1. What does this Privacy Notice cover?

This Privacy Notice applies to the following circumstances:

• personal data processed when you visit and use our website (“website”);

• personal data processed to service our potential and existing agents (“agents”);

• personal data processed to service our potential and existing customers (“customers”).
  

2. Data Protection Principles

We comply with the principles set out in the Data Protection Act (DPA), meaning personal data must be:

• used lawfully, fairly, and in a transparent way;

• collected only for valid purposes we have clearly explained;

• relevant and limited to what is necessary;

• accurate and kept up to date;

• kept only as long as necessary; and

• stored securely.

Personal data means information about an individual from which they can be identified. Anonymous data is excluded.

3. What Personal Data Do We Collect?

3.1 Personal Data Gathered from You

Website

When you visit our website, we collect minimal personal data, such as:

• your computer/device information, including browser type and settings;

• log data (pages visited, time spent, search history, IP address, access times/dates);

• interaction history with webpages;

• other non-direct identifiers based on website actions.

Providing your data is optional but may be necessary for certain services.

Agent

We collect the following personal data during onboarding of directors and ultimate beneficial owners:

• name;

• email address;

• telephone number;

• address;

• nationality;

• date of birth;

• security credentials;

• professional information (CV);

• identification documents.

During the relationship, we also collect:

• account activity;

• communications with staff;

• portal usage.

Customer

We collect the following personal data during customer onboarding:

• name;

• email address;

• telephone number;

• address;

• nationality;

• date of birth;

• security credentials;

• identification documents.

Ongoing data collected includes:

• account activity;

• communications with staff or agents;

• portal usage.
  

3.2 Personal Data from Other Sources

Website

We do not collect personal data from other sources for the website.

Agent

We may collect director and beneficial owner data from sources such as:

• credit reports;

• credit references;

• criminal background checks;

• compliance checks.

Purposes include:

• fitness and probity checks;

• fraud prevention;

• compliance with regulations;

• service personalization.

Explicit consent will be requested before any credit search.

Customer

We may collect external data (mainly compliance-related) for fraud prevention, legal compliance, and service improvement.

3.3 Cookies and Similar Technologies

Our website uses cookies. You can access our full [Cookies Policy] on our website.

4. How Do We Use Personal Data?

Website

We use personal data to:

• provide support and communicate service updates;

• enable website navigation and service registration;

• comply with legal obligations;

• improve the website and services.

Agent

Data is used for:

• onboarding and account management;

• compliance and regulatory checks;

• fraud prevention;

• customer service;

• statistical and behavioral analysis.

Communications may be monitored for quality assurance and legal compliance.

Customer

Data is used for:

• onboarding and account management;

• payment processing;

• compliance and regulatory checks;

• customer service;

• statistical and behavioral analysis.

Communications may be monitored for the same purposes as with agents.

5. Who Your Personal Data May Be Shared With

We may share your personal data with:

• agents and contractors;

• service providers;

• credit reference agencies;

• law enforcement agencies;

• legal representatives;

• IT system processors.

We never sell your personal data.

6. Reasons We Can Collect and Use Personal Data

We process personal data based on:

• contractual necessity;

• legal obligation;

• legitimate interests (where these do not override your rights);

• your consent (especially for marketing purposes).
  

7. How Long Your Personal Data Will Be Kept

We retain personal data following our Data Retention Policy, throughout contractual relationships and for legal/regulatory compliance after termination. If not required, we delete, destroy, or anonymize it.

8. Keeping Your Personal Data Secure

We implement strong technical and organizational measures to secure personal data. Access is limited to authorized individuals.
Despite our efforts, online data transmission cannot be guaranteed 100% secure.

9. Transfers of Personal Data Outside the EEA

If your data is transferred outside the UK/EEA, it will be protected through mechanisms such as Standard Contractual Clauses to ensure lawful and secure processing.

10. Marketing

We may send marketing communications by post, email, or telephone, if you opt in.
You can opt out at any time by contacting us or using unsubscribe links.

11. Credit Checking Policy

We may perform credit checks (with your explicit consent) to assess financial crime risks or make credit decisions.
Suspected fraud may be recorded with appropriate authorities.

12. What Rights Do You Have?

You have the right to:

• Access your data;

• Rectify inaccurate data;

• Erase your data (under conditions);

• Restrict processing;

• Object to processing;

• Port your data to another entity.

We will respond to your requests within one month.

You can unsubscribe from marketing at any time.

13. Changes to the Privacy Notice

Last updated: 12 January 2022.
We may update this Privacy Notice periodically.
We will notify you of material changes via:

• email (if opted-in);

• notices on the website.