Privacy Statement

How Your Personal Information is Used by NAK

Your information will be held by NAK Consulting Services Limited (“NAK”). This privacy notice is to let you know how NAK promises to look after your personal information. This includes what you tell us about yourself, what we learn by having you as a customer, and the choices you give us about what marketing you want us to send you. This notice explains how we do this and tells you about your privacy rights and how the law protects you.

Our Privacy Promise

NAK Promise:

• To keep your data safe and private

• Not to sell your data

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

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How the Law Protects You

As well as our Privacy Promise, your privacy is protected by law. This section explains how that works.
Data Protection law says that we are allowed to use personal information only if we have a proper reason to do so. This includes sharing it outside NAK.

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.

A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you. If we rely on our legitimate interest, we will tell you what that is.

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.

Groups of Personal Information

We use many different kinds of personal information, and group them together like this:

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Where We Collect Your Personal Information From

​We may collect personal information about you (or your business) from these sources:

Data you give to us:

• ​When you apply for our products and services

• When you talk to us on the phone or in person

• When you use our website

• In emails and letters

• In insurance claims or other documents

• In account reviews and meetings

• In customer surveys

Data we collect when you use our services. This includes the amount, frequency, type, location, origin and recipients:

• Payment and transaction data.

• Profile and usage data. This includes the profile you create to identify yourself when you connect to our managed technology services. It also includes other data about how you use those services. We gather this data from devices you use to connect to those services, such as computers and mobile phones.

Data from third parties we work with:

• Credit reference agencies

• Insurers

• Cloud Service Providers

• Hardware and Software Vendors

• Fraud prevention agencies

• Payroll service providers

• Public information sources such as Companies House

• Official Regulators

• Agents working on our behalf

• Market researchers

• Government and law enforcement agencies

 Who We Share Your Personal Information With

We may share your personal information with affiliates, vendors, subcontractors or other service-providers carrying out services on your behalf as well as the following organisations:

• HM Revenue & Customs, regulators and other authorities

• Credit reference agencies

• Fraud prevention agencies

• Any party linked with you or your business’s product or service

• Companies we have a joint venture or agreement to co-operate with

• Companies that we introduce you to

• Market researchers

• Companies you ask us to share your data with

We may need to share your personal information with other organisations to provide you with the product or service you have chosen:

• If you use direct debits, we will share your data with the Direct Debit scheme.

• If you make an insurance claim, information you give to us or the insurer may be put on a register of claims. This will be shared with other insurers

We may also share your personal information if the make-up of NAK changes in the future:

• We may choose to sell, transfer, or merge parts of our business, or our assets. Or we may seek to acquire other businesses or merge with them.

• During any such process, we may share your data with other parties. 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.

How We Use Your Information to Make Automated Decisions

We sometimes use systems to make automated decisions based on personal information we have or are allowed to collect from others, about you or your business. This helps us to make sure our decisions are quick, fair, efficient and correct, based on what we know. These automated decisions can affect the products, services or features we may offer you now or in the future, or the price that we charge you for them.

Here are the types of automated decision we make:

Pricing

We may decide what to charge for some products and services based on what we know about there usage.

Tailoring Products and Services

We may place you in groups with similar customers. These are called customer segments. We use these to study and learn about our customers’ needs, and to make decisions based on what we learn. This helps us to design products and services for different customer segments, and to manage our relationships with them.

Detecting Fraud

We may detect that an account is being used in ways that fraudsters work, or we may notice that an account is being used in a way that is unusual for you or your business. If we think there is a risk of fraud, we may stop activity on the accounts or refuse access to them.

Opening Accounts

When you open an account with us, we check that the product or service is relevant for your business, based on what we know. We also check that you or your business meets the conditions needed to open the account. This may include checking your businesses financial position.

​Your Rights

As a person you have rights over automated decisions.

• You can ask that we do not make our decision based on the automated score alone.

• You can object to an automated decision and ask that a person reviews it.

If you want to know more about these rights, please contact us.

Credit Reference Agencies (CRAs)

We may 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 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

• Public information, from sources such as Companies House

We’ll use this data to:

• Assess whether you or your business is able to afford to make repayments

• Make sure what you’ve told us is true and correct

• Help detect and prevent financial crime

• Manage accounts with us

• Trace and recover debts

We will go on sharing your personal information with CRAs for as long as you are a customer. This will include details about your settled accounts and any debts not fully repaid 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.

