Privacy Policy

Overview

  1. Finance for Entrepreneurs is committed to protecting and respecting your privacy. This policy describes how we collect, use, process and share your information, including personal information.
  2. In this policy, ‘Finance for Entrepreneurs’, ‘we’, ‘us’ or ‘our’ means the members of our group. You can find out more information about our group companies in our Terms of Use. If you see an undefined term in this policy, it will have the same meaning as our Terms of Use.
  3. ‘You’ or ‘Your’ refers to anyone accessing our website or products and services. Where you sign up to or use any of our products or services on behalf of a business, ‘You’ or ‘Your’ also refers to directors, beneficial owners and other controlling officials of the business, as well as anyone who has provided information to us in relation to the products and services provided to you by us.
  4. When we collect and use your personal information, we do so in compliance with the Data Protection Act 1998 and, from the 25th of May 2018, the General Data Protection Regulation (GDPR). We are responsible as a ‘controller’ of that personal data.
  5. If you have any questions about our policy or how we use your data, you can get in touch by email at privacy@financeforentrepreneurs.co.uk or by calling one of our team on 01793 292 147. You can also write to us at Crowood House, Gypsy Lane, Swindon, SN2 8YY.
  1. The information we collect and process
    1. The information we collect and process is required for us to act as a Broker and Introducer.
    2. We may collect the following information about you:
      1. If you are an individual, information about you which includes personal data such as your name, date of birth, phone number, email address, residential address, financial information, employment details and your source of funds.
      2. If you are a business, information about your business, such as your business name and activities, financial information (which in most instances will not include any personal data), as well as information about all of your directors, business partners and persons of significant control (which includes personal data such as names, dates of birth, phone numbers, email addresses and residential addresses).
      3. Information about your use of our services, including your IP address.
  2. How we collect the information
    1. We collect most personal information from you directly, through our websites as well as by email, telephone and post. We may also collect information in the following ways:
      1. Directly from third parties such as companies that introduce you to us, credit reference agencies and fraud prevention agencies.
      2. From publicly available sources such as Companies House either directly, through an API (application programming interface) or through a third-party provider.
      3. From other third parties where we have your consent.
      4. From cookies on our website (for more information, please see the Cookies section below).
    2. Where you are applying to be a borrower, we will collect this information when you first apply. This enables us to continue to provide you with the products and services, as well as ensuring that we are complying with our relevant legal and regulatory obligations.
  3. How we use your information
    1. Under data protection law, we cannot use your personal information unless we have a proper reason to do so. The lawful bases for processing information are:
      1. For the performance of/to fulfil a contract we have with you; or
      2. When it is our legal duty; or
      3. When it is in our legitimate interest (which means we have a business or commercial reason of our own to use your information); or
      4. When you consent to it.
    2. We (or third party data processors, agents and contractors acting on our behalf) will collect, store and use your personal information for the following reasons:
WhoWhat we use your data forWhy we use your data
All usersTo provide our products and services to you and to manage our relationship with you.For the performance of our contract with you or to take steps at your request before entering into a contract.
All usersTo update and enhance our customer records.For the performance of our contract with you and to comply with legal requirements to keep our records up-to-date and accurate.
All usersStatistical analysis to help us manage and promote our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures.For our legitimate interests or those of a third party, ie to promote our business and be as efficient as we can so we can deliver the best service to our customers.
All usersInformation about how you use our website.This information will be anonymised and used to produce aggregate statistics or for reporting purposes and to calculate referral fees, where applicable.
BorrowersTo carry out regulatory checks and report to the Financial Conduct Authority, HM Revenue & Customs or any other relevant authority.To comply with our legal and regulatory obligations.
BorrowersTo complete checks for the purposes of preventing fraud and money laundering, and to verify your identity. We and fraud prevention agencies may enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime. Such checks will be completed when you first apply and then periodically during the time you are an active borrower or investor.We have a legitimate interest in preventing fraud and money laundering, and to verify your identity, in order to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the services you have requested.
BorrowersTo assess your application for credit, including by using scoring methods and to check the accuracy of details on applications for credit.For our legitimate interests or those of a third party, i.e. to ensure our customers are likely to be able to pay for our products and services.
BorrowersTo disclose your personal information to other credit providers or brokers who we believe may be able to help you obtain credit that we have been unable to provide.We will only use your information in this way where you have specifically consented to us doing so.
  1. Who we share information with
    1. We may share your information with the following categories of companies as an essential part of being able to provide our services to you:
      1. Companies within the ownership of Smarter Finance Limited.
      2. Companies we use to deliver our products and services to you, such as payment service providers.
      3. Professional service providers, we use to help us run our business, such as our accountants, auditors, marketing and advertising agencies or website hosts.
      4. Credit reference agencies, law enforcement and fraud prevention agencies and regulatory bodies.
      5. Organisations that introduced you or your business to us.
      6. Anyone else with your permission, including companies you ask us to share your data with.
    2. We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you.
  2. Credit reference agencies (CRA’S) and fraud prevention agencies (FPA’s)

