What Information do we collect and store about you?
The personal information we collect from you is used primarily to enable us to provide the specific service you require and to help you access your account, securely.
The personal information may include your name, address, date of birth, contact details (including email address and phone numbers), any other information to allow us to check your identity (including a copy of your identification documents (such as a passport or driving licence)) and information about your credit history.
There may be some products and services where we may need to use additional personal information about you – without this information it may not be possible to provide those products and services to you. We need financial information (which may include your income, expenditure, assets and liabilities, credit history and credit scoring), employment details, details of any criminal prosecutions and details of bankruptcy or any County Court Judgements. This information will be used for funding decisions, to help us to operate a funding facility, for fraud prevention and anti-money laundering and to meet our own legal obligations.
How do we collect the information?
This information collected will mainly be information voluntarily provided to us by you, but we may also collect it where lawful to do so from (and combine it with information from) credit reference and fraud prevention agencies, public sources, third party service providers (such as credit reference agencies including Credit Safe who conduct a credit search as part of our application process), tax or law enforcement agencies and other third parties. We may also collect personal information about you from your use of other Company or Group websites or services.
We will also collect standard internet and website log information to understand how our website visitors behave, which we use to improve your experience online. This may include information about your Internet Service Provider, your operating system, browser type, domain name, the Internet Protocol (IP) address of your computer (or other electronic Internet-enabled device), your access times, the website that referred you to us, the web pages you request and the date and time of those requests.
How will we use the information?
For most of the products and services we will provide to you we need your name, address, date of birth, contact details (including email address and phone numbers), any other information to allow us to check your identity (including a copy of your identification documents (such as a passport or driving licence) and information about your credit history. Other information we may need to obtain has been covered earlier in this document. On occasions we will need to gather use and share further information about you but will only do this where we have a lawful basis to do so.
In order to administer and operate any facility we have made or may make to you we will need to use your contact details, your location data and your IP address for fraud prevention and security purposes. We may share this information with third parties to help verify you identity or contact details. In order to deliver the products and services required we may have to share information with our subcontractors and service providers which may include providers of our IT systems and platforms, providers of document management services and solutions, credit or other insurers for underwriting purposes or in relation to the administration of any claims, external payroll service providers (where that forms part of the services we provide to you), our legal and tax advisers, any person giving (or potentially giving) a guarantee, indemnity or other commitment to any of the Calverton Group Companies in relation to any funding facility or other product we make available to you, third party trainers; third party auditors and other advisers acting on behalf of any of the Calverton Companies or on your behalf, so that they can carry out their services to such persons and any regulators. Your information is used in this manner in order for us to be able to perform our contract with you and to meet any legal obligations.
In order to administer payments to or from you (or on your behalf) we will use your contact details, payment details as you have provided and location data to enable the locations of payment that are made to be verified in order to prevent fraud. This information may be shared with our third party payment providers to process payments to or from you or otherwise in respect of payments being made to us. We use your details because it is necessary to perform our contract with you where you are our client or, where you are the debtor of our client. Your personal information is used on the basis of our legitimate interests to collect debts due to us.
In order to make any credit decisions about your company including new funding and requests to increase existing funding limits we will need to use information you have given us about your credit history, information about those people you are financially linked to (e.g. your partner); information about how you have used other products and services offered by us; information we receive from third party credit reference agencies, fraud prevention agencies and watchlist agencies; and information we receive about you directly from other third parties. For this purpose, we will share information with credit reference and fraud prevention agencies (a list of such credit reference agencies can be obtained from our DPO using the contact details contained at the bottom of this policy. The information may then be used as follows. The credit reference or fraud prevention agency might add details of our search and your credit application to the records they hold about you, whether or not your application proceeds. We and the credit reference or fraud prevention agency might link your financial records to those of any person you are financially linked to – this means that each other's information (including information already held by us or the credit reference agency) will be taken into account in all future credit applications by you (or such financially linked person), until one of you successfully files a 'disassociation' at the credit reference agencies. We might add details of your (or the Connected Company’s) facility with us to the credit reference or fraud prevention agency's records, including details of how that facility is being operated and including any default or failure to keep to the terms of the underlying agreement. The credit reference or fraud prevention agency could pass on any of that information to other companies unrelated to us for the credit checking and fraud prevention purposes mentioned above; and the credit reference or fraud prevention agency will also use the information for statistical analysis about credit, insurance and fraud on an anonymous basis. When credit reference agencies receive a search from us, they will place a search record on your credit file that may be seen by other lenders and other companies unrelated to us (including other funders and credit providers). We use your information in this way because it is necessary to perform our contract to deliver credit related products and services to you, to meet any legal obligations and because it is in our legitimate interests to understand your financial position and to promote responsible lending.
