Commercial Experts Privacy Policy

Who Are We?

digitalmarketing-commercialexperts.co.uk is a trading name of TFLI Limited, who are registered in England and Wales (Company number 08424810), Registered Office; TFLI Limited, First Floor Beechwood Court, Springwood Way, Tytherington Business Park, Macclesfield, Cheshire, SK10 2XG. Licensed by the Information Commissioners Office, (registration number Z3585914).

digitalmarketing-commercialexperts.co.uk are aware how important your privacy is, based on this we have implemented measures which will ensure any personal information that is obtained from you by visiting our website will be processed and maintained in line with accepted principles of good information handling and in accordance with the General Data Protection Regulations (GDPR). Contained within this statement and set out below are details of the type of information that we at Commercial Experts may hold about you our customer, also how we obtain and process any information we may have and importantly how we protect your privacy.

This privacy policy is only applicable to us and personal information which may be collected and obtained by us. digitalmarketing-commercialexperts.co.uk may choose to amend the content of this privacy policy on occasion. If this occurs then we will update the policy and the revised policy will be posted on this website.

How We May Contact You As Part Of Your Application

We, and our panel of digital marketing providers will keep you informed with the progress of your application. Unless you state otherwise you may be contacted via telephone, email, post, SMS and automated message. (see further section on 'How we keep you informed')

Lawful basis for collecting your personal data

We rely upon various different lawful bases to process your personal data according to the reason for which you have provided your data to us.

Our use of your personal data will always have a lawful basis.

Consent:

When you submit your application with TFLI Limited, we process your personal data on the basis that you have provided your consent to be contacted by TFLI Limited and our panel of digital marketing providers. 

You can withdraw your consent to us processing your personal data for marketing purposes at any time by clicking the "unsubscribe" option in any marketing SMS, email we, or any associated third party, send to you.

Alternatively, you can withdraw your consent by contacting our Data Protection Officer at customerservices@tfli.co.uk or using the contact details stated in section 15 / 16. If you change your mind about agreeing to us processing your personal data, this will not have any effect on the lawfulness of any processing we have carried out before you changed your mind.

Contract:

Your personal data will also be processed on the basis that we need this information to fulfil our obligations under the contract we have entered into with you by providing you with a digital marketing quote. TFLI Limited and our panel of digital marketing providers will contact you regarding your enquiry.

Legitimate Interest:

We have a legitimate interest in processing your data (i.e. to share your application with our panel of digital marketing providers to obtain the quote you have applied for).

It also includes processing your data for ID protection and tracing purposes such as Credit Reference and Fraud Prevention. This is in relation to appropriate agencies which are listed within section 9.

You can object to us processing your data in this way by contacting our Data Protection Officer at customerservices@tfli.co.uk or using the contact details stated in section 15 / 16.

How You Contact Us

If you are required to telephone us using the specified telephone numbers on our website under the Contact or advertising/marketing correspondence then your call may be recorded for training, quality and regulatory purposes. We pride ourselves in customer care and this gives us the opportunity to continuously improve and monitor our customer experience.

How We Keep You Informed

We may want to make contact with you at some point in order to keep you informed regarding offers on products or services which we think you may find of interest, this contact will be made via email and SMS. Third parties may also wish to contact you from the information we have shared with them, any information that is shared to third parties is completely trusted for the purpose it is specified for, third parties may also use the same means of contact stated above.

Whilst the digital marketing providers will make contact with you to confirm whether your application has been successful they will too have their own privacy policy and recommend you refer to them, upon making your application, you will be requested to agree to their use of your information.

Obtaining Your Personal Data/Information

1. You are free to access and browse our website digitalmarketing-commercialexperts.co.uk at your convenience and do not have to provide any personal information/data, however we would like to refer you to the 'Cookies' section set out within the separate Cookies policy page. 
2. The personal information/data that we would normally collect from you is as follows:
   • Company Name / Legal Entity
   • Company Address
   • Name
   • Email address (if applicable)
   • Telephone number (mobile, work)
   • IP Address
   • What you do on our website; the results of this will be used to show Commercial Experts examples of which parts of our website are most and least used (please refer to 'Cookies' section)

If you apply with us and have a question about our services, or alternatively choose to send an email to customerservices@tfli.co.uk we may also collect the above personal information/data in this instance in order for us to respond to your enquiry.

Customer Communication

Unless the customer states otherwise we will contact the customer via means of telephone, SMS and email to provide information and alerts relating to our services and our associate companies. We may also receive personal information/data from third parties, which enables us to offer Identified potential customers products, and services who have expressed interest in our products and services. Any information/data obtained from third parties is checked in regards to accuracy and we will endeavour to check your information with you on occasion.

Ensuring your personal details & or preferences are kept up to date.

