secure, including such measures as usernames, passwords and encryption.

If we give you a password, you must keep it confidential. Please don’t share it. We make sure that passwords are securely encrypted we use various other measures including passwords and encryption. Although we try to provide protection, we cannot guarantee complete security for your data, and you take the risk that any sending of that data turns out to be not secure despite our efforts.

We only keep your personal data for as long as we need to in order to use it as described above in section 5, and/or for as long as we have your permission to keep it. Our general retention period for accounting and legal reasons is 7 years but your data may be kept for shorter or longer periods of time, in accordance with our data retention procedures. In any event, we will conduct regular reviews to ascertain whether we need to keep your personal data. Your personal data will be deleted if we no longer need it.

7. Disclosing your information

We are allowed to disclose your information in the following cases:

• If we want to sell our business, we can disclose it to the potential buyer.
• We can disclose it if we have a legal obligation to do so, or in order to protect other people’s property, safety or rights.
• We can exchange information with others to protect against fraud or credit risks.

We may contract with third parties to supply our services to you on our behalf. These may include payment processing, search engine facilities, web hosting, consulting, advertising, marketing and lead generation. In some cases, the third parties may require access to some or all of your data. These are the third parties that have access to your information:

• Accounting companies, as may be required for our compliance with statutory obligations and financial calculations – identity, contact, financial and transactional data
• KYC/AML and Due dilligence companies, as may be required for our compliance with statutory obligations and financial calculations – identity, contact, financial and transactional data
• IT and hosting services providers, as may be necessary for the provision of their services to us – identity data, contact data, financial data, transaction data, technical data, profile data, usage data and/or marketing and communications data
• Payment processing companies, as may be necessary for the provision of their services identity data, contact data, financial data and transaction data
• Banks, as may be necessary for the provision of their services to us – identity data, contact data, financial data and transaction data
• Insurance companies, as may be necessary for the provision of their services to us – identity data, contact data, financial data and transaction data
• Debt collection agencies, as may be necessary for the provision of their services to us – identity data, contact data, financial data and transaction data
• Marketing services/ CRM providers including Hubspot, as may be necessary for the provision of their services to us – identity data, contact data and transaction data
• Services to analyse the traffic visiting our site and to support users – identity data and contact data
• Telecommunication services providers, as may be necessary for the provision of their services to us – identity data, contact data, financial data, transaction data, technical data, profile data and usage data
• Other services providers, including law firms and documents services – identity data, contact data, financial data and/or transaction data as may be required for the provision of the relevant services
• Governmental authorities, as may be necessary in order for us to comply with statutory requirements and official requests – identity data, contact data, financial data, transaction data, technical data, profile data, usage data, marketing and communication data.

Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under UK GDPR and the law.

8. Your rights

You can ask us not to use your data for marketing. You can do this by ticking the relevant boxes on our forms, clicking the unsubscribe link contained in our marketing communications or by contacting us at any time at [email protected]

Under the UK GDPR, you also have the right to:

• request access to, deletion of or correction of, your personal data held by us at no cost to you;
• request that your personal data be transferred to another person (data portability);
• be informed of what data processing is taking place;
• restrict processing;
• to object to processing of your personal data; and
• complain to a supervisory authority.

You also have rights with respect to automated decision-making and profiling.

To enforce any of the foregoing rights or if you have any other questions about our site or this Privacy Policy, please contact us at [email protected]

9. Links to other sites

Please note that our terms and conditions and our policies will not apply to other websites that you get to via a link from our site.We have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

10. Changes

This Policy was last updated on 26 January 2022. If we change our Privacy Policy, we will post the changes on this page.

11. Automated Decision-Making and Profiling

We do not undertake any automated decision-making, including profiling.