1. Introduction

True Network Solutions Limited (“we”, “us”, “our”) is committed to protecting your personal data and respecting your privacy.

This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you:

· Visit our website

· Make enquiries regarding our services

· Purchase products or services

· Engage with us as a customer, business contact, or prospect

2. Who We Are

True Network Solutions Limited is the data controller responsible for your personal data. Contact details:

Email: Info@truenetworksolutions.co.ukTelephone: 02080 502 630

Website: www.truenetworksolutions.co.uk

Registered Office: 64 Aerodrome Road, Gosport, PO13 0FQ Company Number: 15395852

Registered in England and Wales

3. Our Role as a Data Processor

We act as a data controller in respect of all personal data collected and processed for our own business purposes.

Where we process personal data strictly on behalf of third-party partners, under their instructions, we act as a data processor.

Where we introduce you to finance providers or other third parties:

· We act as an independent data controller at the point of data collection and onward sharing

· The relevant finance provider or third-party acts as a separate and independent data controller upon receipt of your data

· Each party is independently responsible for its own compliance in line with applicable data protection law

The typical data flow is as follows:

Customer enquiry → Data Collection → Assessment and Qualification → Introduction to Finance Provider → Lender-led Decision-making

We recommend you review the privacy policies of any/all third-party providers you engage with.

4. Personal Data We Collect

We may collect and process the following categories of personal data: Identity and Contact Data

· Full name

· Email address

· Telephone / Mobile number

· Business name

· Job title

· Billing and delivery address Business and Financial Data

· Business requirements and service needs

· Payment and transaction details

· Financial information required for quotations and service delivery

· Information required for finance applications and credit assessments Technical and Usage Data

· IP address

· Browser type and version

· Device information

· Website usage data (including analytics tracking data)

· Data on Phone contract and service usage Communication Data

· Records of correspondence (email, telephone calls, messages)

· Call recordings (used for training, quality assurance, compliance, and dispute resolution)

Identity Verification Data

· Identification documents and related verification data used for fraud prevention and compliance. This could include but is not limited to Photo ID, Utility Bills, Bank Statements, Phone Bills.

5. How We Collect Your Data

We collect personal data through:

· Direct interactions (telephone, email, meetings, forms, messages)

· Website enquiries and digital forms

· Third-party introducers, suppliers, and partners

· Data enrichment and marketing partners (where legally permitted)

6. How We Use Your Data

We only process personal data where a lawful basis applies. Provision of Services

· Processing enquiries and quotations

· Delivering products andservices

· Managing contractual relationships

Lawful basis: Performance of a contract Finance Introduction and Assessment

· Sharing data with finance providers and lenders

· Fraud prevention and compliance screening

Lawful basis: Contract, legal obligation, legitimate interests Business Operations

· Service improvement and analytics

· Systems administration and record keeping

· Customer relationship management

Lawful basis: Legitimate interests (balanced against individual rights and freedoms)

Marketing

· Sending relevant business communications

· Informing you about relevant products and services

· Advising on offers, promotions and upgrades

Lawful basis: Consent or legitimate interests (including soft opt-in under PECR where applicable) Details on opting out of Marketing can be found in section 14.

Legal and Regulatory Compliance

· Fraud prevention and financial crime detection

· Compliance with legal and regulatory obligations Lawful basis: Legal obligation

7. Automated Decision-Making and Profiling

We do not carry out any decision-making based solely on automated processing which produces legal or similarly significant effects.

Where you apply for finance, third-party finance providers and lenders will undertake automated decision-making and profiling, including credit scoring and risk assessment. These processes may affect eligibility decisions.

Finance providers act as independent data controllers and are responsible for their own automated processing activities.

8. Sharing Your Personal Data

We may share your personal data with:

· Finance providers and lending institutions

· Credit Reference Agencies: 

· Payment service providers

· IT, CRM, and marketing service providers

· Professional advisers (legal, financial, insurance)

· Regulatory bodies, law enforcement, and public authorities

Any sharing of data will be done for legitimate interests, legal obligation, and performance of a contract.