It is your responsibility to ensure that any information we have on record for you is kept up to date and correct. If you do require any of your information to be updated then please contact us as soon as possible so we can ensure it is corrected.

If you require your preferences to be updated then please contact our Compliance Director as soon as possible (details set out below within 'Contact' page).

What Personal Information Do We Collect?

We collect personal information about you when you give this to us when applying for a product online. This might be, for example, to obtain quotes for digital marketing services. In the course of providing the Services to you, we may also store information about how you use our Sites, for example, the pages viewed, the website from which you came to visit our Sites, changes you make to information you supply to us, details of the quotes you request and your applications, together with details of your financial information, for example, bank account or employer details.

In order to provide you with a quote we will need to collect personal information. By proceeding with obtaining a quote you give your explicit consent to such information being processed by us and our third-party providers such as digital marketing providers, 

We will store the information you provide and may use it to pre-populate fields on the Sites and to make it easier for you to use the Sites when making return visits.

We may monitor or record your Calls, Emails, SMS or other communications but we will do so in accordance with data protection legislation and other applicable law. Monitoring or recording will always be for business purposes, such as for quality control and training (e.g. where you call our compliance or customer service department), to prevent unauthorised use of our telecommunication systems and Sites, to ensure effective systems operation, to meet any legal obligation and/or to prevent or detect crime.

We will periodically review your personal information to ensure that we do not keep it for longer than is permitted by law.

How Do We Use Your Personal Information?

We may use your personal information:

1. to enable you to access and use the Services;
2. to personalise and improve aspects of our Services;
3. for research, such as analysing market trends and customer demographics;
4. to communicate with you, including some or all of the following:
   1. sending you information about products and services which we think may be of interest to you - this may include new product launches 
   2. sending you quotes in order to provide this service to you, we may also send that information to our partners such as our panel of digital marketing providers so that they can calculate their quotes. When they do this, our partners may carry out credit checks on you (see section 9 Who do we share your information with? below for further information on the type of checks that may be undertaken);
   3. sending you a confirmation email of your quote - when you submit an application with us, you will automatically be sent confirmation of your application by email or SMS so that you have a record of it;
5. to process an application between you and a third party such as the digital marketing providers;
6. to track sales, which may involve us sharing data with your product provider relating to the product(s) you have purchased. Your product provider may also send us information they hold relating to the product(s) you have purchased for this purpose;
7. to match our data with data from other sources - we may validate and analyse your information and, in some cases, match it against information that has been collected by a third party to ensure that the information we hold about you is as accurate, consistent and as well-organised as possible. As well as ensuring that any marketing material that we send you is appropriate to your needs, this process also ensures that our Services continue to be as personalised and focused as possible;
8. to circulate our customer survey review which are available to customers once an application has been completed;
9. to potentially pass on your data to third parties for marketing purposes as per section 9 where you have consented to do so.

Keeping you informed about the Services: You agree that we and, with your consent, other trusted third parties will be entitled to contact you (depending on your contact preferences) via email, post, telephone, SMS, or by other electronic means such as via social and digital media, in relation to products, services and other offers that may interest you.

Whenever you provide us with personal information, where necessary we will seek your consent and/or we will give you an opportunity to tell us you do not consent to the use and sharing of your information for marketing purposes. Unless you tell us otherwise, you are consenting to such use.

Who Do We Share Your Personal Information With?

When you complete an application, you consent to us disclosing your personal information to the following parties:

1. digitalmarketing-commercialexperts.co.uk and TFLI Limited: (i) to communicate with you, including sending you information about products and services which may be of interest to you; (ii) to speed up form filling, or to personalise, or improve your experience on its website, mobile applications or other similar devices, channels or applications; or (iii) in accordance with its privacy policy.
2. Digital Marketing Providers  as detailed below. You can view details to how they will process your data within their privacy polices.
3. Trusted third parties but only where you have opted in to allow us to do so and they are detailed below.  They will contact you with regards to the digital marketing quote that we believe could be of benefit to you. You can opt out at any time from receiving these communications.
   • Add People Limited
   • CommercialExperts.com
   • Yell Limited
4. Regulatory/governing bodies, for the purposes of compliance monitoring;
5. Credit Reference Agencies and Other Agencies where we collect your data and share with the organisations which you have a relationship with or it may be used where they have a lawful reason, which will include these organisations' own legitimate interest. The data will be used to trace individuals, verification and/or validation of the identity of individuals for the purpose of, but not limited to, anti money laundering regulations, national security, crime prevention and detection, anti-fraud processes, asset recovery and asset reunification.
6. Under data protection laws we are permitted to share some information where the reason for doing so is legitimate and isn't outweighed by the effects it will have on the relevant individuals. Your data may also be used in a similar manner to aid debt recovery and to prevent fraud by helping to identify you (for instance when you are applying for new products.

