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Privacy Policy

Last updated September 2024

Our commitment

We are committed to protecting your privacy during your relationship with Conister Bank (“CBL”) and when you visit our website. We recognise our responsibility to keep the information you provide to us confidential at all times.

This privacy notice covers:

How and why we process your personal information;
The sources of information about you;
The parties we may disclose it to;
How long we will retain your information;
What rights you have in respect of your personal data; and
How you can contact us with any further queries or concerns.

The data controller

Conister Bank is the Data Controller for the purposes of the Data Protection Act 2018 and in relation to all the personal data provided to us.

The legal basis for processing your data

The Data Controller may process personal data when any of the following apply:

For the performance of contracts we enter (or may enter) into with you for our services or finance products;
For compliance with legal obligations to which the Data Controller is subject; and
For your and our legitimate interests.

Why do we collect personal information?

We collect your personal information for the following purposes:

To consider proposals from you for our products and/or services, or for considering third-party service agreements, in preparation for the entering into contracts;
To assess your creditworthiness, and that what you have told us is true and correct;
To provide existing customers with our products and/or services, to perform obligations under agreements for products and/or services and maintain our ongoing relationships with you;
To understand how our customers use our products and services to enable us to improve our services to you;
To manage any third-party arrangements required by CFL in order to run our business and provide you with the products and/or services;
To comply with our legal and regulatory obligations as a regulated financial services provider;
To help detect and prevent fraud;
To trace and recover debts;
To develop and carry out marketing activities, send marketing communications and to make sure any offers are relevant for you; and
To consider any applications for employment or sponsorship.

Your personal information is collected and used for the purpose(s) it was provided for, and of which you were aware at the time your information was supplied to us. We will limit the collection of your personal information to only that which is needed in order to satisfy our intended purposes.

It is ultimately your decision as to whether to provide us with any of your personal information, however, please note that if you fail to provide the information we have requested, or you fail to provide accurate information, we may not be able to engage with you further.

What information do we collect and how do we collect it?

In order to fulfil the purposes above, we will need to collect your personal information. We collect it from you when you initially provide it to us, every time you contact us during the administration of your relationship with us, and from additional sources such as background checks and/or references. Information is collected when you meet with us, complete forms, correspond with us, telephone us, or send us an email. We may also get your personal information from an intermediary, for example, a car dealership if you are seeking finance for a vehicle or financial advisor if you have engaged them to find you suitable finance options.

This information can include all, or a combination, of any of the items listed below:

General personal details including your name, date of birth, place of birth, nationality, gender, and marital status;
Your contact details (address, telephone numbers, e-mail);
Employment details such as employment status, employer contact details, benefits and salary information;
Information about previous products and/or services you may have had relevant to your current requirements;
Financial details such as bank account details and/or tax information;
Character references if you are applying for a job with us; and
Publicly available information (generally obtained through internet searches) such as news articles or public register information; which is obtained from background searches or reference checks.

Sensitive information

Certain types of personal information are classed as “sensitive” under the Data Protection legislation, or otherwise referred to as “special categories” of data. This includes information about your health, race, ethnic origin, political opinions, religious or philosophical beliefs, sexual orientation, trade union membership and genetic and biometric data.

We do not need to collect your sensitive personal data during the normal course of our business. However, sometimes we may indirectly come across sensitive information such as your health data. In order to be able to process any sensitive personal data, we will need your consent. In the event we are likely to (or do) come into possession of your sensitive personal data, we will contact you separately to seek your consent for its processing.

How do we use your personal information?

We store and process the personal information that you (or third parties) have provided to us in any or all of the following ways:

To conduct credit searches and background checks if you are seeking our finance or leasing products or services;
To consider any application for employment or sponsorship you may have submitted;
Administrative in order to allow us to perform our obligations under our Terms of Business, credit, lease or hire agreements, or employment contracts you may or have entered into with us;
To supply you with information about product(s) and/or service(s) that either you have requested from us, or wish to provide to us;
To manage our relationship with you;
For general business purposes and to prepare management and accounting information necessary for the conduct of our business, including audit;
To develop and improve products and services;
For market research, analysis and developing statistics;
To make decisions about what products and services we think you may be interested in;
To comply with any and all regulatory and statutory responsibilities;
For the prevention and detection of crime, including AML purposes, fraud detection, and debt collection; and
To develop and improve how we deal with financial crime.
Information you submit through our website may be held and processed by our internet service provider, but it is only held and processed on our behalf and under our strict instruction.

