Privacy Policy

About Hilltop Credit Partners Limited

This Privacy Policy sets out how we collect, use and protect your personal information. ‘Personal information’ is information which identifies you or another person, or which is capable of doing so.

Hilltopcreditpartners.com (the “Website”) is owned by Hilltop Credit Partners Limited, a private limited company in England and Wales with company number 11755964 and registered office is 1 Knightsbridge, London, United Kingdom, SW1X 7LX.

Please take the time to read this Privacy Policy, which is part of our Terms and Conditions. If you have any questions about this Privacy Policy or our use of your information you can contact us at info@hilltopcreditpartners.com. You also have the right, however, to make a complaint to the relevant Supervisory Authority about our use of your information (in most cases under this Privacy Policy the relevant Supervisory Authority will be the Information Commissioner’s Office).

About this privacy policy

We take your privacy seriously and are committed to maintaining the privacy and security of information you provide to us, and the choices you have regarding our collection and use of your information. This Privacy Policy applies to information we collect about you through this Website and when you otherwise communicate with us. By visiting our Website, you are accepting and consenting to the practices described in this Privacy Policy.

We process your personal data on the basis that you have provided your consent for us to do so for the purposes set out below when you submitted your personal data to us. You may withdraw your consent to this processing at any time by contacting us at info@hilltopcreditpartners.com. If you do withdraw your consent, we may still be able to process some of the data that you have provided to us on other grounds.

We have a philosophy here about the way we use your consent to be contacted by us (if you give us that consent). If you hear from us, we will always aim to be respectful, relevant and appropriate. If at any time you don’t feel we’ve lived up to our philosophy, please let us know straight away by getting in touch with us.

This Privacy Policy may change from time to time and, if it does, the up-to-date version will always be available on our Website. Please note that by continuing to use our Website you are agreeing to any updated versions.

Information we may collect about you

You may give us information about you by filling in forms (e.g. on our ‘Contact Us’ page), by contacting us on our Website. The information you give to us may include:

  • your name and title;
  • contact information, including telephone number and email address;
  • loan and property specific information.

Each time you visit our Website, we may automatically collect the following information:

  • web usage information (e.g. IP address), your login information, browser type and version, time zone setting, operating system and platform;
  • information about your visit, including the full Uniform Resource Locators (URLs) clickstream to, time on page, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs).

What your information may be used for

We may use your information we collect on you for the following purposes:

  • to respond to any query that you may submit to us;
  • to ensure that our Website’s content is presented in the most effective manner for you and your computer;
  • to customise the Website according to your interests;
  • to administer the Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey responses;
  • to allow you to participate in interactive features of our service when you choose to do so;
  • as part of our efforts to keep the Website safe and secure;
  • to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
  • to comply with the law;
  • as we feel is necessary to prevent illegal activity or to protect our interests;
  • marketing and advertising purposes. This may include sending advertisements where we use your first name to personalise the communication. For more information, please see the section below titled “How your data may be used for marketing and advertising purposes”.

Disclosure of your information

We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

When we share your information with third parties they will process your information as either a data controller or as our data processor and this will depend on the purposes of our sharing your personal data. We will only share your personal data in compliance with the applicable data protection legislation.

We may disclose your information to third parties when:

  • you specifically request this, such as when you submit information to enquire about jobs or submit a job application through the Website;
  • in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
  • if the Website or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
  • if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property or safety of the Website, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

 

The third parties include:

  • business partners, clients, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
  • analytics and search engine providers that assist us in the improvement and optimisation of the Website.

How your data may be used for marketing and advertising purposes

Our business relies upon providing property development finance in the form of both debt and equity. Marketing and advertising are therefore vital parts of our activities. We may use your data for the following types of activity.

Email marketing

We may use your email address to send you marketing that we believe to be of interest or relevance to you, such as product or company information, newsletters, research articles or opinion pieces.

You may opt out of receiving such communications at any time by either following the unsubscribe links within the communications or by sending an instruction to dataprotection@hilltopcreditpartners.com. Any request may take up to 48 hours and may not affect communications scheduled to be sent within that time frame.

It may still be necessary for us to send you service communications by email, such as changes to services. You may opt out of receiving such emails by sending an instruction to dataprotection@hilltopcreditpartners.com

Third-party platforms

We may promote our own content and features via third-party platforms such as social media sites, typically achieved by sending an encrypted identifier to them which is then matched to their records to see if you are a user of that platform. This in turn allows us to send promotions via your profile page on that platform.

You can opt out of this type of promotion at any time by sending an instruction to dataprotection@hilltopcreditpartners.com. We will process these requests as quickly as possible, although communications may be promoted to you in the meantime.