Where permitted by data protection and privacy law, we may also disclose information about you (including electronic identifiers such as IP addresses) and/or access your account:

1. if required or permitted to do so by law;
2. if required to do so by any court, the Financial Conduct Authority, the Competition and Markets Authority or any other applicable regulatory, compliance, Governmental or law enforcement agency;
3. if necessary in connection with legal proceedings or potential legal proceedings; and/or
4. in connection with the sale or potential sale of all or part of our business.
5. TFLI Ltd collect your data and will share it for commercial gain with third parties. These organisations will have a relationship with you or it may be used where they have a lawful reason, which may include these organisation's own legitimate interest. Use includes tracing of individuals, verification and/or validation of the identity of individuals for the purposes of, but not limited to, anti-money laundering regulations, national security, crime prevention and detection, anti-fraud processes, asset recovery and asset reunification.

If we reasonably believe false or inaccurate information has been provided and fraud is suspected, details may be passed to fraud prevention agencies to prevent fraud and money laundering.

FRAUD PREVENTION AGENCIES (FPA'S)

If we reasonably believe false or inaccurate information has been provided, including in relation to a person's identity, and fraud is suspected, details, including personal data may be passed to fraud prevention agencies to prevent fraud and money laundering.

Your details may be passed to statutory bodies, regulators, legal bodies, credit reference agencies, fraud prevention entities and identity and address verification agencies who may record and use your details. They may also disclose your information to other organisations for credit reference, debt tracing, and fraud and money laundering prevention purposes. If you have any queries regarding these uses, please contact the relevant organisation.

By submitting an application form on our site, you confirm that all of the information provided is true and accurate. You also, when applying, authorise the digital marketing providers and brokers to use both fraud prevention and credit referencing agencies to help make relevant decisions. Credit checks and credit reference agencies can also help prevent fraudulent applications.

What Is A Fraud Prevention Agency?

Fraud Prevention agencies collect, maintain and share information on any known or suspected fraudulent activity.

They work in the following ways with various organisations:

• If false or inaccurate information is provided and fraud is identified, details will be passed to Fraud Prevention Agencies
• Law enforcement agencies may access and use this information.
• FPA's along with ourselves and other organisations, may also access and use this information to prevent fraud and money laundering, for example, when:
• Checking details on applications for credit and credit-related accounts, or other, facilities;
• Managing credit and credit-related accounts or other facilities;
• Recovering debt;
• Checking details on proposals and claims for all types of insurance; and,
• Checking details of job applicants and employees.
• We, and other organisations may also access and use the information recorded by FPAs from other countries.

You have the right to object to this processing at any time by contacting us at customerservices@tfli.co.uk

Who Might Our Digital Marketing Partners Share Your Personal Information with?

Some of our providers will use your information to assess your application and verify the information that you have provided before providing a quote. 

This information exchange allows providers to verify the information that is provided during the quote process (including information about any third party who is named on the application, and also helps to detect fraudulent applications. These checks are not unique to users of our Services - they may also be carried out if you obtain quotes from other sources.

If you decide to enter into a contract, the information you have provided to us, together with any further information requested by, and supplied by you or us to the third party provider, will be held by the provider for the purposes set out in that provider's privacy policy. Therefore, you are strongly advised to read your chosen provider's privacy policy and satisfy yourself as to the purposes for which the provider will use your personal information before entering into the agreement. We have no responsibility for the uses to which a provider puts your personal information.

How Secure Is Our Site And What Steps Do We Take To Keep Your Personal Information Safe?

Our Sites are "Let's Encrypt Secure Websites" and keeping information about you secure is very important to us. However, no data transmission over the internet can be guaranteed to be totally secure. Sensitive information, for example, your card details, is encrypted to minimise the risk of interception during transit.

We do our best to keep the information you disclose to us secure. However, we can't guarantee or warrant the security of any information which you send to us, and you do so at your own risk. By using our Sites you accept the inherent risks of providing information online and will not hold us responsible for any breach of security.

Where will your personal data be held?

Your personal data may be held within the European Economic Area (EEA) or outside the EEA. If any personal data is transferred or stored outside of the EEA, we check whether the EU Commission has determined that it will afforded the same level of protection as it would within the EEA (this is called an adequacy decision). If it will not, we will ensure any such transfer is subject to appropriate safeguards (for example by putting appropriate contractual provisions in place with relevant third parties to provide us with reassurance about the security of your personal data) or is otherwise permitted (for example with your express consent to transfer) in accordance with the provisions of the GDPR.

Rights of Access To Your Personal Information

You have certain rights under the General Data Protection Regulations . For example, we will always let you have a copy of the personal information we hold about you, if you request it from us in writing.