Credit Reference Agencies

    1. Where you apply for credit, as a borrower, we’ll perform identity checks on your company, directors, shareholders and, where required, on guarantors. We’ll also make periodic checks with CRAs while you’re using our services to help us manage your account.
    2. We will share your personal and business information with CRAs and they will give us information about the business and you. The information we exchange can include:
      1. information about your business or company, such as previous applications for credit and the conduct of the accounts and also similar personal credit information in your name and of your business partners;
      2. public information such as County Court Judgments (CCJs) and bankruptcies; and
      3. electoral register information on you and your business partners.
    3. When credit reference agencies receive a search from us they will:
      1. place a credit search “footprint” on your company credit file whether or not your application proceeds. The record of that search (but not the name of the organisation that carried it out) may be seen by other organisations when your business applies for credit in the future;
      2. place an enquiry search on the personal credit files of any director/owner or partner that has been searched;
      3. link together the records of you and anyone you have advised is your financial associate including previous and subsequent names of parties to the account;
      4. place an enquiry or identification search on the record of any shareholder who is a beneficial owner of the company and who we have checked;
      5. create a record of the name and address of your business and its proprietors if there is not one already.
    4. Credit reference agencies will keep records of outstanding debts on file for six years after they are closed, whether settled by you or defaulted.

Fraud Prevention Agencies

  1. Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.
  2. If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services or financing you have requested or to employ you, or we may stop providing existing services to you.
  3. A record of any fraud or money laundering risk will be retained by the fraud prevention agencies and may result in others refusing to provide services, financing or employment to you. If you have any questions about this, please contact us on the details above.
  4. Whenever fraud prevention agencies transfer your personal data outside of the European Economic Area, they impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the European Economic Area. They may also require the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing.
  1. How long your information will be kept
    1. We will keep your information when you have an applied or enquired with us or we are providing products and services to you. Thereafter, we will keep your information for as long as is necessary to respond to any questions, complaints or claims made by you or on your behalf; to show that we treated you fairly, and to keep records required by law.
    2. We will not retain your personal information for longer than necessary for the purposes set out in this policy.
  2. Cookies
    1. Finance for Entrepreneurs websites uses cookies to collect information about you. Cookies are small data files which are placed on your computer when you use a website and which collect certain personal information about you.  Cookies enable us to tailor our service offering (including the websites) and to provide you with a better service.
    2. We use the following cookies:
      1. Strictly necessary cookies. These are cookies that are required for the operation of our website.  They include, for example, cookies that enable you to log into secure areas of our website. They do not gather information about you that could be used for marketing purposes or remembering where you have been on the Internet.
      2. Analytical/performance cookies. They allow us to collect information about how you use our website, such as, how you move around our website and if you experience any errors. These cookies do not collect any information that could identify you; all of the information collected is anonymous and is only used to help us improve the way our website works, understand what interests our users and measure how effective our advertising is.
      3. Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences and improve your visit.
      4. Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. They are linked to services provided by third parties, such as “Like” and “Share” buttons. The third-party provides these services in return for recognising that you have visited our website.
    3. Generally, cookies which are strictly necessary for the operation of the website will expire when you leave the website. Other cookies may be more permanent or not expire unless you actively delete them.
    4. If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may be unable to use our services and may lose some of the functionality of our websites. For further information on cookies and how to disable them, you can visit the Information Commissioner’s Office (ICO) website on  https://ico.org.uk/for-the-public/online/cookies.
  3. Your rights
    1. You have a number of rights in relation to your personal information:
      1. The right to request access to the personal information we hold about you.
      2. The right to request an update or correction to any out-of-date or incorrect personal information we hold about you.
      3. The right to request that we delete any personal information concerning you where you don’t think there is any justification for us holding it.
      4. The right to receive the personal information concerning you which you have a provided to us, in a structured, commonly used and machine-readable format and to ask us to pass this information on to other organisations.
      5. The right to object to or restrict our processing of your personal information in certain circumstances.
      6. The right to opt-out of any marketing communications that we (or any third party to whom we have disclosed your personal information with your consent) may send you.
    2. If you wish to exercise any of the above rights, please contact us by email at privacy@financeforentrepreneurs.co.uk.  You must provide us with enough information to identify you, for example, your full name and address as well as proof of your identity, such as a copy of your passport or driving licence.
  4. Security
    1. We have appropriate security measures in place to prevent personal information from being accidentally lost, used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
    2. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
    3. Whilst we take appropriate technical and organisational measures to safeguard the personal information that you provide to us, we accept no liability if communications are intercepted by third parties or incorrectly delivered or not delivered.
    4. If we transfer your information to third parties we will take steps to ensure that such transfer and any on-going processing by such third parties is carried out securely and in accordance with applicable privacy laws.
  5. How to complain
    1. If you are unhappy about the way we use your information, you should contact us in the first instance using the information above. Under the GDPR, you can also lodge a complaint with the ICO. The ICO can be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
  6. Changes to this privacy policy
    1. We may make changes to this policy to ensure it accurately reflects how we are processing your data. If we make any substantial changes, we’ll make sure you’re aware of these by posting a message on our websites or contacting you by email.