If you apply for a product with someone else, we will link your records with theirs. We will do the same if you tell us 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 is 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 will 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.

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

The three main Credit Reference Agencies NAK would use are:

•    Callcredit

•    Equifax

•    Experian

Sending Data Outside of the EEA

NAK will not send your personal or business data outside of the European Economic Area (‘EEA’)

If You Choose Not to Give Personal Information

We may need to collect personal information by law, or under the terms of a contract we have with you.

If you choose not to give us this personal information, it may delay or prevent us from meeting our obligations. It may also mean that we cannot perform services needed to run your accounts or policies. It could mean that we cancel a product or service you have with us.

Any data collection that is optional would be made clear at the point of collection.

Marketing

We may use your personal information to tell you about relevant products and offers. This is what we mean when we talk about ‘marketing’. The personal information we have for you is made up of what you tell us, and data we collect when you use our services, or from third parties we work with.

We study this to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

We can only use your personal information to send you marketing messages if we have either your consent or a ‘legitimate interest’. That is when we have a business or commercial reason to use your information. It must not unfairly go against what is right and best for you.

You can ask us to stop sending you marketing messages by contacting us at any time. Whatever you choose, you’ll still receive statements, and other important information such as changes to your existing products and services.

We may ask you to confirm or update your choices, if you take out any new products or services with us in future. We will also ask you to do this if there are changes in the law, regulation, or the structure of our business.

If you change your mind you can update your choices at any time by contacting us.

How Long We Keep Your Personal Information

We will keep your personal information for as long as you are a customer of NAK Consulting Services Limited

After you stop being a customer, we may keep your data for up to 15 years for one of these reasons:

• To respond to any questions, complaints or potential legal disputes

• To show that we treated you fairly

• To maintain records according to rules or legislation that apply to us

We may keep your data for longer than 10 years if we cannot delete it for legal, regulatory or technical reasons.

Third Party Processors

Our carefully selected partners and service providers may process personal information about you on our behalf as described below:

Digital Marketing Service Providers

We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information. Our appointed data processors include:

• Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: https://sopro.io – Sopro are registered with the ICO Reg: ZA346877 and their Data Protection Officer can be emailed at: dpo@sopro.io

How to Get a Copy a Your Personal Information

You can access a copy of your personal information by writing to us at this address:

FAO: Data Privacy Officer,
NAK Consulting Services Limited
Suite 2b, Portman House,
300 Pavilion Drive,
Northampton, NN4 7YE

Future Formats for Shared Data

The General Data Protection Regulation (GDPR) came into force at 5pm on Friday 25th May 2018.

From this point onwards, you have the right to get your personal information from us in a format that can be easily re-used. You can also ask us to pass on your personal information in this format to other organisations.

Letting Us Know Your Data Is Incorrect

You have the right to question any information we have about you that you think is wrong or incomplete. Please contact us if you want to do this.

If you do, we will take reasonable steps to check its accuracy and correct it.

What if You Want Us to Stop Processing Your Information?

You have the right to object to our use of your personal information, or to ask us to delete, remove, or stop using your personal information if there is no need for us to keep it. This is known as the ‘right to object’ and ‘right to erasure’, or the ‘right to be forgotten’.

There may be legal or other official reasons why we need to keep or use your data. But please tell us if you think that we should not be using it.

We may sometimes be able to restrict the use of your data. This means that it can only be used for certain things, such as legal claims or to exercise legal rights. In this situation, we would not use or share your information in other ways while it is restricted.

You can ask us to restrict the use of your personal information if:

• It is not accurate.

• It has been used unlawfully but you don’t want us to delete it.

• It not relevant anymore, but you want us to keep it for use in legal claims.

• You have already asked us to stop using your data but you are waiting for us to tell you if we are allowed to keep on using it.

If you want to object to how we use your data or ask us to delete it or restrict how we use it or, please contact us.

How to Withdraw Consent

You can withdraw your consent at any time. Please contact us if you want to do so.

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.

How to Complain

Please let us know if you are unhappy with how we have used your personal information. You also have the right to complain to the Information Commissioner’s Office. Find out on their website how to report a concern.