8th June 2020
This policy applies to Funding Options Limited.
Here are the details that the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regards to the processing of personal data and on the free movement of such data, known as General Data Protection Regulation (GDPR) says we have to give you as a 'data controller':
- Who We Are
Funding Options Limited.
- Our site address is https://www.fundingoptions.com/
- Our company is Funding Options Limited, registered in England with registration number 7739337 and registered address at Cocoon Building, 4 Christopher Street, London, EC2A 2BS
- We are registered with the Information Commissioner’s Office ref (ICO): Z2992318
- We are authorised by the Financial Conduct Authority (FCA): 727867
- What information we collect
We collect and process the following data about you:
- Identity data, including name, username or similar identifier.
- Contact data, including email address, postal address, residential address and telephone numbers.
- Financial and business data, including financial requirements (e.g. how much our customers would like to borrow), business information, bank statements, filed accounts, VAT returns, bank account information, file and payment details; in case of sole traders – other personal financial data relevant to business finance application, such as value of personal pension, value of property equity, county court judgements (personal and business), credit ratings (personal and business).
- Transaction data, including details about payments to and from you and other details of products / services you have purchased from us or products / services we have purchased from you.
- Profile data, including your username and password, your interests, preferences, feedback and survey responses.
- Usage data, including information about how you use our website and products and services that you purchase from us
- Marketing and communication data, including your preferences in receiving marketing from us and our third parties and your communication preferences.
To keep your personal information up-to-date, please advise us of any changes by e-mail to email@example.com, and as soon as possible after any change in your name, residential address, telephone number, e-mail address and any other such important details.
We also collect, use and share Aggregated data such as statistical or demographic data. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage data to calculate the percentage of users accessing a specific website feature.
We do not generally collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).
Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following bases applies:
- you have given consent to the processing of your personal data for one or more specific purposes;
- processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
- processing is necessary for compliance with a legal obligation to which we are subject;
- processing is necessary to protect the vital interests of you or of another natural person;
- processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
- processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our credit card payment processing, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data.
We use different methods to collect data from and about you, including:
- Direct interactions when you make enquires or we purchase your products or services, you create an account on our site, request marketing to be sent to you, enter a promotion or survey, or give us feedback or contact us.
- Third parties or publicly available sources, including existing or prospective providers of finance to you (in the course of considering whether to make an application or making an application to them), analytics providers such as Google, advertising networks, search information providers,] and identity and contact data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
- How we use what we collect
We use information about you to:
- Help make decisions about credit and credit related services
- Provide partner and event information
- Retargeting purposes
- Improve our service
- Trade debtors, recover debt, prevent fraud, and to manage your accounts
- Prevent fraud and money laundering
- Present our site content effectively to you.
- Provide information and products and services that you request, or (with soft opt-in following your purchase, your consent or if we have another lawful basis, such as legitimate interest) which we think may interest you.
- Carry out our contracts with you.
- Tell you our charges.
If you are a sole trader, you acknowledge that credit reference agencies link together the records of you and anyone that you have advised is a financial associate (joint credit account). Links between financial associates will remain on your, and their, credit reference files until such time as you or your partner successfully files for a disassociation with the credit reference agencies. When assessing the affordability of your repayments, we may take into account information about your financial associates in your credit reference.
If you are already our customer, we will only contact you electronically about things similar to what was previously provided to or of interest to you and you will be given an opportunity to opt-out and unsubscribe from further communications.
Please note: We don't identify individuals to our advertisers, but we do give them aggregate information to help them reach their target audience, and we may use information we have collected to display advertisements to that audience.
If you don’t want us to use your personal data for any of the reasons set out in this section, you can let us know at any time by contacting us at firstname.lastname@example.org, and we will delete your data from our systems. However, you acknowledge this may limit our ability to provide our products and services to you.
In some cases, the collection of personal data may be a statutory or contractual requirement, and we will be limited in the products and services we can provide you if you don’t provide your personal data in these cases.
Type(s) of data subject
Categories of personal data
Purpose of processing
Customers, their employees and contractors
Identity data, Contact data, Communication data, Financial and business data, Transaction data
Process applications, make credit decisions, offer and provide products and services
Necessary for the performance of a contract (or pre-contractual steps)
Customers, their employees and contractors
Contact information, including name, address, telephone number and e-mail address
Marketing communications, including competitions
Consent, legitimate business interest or service/transactional communications
Suppliers, partners, subcontractors and their employees
Contact information, including name, address, telephone number and e-mail address; bank details
To enable compliance with obligations under relevant contracts, including processing order, refunds, logging and payment of invoices.
Necessary for the performance of a contract
Contact information, including name, company name, job position, address, telephone number and e-mail address, including those available via business networking websites, such as LinkedIn
Legitimate interests of all parties
1. The legitimate interests of both Funding Options Limited and our business contacts is to network in the context of business.
2. It is necessary to exchange, keep and otherwise process contact information in order to network in the context of business.
3. There is normally a positive action taken by all parties to provide their contact details during networking with the expectation that such contact details, including personal data, may be used by the recipient for business networking.
Staff - pre and post offer
Proof of Identity
contact details, such as email and phone number
Bank account information, previous employment details.
Validating permissions for employment, reference checks, criminal checks, Payroll purposes.
Legitimate interest of all parties
CV/LinkedIn Profile, contact/communication data such as email and phone number.
