GDPR Privacy Policy

A. INTRODUCTION

Welcome to Capital Finesse Limited. Thank you for your interest in our products. We are committed to protecting and respecting your privacy. This notice will provide you all the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data. As you have entrusted us your data, we ensure we meet our legal obligations to you under relevant data protection regulations and laws including EU General Data Protection Regulation (‘GDPR’) and Data Protection Act 2018 (‘DPA’).

B. WHO WE ARE

Capital Finesse Limited is registered in England and Wales under company number 16084713. We are a ‘data controller’ under the GDPR and DPA.
Company Registration Information:
England and Wales under company number 16084713
Company Registered Office Address:
Office Address: 86-90 Paul Street, London EC2A 4NE, UNITED KINGDOM
Our Designated Responsible Person:
Compliance Officer
Capital Finesse Limited
86-90 Paul Street
London
EC2A 4NE

C. THE INFORMATION THAT WE COLLECT

We collect information and your personal data in a number of different ways.
1. Through our website.
• When you visit our website
• When you attempt to apply for a credit
2. Through completed application form
3. Through communications.- When you contact us or you replied to a communication from us. This includes telephone calls (which may be recorded), letters, sms messages and e-mails - When we receive feedback from you and when you response to research surveys.
4. From third party commercial en
tities, including credit reference agencies and lead brokers.
5. From government agencies, such as the courts and electoral register.
6. From collections agencies, tracing agencies, debt management companies.

What type of information we collect from you?

• Your IP Address, browser type and type of device you use
• Your Full Name
• Your Date of Birth
• Home Address
• Contact Details: contact numbers and email address
• Business Details
• Bank Details
• Payment Details
• Your Asset & Liability details
• Other personal information that you may provide us in support of your application.

How We Use Your Personal Data?

We collect your personal data to ensure we provide you with the best service we possibly can. Capital Finesse commits to respect and protect your privacy. We will never disclose, sell and share your data without your consent unless required to do so by law. The purpose and reasons why we collect your personal data are:

• To assess, develop and improve the products and services we provide.
• If you make an application, you confirm that all information provided by you is accurate and complete. You also consent to use your information to carry our credit assessment including checking credit history held by Credit Referencing Agencies
• To check your identity, assess your credit history,
• To enter into a credit contract or to ensure the performance of your obligations under the contract.

Information We collect from other sources

We may receive information about you if you make an enquiry about or apply for credit or use any of the other services which we provide. In this case, we will have informed you when we collected that data that it may be shared internally and combined with data collected on this site.

Fraud Prevention Agencies. In the event that you provide us with false or inaccurate information, and we have reasonable grounds to suspect fraud, we may share your information with a fraud prevention agency to create a digital footprint based on all available information associated with any attempt to commit fraud. Any information disclosed to a fraud prevention agency may be used by them for statistical analysis and disclosed to other organisations to prevent any further fraud or attempted fraud.

Identity and Document Checking Service. We use identity and document checking service for address verification, Politically Exposed Person (PEP) & Sanction checks, identity document verification and liveness check which means at certain stage of the process you need to do a selfie.

Credit Reference Agencies. We use credit reference agencies to help build a better understanding of your financial circumstances, but the information which they provide to us alone does not determine your eligibility (or otherwise) for credit from us. The information which we collect from credit reference agencies relating to you is for our own use only. We will notify credit reference agencies of any default of your obligations under any such contract with us and/or your account being referred for legal collection. We only use UK-based credit and fraud agencies and do not disclose any of your information to any third party companies outside the United Kingdom or otherwise in a manner which does not comply with the GDPR and DPA.

In order to process your application, we will perform credit and identity checks on you with one or more credit reference agencies (“CRA”). Where you take financial services from us we may also make periodic searches at CRAs to manage your account with us.

To do this, we will supply your personal information to CRAs and they will give us information about you. This will include information from your credit application and about your financial situation and financial history. CRAs will supply to us both public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information.