• Right to be informed when we collect your data we have to tell you what we are going to do with it primarily though this Privacy Policy and within the opt in /consent statement.
• Right to Object - because you have asked us to help you find a financial product or service, we need to process the personal information you give us to enable us to find the best product or service available amongst our panel of website design providers. You can object to this processing at any time by sending us an email at customerservices@tfli.co.uk, or by writing to the Customer Services Team at TFLI Limited, First Floor Beechwood Court, Springwood Way, Tytherington Business Park, Macclesfield, Cheshire, SK10 2XG. We will action any request you make promptly, although this will mean that we will not be able to help you find the financial product or service that you asked us to search for.
• Right of Access - you can ask us at any time to confirm whether we hold your personal information, and if so, you can access it by writing to us at: Compliance Department. TFLI Limited, First Floor Beechwood Court, Springwood Way, Tytherington Business Park, Macclesfield, Cheshire, SK10 2XG or by sending us an email at customerservices@tfli.co.uk
• Right to rectification - if we hold personal information about you that is inaccurate, you can ask us to correct it, and we will do this as quickly as possible.
• Right to erasure - if it is no longer necessary for us to hold your personal information bearing in mind the reason why you provided it to us, you can ask us to delete it. If you ask us to do this, we will delete your personal information as soon as possible although this will mean that we may not be able to help you find the financial product or service that you asked us to search for.
• Right to restrict our use of your information - you can ask us to restrict our processing of your personal information if you think for example that the personal information you gave us is inaccurate. This may mean that we may not be able to help you find the financial product or service that you asked us to search for.
• Right to data portability - this gives you the right to ask a holder of your information to transfer that information to another business. This right would most commonly be used if you were switching banks, insurance companies and utility companies.
• Right to complain to the Information Commissioner's Office (ICO) - we will try to resolve any complaint that you may have in relation to data protection issues. If you are not happy with our final response you have the right to have your complaint dealt with by the ICO. Please refer to our Complaints section How To Make a Complaint below for further information.

To make enquiries and/or exercise any of your rights set out in this Privacy Policy please contact our Customer Services Team at customerservices@tfli.co.uk

How Long Will We Retain Your Personal Information For?

The amount of time we retain your information for will depend on the reason it was provided:

• If you request to opt out of marketing, we will still need to retain your information in order to evidence your preferences.
• We will need to retain, for a minimum period of 6 years, any information relating to applications you have entered into on our website. This period will commence once your relationship with us has ended. We need to keep your information for this length of time to assist with any potential future complaints.
• Your information/data will not be used for marketing purposes once 12 months has passed following your application.

If you require further information on our data retention policies please email: customerservices@tfli.co.uk

Your Right To Opt Out of Future Contact From Us And Our Trusted Third Parties

You can opt out of future contact from Commercial Experts at any time. All of our marketing messages provide an opt out link - please allow up to 48 hours for us to process your opt out request. Alternatively you can email customerservices@tfli.co.uk where your details will be removed from any future marketing campaigns.

If you are receiving contact from third parties you will need to contact them directly and request them to remove your details.

Your Right to be Forgotten / Erasure Of Your Personal Information

Under the General Data Protection Regulation (GDPR), all individuals have the right to request the deletion or removal of personal data (the right to be forgotten) under the following circumstances:

• Where the personal data is no longer necessary in relation to the purpose for which it was originally collected/processed.
• When the individual withdraws consent.
• When the individual objects to the processing and there is no overriding legitimate interest for continuing the processing.
• The personal data was unlawfully processed (i.e. otherwise in breach of the GDPR).
• The personal data has to be erased in order to comply with a legal obligation.
• The personal data is processed in relation to the offer of information society services to a child.

There are some circumstances where the right "to be forgotten" does not apply i.e. where we need to comply with a legal obligation.

If you wish to request your "right to be forgotten" please email: customerservices@tfli.co.uk

Our marketing partners will also be informed of your request where you have stipulated to do so.

How to make a complaint

Commercial Experts always aim to be fair and honest in everything we do, so if you have a complaint about any aspect of our service we're keen to resolve it as quickly as possible. You can contact us is any of the following ways:

By Post:
Complaints Department, Commercial Experts, First Floor Beechwood Court, Springwood Way, Tytherington Business Park, Macclesfield, Cheshire, SK10 2XG

By Phone:
01625 32 25 55 (calls are charged at local rates and are inclusive of mobile phone users' free minutes)

By Email: complaints@tfli.co.uk

We will acknowledge receipt of the complaint within 3 working days and we hope to provide a final response within 4 weeks. We will write to you again within 4 weeks if we are unable to provide a final response within that time period. In any event we will respond to your complaint in full within 8 weeks.

You can report any of your concerns to the Information Commissioner's Office (ICO)

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number
Fax: 01625 524 510

Last updated September 2024