This policy sets out how First Milk use the information that you provide to us.
Use of Personal Information
First Milk will share information about you with other members of the Group. The following sections explain in more detail how and for what purposes the Group will use your personal information. We currently may hold personal and financial information about you and may obtain or receive such information about you in the future. The information we process about you will be obtained from various sources including:
- Directly from you;
- From your dealings with any member of the Group;
- From other organisations including credit reference and fraud prevention agencies; and
- From persons who know you including joint members and persons with whom you are financially linked in the context of your dealings with any member of the Group.
For our internal operational reasons we may link information concerning your dealings with any member of the Group to information concerning other products and services we provide to you. We may also link your information to that of other individuals with whom you are financially associated. Such information may also include sensitive personal data. However we only hold such data where we need to for the purposes of the product or services we provide to you or it is in our normal course of business to do so. We will use your information:
- To operate and administer the products and services we provide to you;
- To assess the suitability of our products and services for you;
- To analyse the operation of your accounts and services and your purchasing preferences;
- To develop, improve and market our products and services generally;
- For market and product analysis purposes;
- To advise you about other members who may wish to contact you or stand for election to an office of First Milk
- For debt recovery purposes;
- To make credit decisions about you; and
- For the prevention of fraud and money laundering;
We may also use your information for system testing purposes. We may use email in response to enquiries you raise with us.
We will treat all your information as confidential and will not give your information to anyone except where:
- We are permitted to do so by law;
- We have a public duty to disclose the information;
- We need to do so to comply with the requirements, codes or recommendations of our regulators;
- We have your consent (which is not necessarily required to be in writing);
- It is necessary for the performance of any product or service that we provide to you; or
- We have transferred any of our rights or obligations to another party.
We may contact you by post, phone, fax, e-mail, SMS text or other reasonable means to inform you about products and services supplied by ourselves and/or selected third parties that we consider may be of interest to you. We will not pass your information to anyone outside our Group for their own marketing purposes. You can inform us at any time if you do not want to receive marketing information by any one or all of these means.
Transfer of Information
From time to time we will engage service providers, agents and subcontractors to provide services. They will have access to, and will process, your information on our behalf to provide such services.
If we transfer your information abroad to other Group companies, service providers, agents and subcontractors in countries where they may not have data protection laws providing the same level of protection as those in the European Economic Area we will ensure that your information is processed only in accordance with the applicable legislation and under strict obligations of confidentiality.
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. We and other organisations may also access and use this information to prevent fraud and money laundering, for example, when:
In order to assess any applications that you may make for credit products or any request for an increase to any existing credit product that we may already provide to you or arrange or process on your behalf, your suitability for, or to provide you with, credit products and services, we may search the records of one or more licensed credit reference agencies to obtain information on you.
These agencies may add details of our search and your application to the records they hold on you, whether or not your application proceeds. We may also add details of how your agreements or accounts operate with us to these records including any default or failure to keep to the terms of your agreement and any failure to advise us of a change of address where a payment is overdue.
Credit searches and other information provided to the credit reference agencies and fraud prevention agencies about you, and those with whom you are linked financially, may be used and disclosed by such agencies to other companies unrelated to us for the purposes mentioned above. Credit reference agencies will also use the information for statistical analysis about credit, insurance and fraud.
For the purposes of this application you may be treated as financially linked and your application will be assessed with reference to any "associated" records. An "association" between joint applicants and/or any individual identified as your financial partner will be created at credit reference agencies, which will link your financial records. You and anyone else with whom you have a financial link understand that each other's information will be taken into account in all future applications by either or both of you. This linking will continue until one of you successfully files a 'disassociation' at the credit reference agencies. Information held about you by the credit reference agencies may already be linked to records relating to one or more of your partners.
If you would like details of the agencies from which we obtain and record information about you, please write to: The Secretary, First Milk Limited, Cirrus House, Marchburn Way, Glasgow Airport Business Park.
You do not need to register to access most of our websites and where you do not register, personal information about you will not be collected by us unless you give us this voluntarily in order to process a specific request. We will use that data only to fulfil that request.
We may work with third parties to research certain usage and activities on our website on our behalf. No personal information about you is shared except to the extent it is required to be used by a third party or parties for providing such research, and in the course of conducting this research we, and/or these third parties may place a unique "cookie" on your computer.
If you register for our services, any details you provide will be stored for use on future visits, as we do not want you to give us any information more than once. The details you give us may be combined with information about your use of our websites and information from other of our records in order to provide you with the products and services you request. If you register for our services, we will treat you as having consented to our using your personal data in the manner described in this Policy.
As a result of improvements we make to our services, amendments to laws or regulation or developments in the technology or processes we use, we may change the information we hold about you and/or the way in which or the purposes for which we process such information. Where we require your consent to such change we will notify you of the change. However, unless you inform us otherwise, we will deem your continued receipt of products and services to which the change relates to constitute your consent to the relevant change.
Data Protection Act
If you would like any further information on the Data Protection Act and your rights under it, you can also contact The Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF or visit www.ico.gov.uk.
- Checking details on applications for credit and credit related or other facilities;
- Managing credit and credit related accounts or facilities;
- Recovering debt;