Facilitate communications in relation to applications
Legitimate interest of all parties
- Where we store your data
We store your personal data on our own service databases as well as selected third party providers, including but not limited to; AWS, Salesforce and Hubspot servers. This is used by the Funding Options service which sends customers emails and tracks the status of applications. We may transfer your collected data outside the European Economic Area (EEA). It may be processed outside the EEA as may be necessary to provide our products and services to you, to provide our service to you, or if we have your consent.
We will only transfer your data to countries that are deemed to have an adequate level of protection of personal data by the European commission; or we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe; or we may transfer data to US based providers, such as Hubspot, that are part of the Privacy Shield; or data may be transferred to other countries, but remain accessible within our organisation only, by employees including but not limited to contractors who are obliged to adhere to Funding Options policies and procedures.
By giving us your personal data, you agree to this arrangement. We will do what we reasonably can to keep your data secure.
If we give, or you create a password, you must keep it confidential. Please don't share it. Although we try to provide protection, we cannot guarantee complete security for your data, and you take the risk that any sending of that data turns out to be not secure despite our efforts.
We only keep your personal data for as long as we need to in order to use it as described above in section 5, and/or for as long as we have your permission to keep it. Our general retention period is 7 years but your data may be kept for shorter or longer periods of time, in accordance with our internal Data Retention Policy and applicable legislation. In any event, we will conduct regular reviews to ascertain whether we need to keep your personal data. Your personal data will be deleted if we no longer need it.
- Disclosing your information
We are allowed to disclose your information in the following cases:
- If we want to sell our business, we can disclose it to the potential buyer.
- We can disclose it if we have a legal obligation to do so, or in order to protect other people's property, safety or rights.
- We can exchange information with others to protect against fraud or credit risks.
We will also check your details with a fraud prevention agency or agencies and if you give false or inaccurate information and we identify fraud, this will be recorded and may be shared by those agencies with other organisations and us, so that we and other organisations, including law enforcement agencies and debt collection agencies may access, use and search these records as described in section 5.
With your permission we will share your personal data with suitable lenders for the purpose of loan underwriting.
We also contract with third parties to supply our products or services to you on our behalf. These may include payment processing, search engine facilities, web hosting, advertising and marketing. In some cases, the third parties may require access to some or all of your data. These are some of the third parties that have access to your information:
- AWS, Salesforce, Hubspot - storage of all data, including identity, contact, financial and business data, transactional data, technical data, profile data and usage data
- Accounting companies, as may be required for our compliance with statutory obligations and financial calculations - identity, contact, financial and business data, and transactional data
- IT services providers, as may be necessary for the provision of their services to us - identity data, contact data, financial and business data, transaction data, technical data, profile data, usage data and/or marketing and communications data
- Payment processing companies, as may be necessary for the provision of their services - identity data, contact data, financial and business data and transaction data
- Banks, as may be necessary for the provision of their services to us - identity data, contact data, financial and business data and transaction data
- Insurance companies, as may be necessary for the provision of their services to us - identity data, contact data, financial and business data and transaction data
- Debt collection agencies, as may be necessary for the provision of their services to us - identity data, contact data, financial and business data and transaction data
- Marketing and advertising services providers, as may be necessary for the provision of their services to us - identity data, contact data and transaction data
- Warehouse services providers, as may be necessary for the provision of their services to us - identity data, contact data and transaction data
- Telecommunication services providers, as may be necessary for the provision of their services to us - identity data, contact data, financial and business data, transaction data, technical data, profile data and usage data
- Other services providers, including law firms and documents services - identity data, contact data, financial and business data and/or transaction data as may be required for the provision of the relevant services
- FCA or governmental authorities, as may be necessary in order for us to comply with statutory requirements and official requests - identity data, contact data, financial and business data, transaction data, technical data, profile data, usage data, marketing and communication data.
Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under GDPR and the law.
In completing our job application form, submitting your CV or applying by LinkedIn or employment events, you will give us personal information about yourself. We will use your personal data only for the purpose of assessing your suitability for employment by us and in any subsequent interviewing process. Copies of the information you submit, and any further correspondence will be retained in order to progress your job application and as a record of our employment and fair access processes. Your application will only be processed by our People team. The information you provide to us will be stored and processed for internal recruitment purposes only. We may store and record any telephone calls you have with staff for record keeping and quality control purposes. We will retain your information in the event of an unsuccessful application for a period of 12 months, in line with GDPR. After this period the data will be anonymised.
- Your rights
You can ask us not to use your data for marketing. You can do this by ticking the relevant boxes on our forms, clicking the unsubscribe link contained in our marketing communications or by contacting us at any time at email@example.com.
Under the GDPR, you also have the right to:
- request access to, deletion of or correction of, your personal data held by us at no cost to you;
- request that your personal data be transferred to another person (data portability);
- be informed of what data processing is taking place;
- restrict processing;
- to object to processing of your personal data; and
- complain to a supervisory authority.
You also have rights with respect to automated decision-making and profiling.
- Links to other sites
Please note that our terms and conditions and our policies will not apply to other websites that you get to via a link from our site. We have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
- Automated Decision-Making and Profiling
We do not undertake any automated decision-making, including profiling.
- Notice to Staff
All staff have an obligation to read and adhere to all relevant Funding Options Policies. During the onboarding process e-learning will be assigned and completion is a requirement. Personal information held about staff will be stored securely and will only be accessible by authorised departments. All Funding Options hardware and software is the property of Funding Options. When leaving employment from Funding Options all staff are required to return all hardware, including access cards. If staff use the facilities for personal use, they understand that Funding Options has the right to access the hardware and software at any time without notice. If communications are of a personal nature staff should clearly subject the content as personal. However, Funding Options will still have the right to access these if needed.