We will use this information to:

a. Assess your business affordability and whether you can afford to take the product
b. Verify the accuracy of the data you have provided to us
c. Prevent criminal activity, fraud and money laundering
d. Manage your account(s)
e. Trace and recover debts
f. Ensure any offers provided to you are appropriate to your circumstances

We will continue to exchange information about you with CRAs while you have a relationship with us. We will also inform the CRAs about your settled accounts. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt. This information may be supplied to other organisations by CRAs.

When CRAs receive a search from us they will place a search footprint on your credit file that may be seen by other lenders.

If you are making a joint application, or tell us that you have a spouse or financial associate, we will link your records together, so you should make sure you discuss this with them, and share with them this information, before lodging the application. CRAs will also link your records together and these links will remain on your and their files until such time as you or your partner successfully files for a disassociation with the CRAs to break that link.

The identities of the CRAs, their role as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRAs are explained in more detail within the Credit Reference Agency Information Notice (CRAIN).

This notice is accessible from each of the three CRA links below:
1. Callcredit:www.callcredit.co.uk/crain
2. Equifax:www.equifax.co.uk/crain
3. Experian:www.experian.co.uk/crain

MARKETING

As a valued customer or when you agreed to receive marketing messages from us, Capital Finesse will occasionally contact you with the information of our products and services that might interest you. If you do not wish to receive marketing information from us, you can opt out anytime by sending “OPTOUT” to our email info@capitalfinesse.com.

COOKIES

We use session cookies, which are temporary cookie files that store your browsing information during your time on our site and enable us to know it’s you as you move from page to page through the application process, so you don’t have to repeatedly enter information. These cookies are active until you leave the site and are then erased when you close your browser. We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration. This is statistical data about our users' browsing actions and patterns, and does not identify any individual. You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our site, and you will be unable to fully complete the online application process as we need to use temporary session cookies to store information that enables us to know it’s you as you work through the process. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our Site.

Our legal basis for processing personal data

We need to collect your personal information in order to enter into a finance contract with you. Under GDPR and DPA, our lawful basis for processing your personal information is as follows:

• To provide you with our products and services
- To allow us to process your application, we will use your personal information to assess your suitability for finance
- Lawful Basis: Fulfilling a Contract, Legal Duty, Legitimate Interests - promoting responsible lending and helping to prevent over indebtedness; to prevent, detect, investigate and report financial crime.
• To manage our agreement and relationship with you
- We will process your information to ensure that you are able to fulfil your obligations under your credit agreement and to communicate with you to provide and manage your needs.
- Lawful Basis: Fulfilling a Contract, Legal Duty, Legitimate Interests - to manage your agreement with us and ensure repayments are made and received.
• To meet our Legal Obligations
- We may process your information for the prevention, detection and investigation of fraud and money laundering and to comply with laws and regulations that we have to adhere as a regulated credit provider; and to meet our obligations if we are required to disclose information by reason of any law, regulation or court order
- Lawful Basis: Legal Duty
• To send you details of our products and services
- To provide you with information on other products and services we can offer you
- Lawful Basis: Consent, Legitimate Interests - to send information on similar products where you have not previously objected where these products and services may be of genuine interest to you, for example when your current account is repaid or where there are possible alternatives available to you during the term of your agreement.

Safeguarding Measures

Capital Finesse takes your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place, including:

1. We conduct appropriate checks on members of staff
2. Anti-virus/malware software
3. Data encryption techniques
4. Restricted access
5. Cloud storage
6. Disaster recovery
7. IT authentication
8. Firewalls
9. High tech solutions
10. Locked filing cabinets
11. Alarms and door locks
12. Secure passwords

If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to correct it as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.

How Long Do We Keep Your Data

We will only retain personal data for as long as is necessary. In accordance with our retention policy and applicable anti money-laundering legislation, we will retain your personal data for a minimum of six years from the end of our business relationship with you. Our business relationship will be deemed to be at an end on the date upon which your account is closed. This will either be when all outstanding sums under the agreement have been repaid or when we stop pursuing arrears on the account. You can view our data retention policy here.