Our content might appear on third-party sites depending on your activity or the activity of you network on these sites (for example, after liking one of our posts or products on LinkedIn). These messages are controlled by the third party site, and you will have to change your preferences within the third party site to stop receiving them.

Third party advertising

Under no circumstances whatsoever do we share your personal data with third parties so that they might advertise their products or services to you.

The legal basis for our use of your data

Data protection law obliges us to state what we believe is the legal basis for using or processing your personal data for any of the purposes outlined above. We believe it is in our legitimate interests to carry out those activities as follows:

Purpose: Providing our service

Legitimate interests: To ensure that you enjoy the optimal experience dealing with us as and to ensure that you are kept informed of matters that may be of direct interest or relevance to you.

Purpose: Improving our service

Legitimate interests: To make sure that we continually improve our service and provide users with the most effective service possible.

Purpose: Marketing and advertising

Legitimate interests: To provide relevant communications to ensure you are kept informed of developments that may be of interest to you.

You have the legal right to object to us processing your personal data for any of the purposes, and unless a compelling legitimate reason exists to continue processing your personal data, we will stop processing it.

You also have the legal right to request that your personal data we hold and process be deleted completely from our systems and archives, and unless a compelling legitimate reason exists to continue processing your personal data, we will delete it.

Your email address, when used for marketing purposes, is processed on the basis that we have your consent to do so. Your consent can be withdrawn by following the instructions to “unsubscribe” in the footer of any email marketing communication.

Cookies

To view our policy regarding cookies please read our Terms and Conditions statement.

Storage of your personal data

The data that we collect from you may be transferred to, and stored at, a destination outside of the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or one of our suppliers. By using the Website, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

We follow strict security procedures as to how your personal information is stored and used, and who sees it, to help stop any unauthorised person getting hold of it. All personal information you register on this Website will be located behind a firewall. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. Unfortunately, the transmission of information via the internet is not completely secure and although we do our best to protect your personal data, we cannot guarantee the security of your data. So, we cannot accept any liability for the loss, theft or misuse of the personal information which you have registered on the Website if there is a security breach.

We will keep your information stored on our systems for as long as it takes to provide the services to you. The third parties we engage to provide services on our behalf will keep your data stored on their systems for as long as is necessary to provide the services to you. We will not store your information for longer than is reasonably necessary or required by law.

Your rights

Even if you have accepted the processing of your personal data for marketing purposes (by ticking the relevant box), you have the right to ask us to stop processing your personal data for such purposes. You can exercise this right at any time by contacting us at info@hilltopcreditpartners.com.

The Website may, from time to time, contain links to and from the websites of advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Access to information

European Data Protection Legislation gives you the right to access information held about you. You are entitled to be told by us whether we or someone else on our behalf is processing your personal information; what personal information we hold; details of the purposes for the processing of your personal information; and details of any third party with whom your personal information has been shared. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you. Sometimes you may be asked to provide proof of identity before we show you your personal information – that’s so we can prevent unauthorised access. Your rights to access, rectify such information, object or cancel the information we hold about you can be exercised at any time by contacting us at info@hilltopcreditpartners.com.

Unsubscribe

From time to time, Hilltop Credit Partners or third parties who we think have products or services of interest to you may send you e-mails, e-mail newsletters, or news updates alerting you to new features, products, promotions, or services pertaining to the Website. If you no longer wish to receive materials from us and/or from such third parties, you may opt-out of receiving these communications by writing to us at Hilltop Credit Partners, 3 Duke of York Street, London, SW1Y 6JP, UK, emailing us your request to ‘unsubscribe’ at dataprotection@hilltopcreditpartners.com.

Contact

Questions, comments and requests regarding this Privacy Policy should be addressed to: 

Registered Address:

1 Knightsbridge
London, United Kingdom
SW1X 7LX

Alternatively, you can contact us through the contact us section of this Website.

Policy Changes

We reserve the right to make changes to this policy at any time. Any changes made will be posted and dated on this page and you will be notified via email if significant changes are made.

Definitions

For the purposes of this Privacy Policy, (“European Data Protection Legislation“) is defined as, for the periods in which they are in force, the European Data Protection Directive 95/46/EC, all laws giving effect or purporting to give effect to the European Data Protection Directive 95/46/EC (such as the Data Protection Act 1998) or otherwise relating to data protection (to the extent the same apply) and, from 25 May 2018, the General Data Protection Regulation (Regulation (EU) 2016/670) (GDPR) or any equivalent legislation amending or replacing the GDPR.

© 2019 Hilltop Credit Partners

Hilltop Credit Partners Limited is an appointed representative of Thornbridge Investment Management LLP which is authorised and regulated by the Financial Conduct Authority
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