In order to be compliant with any legislation to prevent financial crime including fraud and money laundering we will use any information you have given us, any that we have obtained from a third party, or any that we have obtained by looking at how you use our services. We will also use information where it is necessary for us to use that information to comply with a legal obligation; and this information will include name, address, date of birth, every country of residence/citizenship, personal identification (which may include passport number or driving license number) your IP address, and information about any criminal convictions. We will give information to and receive information from third parties where that is necessary to meet any legal obligations, including credit reference agencies, fraud prevention agencies, the police and other law enforcement and government agencies, banks and regulators. Fraud prevention agencies may use your information as advised earlier.
In order for us to carry out financial management and recover outstanding debts we will need to use your contact details and information we obtain from looking at how you have used our services. We will give information to and receive information from third parties where that is necessary to recover debts due by you or your customer’s to us, for example, other funders, debt recovery agents, insolvency practitioners, our legal advisers, credit reference agencies and sheriff officer or bailiff services. We use your information in this way because it is necessary to perform our contract with you, to exercise our legal rights, and because it is fair and reasonable for us to do so.
In order for us to be able to market products and services to you we will use the contact details you have provided to us and information we have gathered from your use of our other products and services to form a profile of you which we will use to assess what other products and services would be most beneficial for you. These details will be stored on Calverton Finance’s CRM database. You will receive communications including updates, newsletters and event information, which we think are relevant to your interests. Your details will not be given to 3rd parties unless we have your prior permission to do so. In all communications you will be provided with a link to unsubscribe to email@example.com. When we send you e-mail communications we use a technology which enables us to track who opens particular articles or emails. This help us to understand which issues are of more interest and helps us improve our service to you by ensuring you continue to receive useful information. It also helps us comply with data protection law to ensure that the information we hold about you is correct. We will pass your personal information to our service providers who help us with these marketing activities. We might also receive personal information about you from a third party and use it to market our products and services to you, where you have given that third party your consent to share the personal information with us (or have otherwise requested them to do this) or where that third party otherwise has a lawful basis for sharing that personal information with us. We may collect your name and address from other service providers for the purpose of providing suitable marketing to you.
In order to assist with introductions from, and to enable introducer fee payments to be made to, third parties, we will give information to and receive information from third party independent financial advisers and brokers. As a result the information we will use is information about the general nature of our products and services and information about the value of those products and services (where we have made them available to you. We use your information in this way because it is in our interests to have relationships with third party introducers in order to expand our business and to allow us to provide you with the products and services that will be best suited to you.
In order to be able to make introductions to third party independent financial advisors and brokers we will need to use information about the general nature of our products and services and information about the value of those products and services that have been made available to you. We use your information because it is in our interests to have relationships with third party introducers in order to expand our business and to allow us to provide you with the products and services that will be best suited to you.
In order for us to make introductions to make introductions to third party financial advisors, brokers or third party funders we will use your contact details and information in relation to the products and services which we understand you are seeking or which may be best suited to you. We use your information in this way where you have either given your consent to this or have otherwise requested us to do this.
In order for us to obtain our own funding which we will provide to you we may use information in relation to your facility with us which could include copies or the originals of our agreements with you and the provision of such information to our funders or discounters. We use your information in this way where our own funding arrangements require us to do so in order to obtain the funding which we can then make available to you.
In order to satisfy and obligations we have to supply details of our business and its performance to our funders, their agents and representatives and to our auditors we may use your name, your contact information, your bank account details, details of the amount of funding made available by us to you or which is otherwise owed by you to us; and details of any payments made by you to us we use your information in order to comply with our own funding arrangements agreements (and a failure to comply would mean that we would be unable to provide you with the funding you need). Typically, your information may be included within reports we issue to our funders (or their agents and representatives) which might, for example, provide those recipients with details of our new clients, our top clients (in terms of facility size) and top debtors (in terms of size of debt). We also use this information to comply with our audit obligations (which we have a lawful obligation to comply with).
In order for us to carry out business development and to engage with introducers, contractors and advisers we will use your contact details in order to make contact with you for any of the above purposes. We do this either because it is necessary in order to enter into a contract with you or to perform a contract once entered into or it is in our legitimate interests to interact with you for networking and business development purposes.
When completing our documents we will use the contact information of any individuals who witness any signatures on any of our documents. This information is required to make it easier to identify and trace a witness in case any questions arise in the future concerning the execution of our documents. Each party to our documents will be provided with a fully signed copy of them and further copies will (where relevant) be filed with Companies House and the Land Registry.