Disclosure of personal information

During the term of your relationship with us we may disclose your personal information to any of the following parties to allow us to properly manage our relationship with you:

The Manx Financial Group PLC group of companies and associated companies in which we have shareholdings;
To screening companies, credit reference agencies and fraud prevention agencies to enable us to conduct credit and background checks; (for further information see below);
To organisations who may record, use and give out information to lenders or insurers in order to make decisions about financial products;
To your credit intermediary (if you used one) for the duration of your agreement(s) with us, and/or to our Isle of Man and UK-based finance partners. For further information about this please contact us using the contact details at the end of this document;
If you have engaged our Credit Brokering services, to your chosen finance provider for them to arrange your loan or leasing agreement with you;
To our insurers for the purpose of acquiring appropriate insurance cover in relation to specific products and/or services that we offer;
To persons acting as our agents or on our behalf under a strict code of confidentiality where we outsource functions relating to our products and services (for example, loan administration and management, our IT system providers, document storage and archiving companies etc.);
To anyone we transfer or may transfer our rights and duties under your agreement(s) with us;
Back to you during the course of your relationship with us;
To other parties legally connected with your account (e.g. guarantor and other people named on the agreement;
If you are a current or former employee, to future employers who seek references about you (who will require your consent to do this);
To relevant Financial Services Ombudsman Services;
To law enforcement and fraud prevention agencies; or
To legal or regulatory bodies (such as the UK Financial Conduct Authority) as required by law or regulation.

Otherwise we will keep all your personal information confidential unless you give us consent to transfer it to a third party.

It is not normally necessary during the usual course of business to transfer your personal data outside of the Isle of Man or the UK, however, in the event it is necessary, it will be done so in accordance with the requirements of Data Protection legislation. These requirements include the provision that the recipient of your personal data must have the same level of protection in place as you are entitled to on the Isle of Man or in the UK. We will advise you if your personal data is to be transferred in this manner.

The exception to this is, if you as a customer live outside the Isle of Man, UK or the EEA and we are sending your personal information back to you, this will be necessary in order to communicate with you and for providing you with our goods and services. Our e-mails to you are subject to encryption and any sensitive documentation will be sent via registered mail.

Credit reference agencies

In considering whether to enter into any agreement with you for our products and/or services, we may search your record and that of any joint applicant or any guarantor using standard public searches and credit reference agencies, these may include credit scoring.

The credit reference agencies will add to their record about you and any joint applicant and any guarantor. The details of our search and your application will be seen by other organisations that make searches using the same credit reference agencies.

This and other information about you and those with whom you are linked financially may be used to make credit decisions about you and other members of your household.

We currently use the following 3 credit reference agencies. For further information regarding how they will process your information, please refer to the links provided:

www.equifax.co.uk/crain

www.experian.co.uk/crain

www.transunion.co.uk/legal/privacy-centre?

Fraud prevention agencies

We have a legal obligation and legitimate interest to report suspected fraud to law enforcement and fraud prevention agencies, and we are not permitted to share the detail of any disclosure with you.

We may share your personal information with fraud prevention agencies if we feel fraud has been or might be committed. We will use the information to confirm identities, help prevent fraud and/or money laundering or fulfill any contracts you or your business has with us.

These agencies collect, maintain and share data on known and suspected fraudulent activity for the purposes of fraud prevention. These records may be searched and shared with other organisations by the fraud prevention agencies. This is to support their duty to prevent, detect, investigate and prosecute crime.

If fraud is detected, you could be refused certain services, finance or employment.

The fraud prevention and law enforcement agencies we may share data with are:

www.cifas.org.uk/fpn
www.dnb.com/utility-pages/privacy-policy.html
www.equifax.co.uk/crain
www.experian.co.uk/crain
www.transunion.co.uk/legal/privacy-centre

Please telephone or write to us at the address stated below if you would like further details of the fraud prevention agencies.

How long do we retain your personal information?

We are permitted by law to retain your information for as long as is necessary in relation to the purposes for which the information was originally provided. This includes our legal requirement to hold some information for at least six years following the termination of a customer relationship or transaction.

We will hold the personal information of our customers, your accounting records, client due diligence (CDD) and transaction records for a minimum of six years, except where records are required for investigation by law enforcement, where they will be retained for as long as required by the Constable or competent authority.

If you have been declined our services, we will retain your personal information for a maximum of 3 months from the date we received it, unless you give us permission to retain it for longer.

If you have been unsuccessful in applying for a job with us, we will retain your information for a maximum of 6 months unless you give us permission to retain it for longer.

Once your information is no longer necessary in accordance with the above, it shall be destroyed in line with Data Protection legislation.

Your rights

Under Data Protection legislation you have the following rights free of charge:

Access to personal Data

Subject to exceptions detailed in Data Protection legislation, you have a right of access to all personal data we hold about you. If you wish to exercise this right, or you have any questions regarding your personal data, please write to the Data Protection Officer at the address below. We will respond within one month from receipt of a valid request, and in any event, without undue delay.