Credit Reference Agencies

We share personal data with Credit Reference Agencies, including:

· Experian Credit Reference Agency Information Notice (CRAIN) | Experian

· Equifax Credit Reference Agency Information Notice (CRAIN)| Equifax UK

· TransUnion Credit Reference Agency Information Notice (CRAIN) | An Information & Insights Company

Where we share data with Credit Reference Agencies:

Where any data is shared with Credit Ref Agencies you can access their Credit Reference Information Notices (CRAIN) through the links above

· They will use your data to perform credit and identity verification checks

· They use this data to support credit scoring, risk assessment and fraud prevention across the financial sector

· They may retain a record of credit searches

· They may share data with other lenders and financial institutions

· They act as independent data controllers for their own processing purposes

9. International Transfers

Where personal data is transferred outside the United Kingdom (for example when our customer is overseas), we ensure appropriate safeguards are in place, including:

· UK-approved Standard Contractual Clauses

· Transfers to countries deemed adequate under UK data protection regulations

10. Data Security

We implement appropriate technical and organisational measures to protect personal data, including:

· Access controls and role-based permissions

· Secure systems and encrypted storage where appropriate

· Confidentiality obligations imposed on all relevant personnel

Personal Data Breaches: 

We will always take appropriate precautions to protect all personal data and have internal processes implemented to support this; we will investigate and respond to data breaches. If there is a risk of a personal data breach and is likely to result in a risk to the rights and freedoms of our customers, we will notify the Information Commissioners Office (ICO) without delay and where required, within 72 hours of becoming aware of the breach. Where legally required, we will also inform the relevant customers or the relevant Third Parties.

Lawful Bases to Individual Processing Purposes:

We process personal data only for the purpose set out in this Privacy Policy. Under Data Protection Legislation, we must have a lawful basis for collecting and using personal data. Below are the lawful bases of which we rely on one or more of. 

· Consent – Customer gives acceptance to receive marketing communication from the introducer.

· Performance of a Contract – Information to be processed at customers request, to facilitate a service or product. 

· Legitimate Interests – Understanding customers’ needs and introducing to relevant service providers: preventing fraud and maintaining records.

· Legal Obligation – Ensuring when processing customers information that all legal and regulatory requirements have been met, such as the following: Anti-Money Laundering (AML) Fraud Prevention, Sanctions Screenings and Retentions Obligations.

11. Data Retention

We retain personal data only for as long as necessary for the purposes for which it was collected. Typically, we retain data for:

· Up to six (6) years following the end of a customer or business relationship

· Longer than six (6) years where required to comply with legal, regulatory, tax, fraud prevention, or accounting obligations

12. Your Rights

You have the following rights under the Data Protection Legislation; this is aligned with the Data Act 2025.

· Right to be informed – Customers have the right to know how your personal data is collected, used, stored and shared through privacy notices. 

· Right to Access (Subject Access Request – SAR) - Customers have the right to obtain their personal data and information and how it is processed.

· Right to Rectification – Customers can request correction of inaccurate or incomplete personal data.

· Right to Erasure (Right to be forgotten) – Customers can request deletion of personal data in certain circumstances.

· Right to restrict Processing – Customers can request processing of their personal data be limited. 

· Right to Data Portability – Customers can receive their personal data in structured, commonly used format and transfer it to another controller.

· Right to Object – Customers can object to processing based on legitimate interests, public tasks or direct marketing.

· Rights related to Automated Decision-Making and Profiling – Customers can request human intervention, express their view, or challenge automated decisions.

To exercise your rights, contact us using the details provided in Section 2 and 13 of this Policy.

13. Complaints and Contact Details

If you have concerns about how your personal data is handled or any questions or requests, you should contact us in the first instance at:

Compliance Team,

True Network Solutions,

Office 64

Aerodrome Road

Gosport

PO13 0FQ 

Telephone: 02080 502 630

Email: compliance@truenetworksolutions.co.uk

We will acknowledge and address all data protection concerns promptly and in accordance with applicable legal requirements.

If you are not satisfied with our response, you have the right to lodge a complaint with: Information Commissioner’s Office (ICO)

Website: www.ico.org.uk

Telephone: 0303 123 1113

We would appreciate the opportunity to resolve any concerns before escalation.