Please note that we do record calls for staff training and fraud prevention purposes.
Sharing and Disclosing Your Personal Information Who has access or may access your information:

1. All our staff
2. Our agents who may meet with you
3. Credit Reference Agencies
4. System and Software Provider
5. Third Parties
a. Debt Collectors and tracing agencies - if your account remains unpaid and we wish to initiate further recovery process.
b. Solicitors / Money Claim Online / HM Court & Tribunals Service – if your account remains unpaid and we pursue court recovery.
c. Debt Purchasers – if your account remains unpaid and we sell your data
d. Fraud Prevention and Law Enforcement Authorities
if false or inaccurate information is provided, including in relation to a person’s identity and fraud is suspected or identified. Details about this information including customer Personal Data will be passed to Fraud Prevention Agencies We and other organisations may also access and use personal information to prevent and detect crime, fraud and money laundering.
e. Debt Collectors if your account remains unpaid.

We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement, or where it is in our legitimate interests to do so. Capital Finesse Limited use carefully selected third-parties to provide some services and business functions; however, all processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy notice, the data protection laws and any other appropriate confidentiality and security measures.

Your Rights

The GDPR and DPA provide the following rights for individuals:
1. The right to be informed
2. The right of access
3. The right to rectification
4. The right to erasure
5. The right to restrict processing
6. The right to data portability
7. The right to object
8. Rights in relation to automated decision making and profiling.

Here we briefly explain what these are in the context of Capital Finesse Limited. This Privacy Statement and our application and agreement documents explain the collection and use of your personal data, including our purposes for processing your personal data, our retention periods for that personal data, and who it will be shared with.
Accessing, correcting, and deleting your information.
You have the right to access the personal information we hold on you by writing to us at the address provided in this Privacy Notice. You also have the right to have your data corrected if it is inaccurate or incomplete, and if we have no legal or legitimate justification in retaining your data, you may have a right to request its deletion or to restrict us from processing your information if it is incorrect or no longer required. However, there may be legal reasons as to why we may need to keep your data.

Right to Object.
You have a right to object to the processing of your information in cases where we do not have legitimate grounds for processing your personal data.

Data Portability
You have the right to ask us to provide you with a copy of the personal information you provided to us or to request that we transfer this data to another organisation in a format that can be easily re-used.

Marketing
You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by checking the relevant box or confirming your preference when applying for credit. You can also exercise the right at any time by contacting us.

Automated decision making and profiling.
When we collect your personal information either directly from you or from other authorised sources, we may use systems to make automated decisions.

The Types of automated decisions we make are:
• Pricing – We sometimes make decisions on the cost of the product and services you have applied for based on the information we have collected.
• Approving Credit – Once you submit an application for finance, we may make automated and manual decisions to establish whether we can offer you our products and services and to proceed with your application.
• This decision is based on our credit rating models which assess how likely you are to act while paying back any funds borrowed. This assessment will check on how you have paid similar accounts in the past.
Our credit rating model uses three sources to ensure a fair and well-informed outcome is achieved:
• The details you submit on your application form.
• Information held and supplied from credit reference agencies.
• Any data that we may already hold that relates to you.
You can ask Capital Finesse Compliance Team not to make our decision based on automated means alone and you can object to an automated decision and request that we review your application manually.

What to do if you wish to make a complaint.

If you are unhappy with how we have processed your personal information, please contact Capital Finesse Compliance Team at the address stated above.
You also have the right to make a complaint to the Information Commissioner’s Office (‘ICO’), which regulates the processing of personal data in the UK. You can do this by phone on 0303 123 1113, or via the ICO website www.ico.org.uk.

Changes to this policy

Any changes we may make to this privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to this Privacy Policy.

Last modified: 18 November 2024