Automated decision making

If you are applying for a loan with us, your application may be decided using purely automated decision-making technology. This means that the personal information you provide (or is collected through background and credit checks) is fed through our computer systems and marked against a list of parameters we are prepared to accept if your loan application is to be successful. If your information does not meet pre-programmed criteria, your loan application may be declined. The decision as to whether to grant you a loan, is therefore 'automatically determined'.

You have the right to request that your application is assessed instead by a physical person. If you would like to exercise this right, or you would like further information about this, please write to the Data Protection Officer at the address below.

Rectification

You have the right to the rectification of inaccurate data, and to obtain completion of incomplete personal data. To correct or amend your personal data, please contact the Data Protection Officer at the address below with the details. We will make the required changes as soon as possible.

Erasure

In certain situations, you have the right to request that your personal data is erased, however, there are limitations to this right.

Examples of grounds for exercising your right to erasure include:

Personal data is no longer necessary for the purpose of the performance of a contract between us and you;
Where data has been unlawfully processed;
Where data has to be erased to comply with a legal obligation; and
Where a right to object to direct marketing or the right to object to processing has been exercised.

Examples of limitations to your right of erasure include:

It is necessary for the performance of a contract between us and you;
Our compliance with legal obligations to retain client records for certain periods of time (as detailed above); and
Establishment, defense or exercise of legal claims.

Restriction of processing

You have the right to restrict our processing of your personal data in the following circumstances:

If you contest the accuracy of personal data processed by us, (we may restrict processing for a limited period to enable us to verify the accuracy and amend the data as necessary);
We no longer require your information for the purposes we originally obtained it; and
We have no legitimate grounds for processing your information or your information has been processed unlawfully.

If you wish to exercise this right, please contact the Data Protection Officer at the address below with the full details.

Data portability

You have a right to receive your personal information that you have provided to us, in a structured, commonly used and machine-readable format. You also have a right to have this personal data transmitted to another data controller (i.e. another business), where technically feasible to do so.

Right to object

You have the right to object to us processing your personal data in the following circumstances:

For direct marketing purposes;
Profiling in relation to direct marketing.

Right to lodge a complaint

If you have a complaint regarding the way we are processing your personal data, please address it with us in the first instance in the hopes that we will be able to resolve the matter with you. However, if you do not want to address your concerns to us, or we have failed to satisfactorily respond to your data protection complaint, you have the right to complain to the Data Protection Supervisor. The contact details are below:

Isle of Man
Information Commissioner,
First Floor, Prospect House,
Prospect Hill, Douglas,
Isle of Man IM1 1ET

Telephone
01624 693260

United Kingdom
Information Commissioners Office,
Wycliffe House,
Water Lane, Wilmslow,
Cheshire SK9 5AF

Telephone
0303 123 1113

Marketing

If you wish to receive information about our products or services, please contact marketing@conisterbank.co.im.

Cookies

If you use our website, for information about our cookie usage please see the information below. In line with the statutory requirements for cookie usage, we make you aware that we will use cookies and that you agree to our use of cookies.

Cookies can be used to recognise your Internet Protocol (“IP”) address, saving you time while you are on, or want to enter, the website. We use cookies for your convenience in using the Website (for example to remember who you are without you having to re-enter your password) and we may use cookies to ensure the advertising you receive is as relevant as possible for you. They help us to improve the website and to deliver a better and more personalised service. They enable us to, for example (but without limitation):

To estimate our audience size and usage pattern;
To store information about your preferences, and so allow us to customise the website according to your individual interests and spending patterns;
To speed up your searches;
To recognise you when you return to the website; and
To enable us to target opportunities in accordance with your interests and spending patterns and to collate the information you have provided in order to strengthen our buying power with third party suppliers.

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of the website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you access the website.

If you want to find out more information about cookies, go to http://www.allaboutcookies.org or to find out about removing them from your browser, go to http://www.allaboutcookies.org/manage-cookies/index.html.

Please note that our suppliers and advertisers may also use cookies, over which we have no control.

What is aggregate information?

Aggregate information is used to show us the total number of visits to our website and which parts of the site are used and most. Aggregate information does not identify individuals, as it does not contain any personal data. This information helps us in developing our website and improving the service we offer you.

Changes to our privacy policy

We keep this privacy policy under regular review, and we may amend it periodically by updating this on our website. If we make a material change, we will notify you by sending you a notification through email or SMS message. We will indicate at the top of this privacy policy when it was last updated.

The data protection officer and contact details

If you have any questions or concerns regarding this notice or you wish to exercise your rights, please contact us, addressing your query to the Data Protection Officer:

Conister Bank Limited, Clarendon House, Victoria Street, Douglas, Isle of Man, IM1 2LN

Telephone
01624 694694

Email
data@conisterbank.co.im