Lawful basis for the use of your personal information
Your personal information will only be used where we have a lawful basis to use it. In the general course of business one of the following will be used:
Consent: You have given clear consent for us to process your personal data for a specific purpose.
Contract: the processing is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract.
Legal obligation: the processing is necessary for us to comply with the law (not including contractual obligations).
Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect your personal data which overrides those legitimate interests.
There are categories of data that are considered to be sensitive and include race; ethnic origin; politics; religion; trade union membership; genetics; biometrics (where used for ID purposes); health; sex life; or sexual orientation.
We will only use this kind of personal information where:
We may use information about criminal proceedings relating to you to decide whether to enter into a facility with you, for fraud prevention/anti-money laundering purposes and to fulfil legal and regulatory obligations.
More information about our lawful basis for processing your personal information has been given earlier in this document.
Your rights and access to your information
Your personal data is protected in the UK by the Data Protection Law. Under the Act, we will process personal data we hold about you in a fair and lawful manner and will keep it secure from unauthorised access by third parties.
Your personal data may have to be disclosed if we are required by law or as a result of a lawful request by a governmental or law enforcement authority.
You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please email or write to us at the address at the end of this policy. We may make a small charge for this service.
We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate. If at any time, you wish to change any of the data we hold about you, or that you do not wish for your data to be used for marketing purposes, then please contact us at firstname.lastname@example.org with your instructions.
Unsubscribing from promotional material – if you would like to stop receiving promotional emails or other direct mail from us, please follow the unsubscribe instructions located in each such email or contact us using the details found at the end of this policy. Should you wish to opt out, we reserve the right to contact you in relation to your account, transactions or other essential communications as required by email or post.
Sharing your Personal Information
We will share your information with other Calverton Group companies and other third parties to enable us to provide the products and services to you. Where the personal information is made available to third parties (within or outside the Company or Group) providing relevant services under contract to the Company, or the Group. Third parties in this context means other corporate entities within our group, providers to the Company or Group of responsible management, accounting, legal, logistics, audit, compliance, information technology, marketing and other services. This may also include providers of call centres, data storage and database hosting services, IT hosting and IT maintenance services. These companies may use information about you to perform functions on our behalf.
We will not sell your personal information to any third party other than as part of any restructuring of the Company or Group or sale of a relevant Group business.
Transfer of information abroad
On occasions we may need to transfer your personal data to companies outside the European Economic Area which don’t have equivalent standards of protection under their legislation and on these occasions we take other steps to protect the data as required under applicable data protection laws and in line with article 46 of the GDPR.
How long is your information held by us?
The length of time your personal information is held will vary depending on the type of product or service we are supplying to you and will be held as long as our relationship remains in place. We will never hold the information for longer than we need to for the purpose we need to use it. Our normal policy is to keep documents for 7 years after the end of any facility you may have had with us but in the case of signed deed or other legal documents these may be retained longer and in some cases we may hold personal information beyond this time where we are aware or anticipate legal proceedings and will need the information to settle or defend any claim.
Your rights under the GDPR
Under the GDPR you have certain rights regarding your personal data. The GDPR provides the following rights for individuals:
• The right to be informed.
• The right of access.
• The right to rectification.
• The right to erasure.
• The right to restrict processing.
• The right to data portability.
• The right to object.
• Rights in relation to automated decision making and profiling.
Further information in relation to these individuals’ rights under the GDPR, including the circumstances in which they apply, can be obtained from the guidance notes from the UK Information Commissioner’s Office (“ICO”) (www.ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/).
You can also make a complaint to the ICO at www.ico.org.uk. For further information about exercising any of your rights in this Privacy Notice please get in touch with our Data Protection Officer using the contact details contained at the end of this policy.
Keeping you informed
We will keep your details on record until we have fully dealt with your request, enquiry or application and then for a reasonable period afterwards, in accordance with data protection and other applicable legislation.
We will let you know about products and services we are providing using any contact details you have given to us - for example by post, email, text message, social media or website.
In most cases we do not need your consent in order to send marketing information to you as we will normally be relying on legitimate interests as our lawful basis to do this. If we cannot rely on legitimate interests and, instead, we seek and obtain your consent to be able to send marketing information to you, you can withdraw that consent by contacting us directly on email@example.com or write to the privacy group at Calverton Finance Limited at our address below. You can also contact us on these addresses if you’d like to update your marketing preferences.
How to Contact us