PRIVACY POLICY

FUNDING ALTERNATIVE GROUP LTD

PRIVACY NOTICE

(Updated 20 December 2024)

We respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. This privacy notice is provided in a layered format so you can click through to the specific areas set out below:

1. Important information and who we are
2. The data we collect about you
3. How is your personal data collected?
4. How we use your personal data
5. Cookies
6. Disclosures of your personal data
7. International transfers
8. Data security
9. Data retention
10. Your legal rights

1. Important information and who we are

Funding Alternative Group Ltd is the controller and responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice). Our ICO reference number is ZA599363.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us at privacy@fundingalternative.co.uk.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements other notices and privacy policies and is not intended to override them.

Changes to the privacy notice and your duty to inform us of changes

We keep our privacy notice under regular review. This version was last updated on the date stated at the beginning of the policy. Any changes we may make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by email.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. The data we collect about you

You give us your personal data when you apply for funding from us, contact us or communicate with us in any way (directly or through our introducers, agents or contractors), through our social media channels, sign up to receive emails and other communications from us our introducers, agents or contractors, create or manage your account on our website, or apply for a job with us.

When you apply for funding from us, we need to perform enhanced identity checks on your company and its directors before we are able to process your application or approve funding. This includes Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFL) checks. We will also monitor the credit profiles of all directors of the company applying for funding from us during the life of the business cash advance to ensure that no adverse credit behaviours are exhibited.

If you are a director of the company who will be personally guaranteeing the funding applied for, we need to perform additional checks to confirm your position at the company and ensure you are able to fulfil your obligations as guarantor for the company. Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

i. if you apply for funding with us, we will record a history of applications for funding made by you, the outcome of our AML, CFL, credit profile and director profile checks. We will also record the outcome of your credit and Know Your Client (KYC) checks, copies of your passport, driving licence and/or national ID card, a copy of your signature image, a copy of your work permit (if applicable), and your statement of position and role at your company. ii. if you receive marketing from us, we may track any subsequent actions online. iii. if you apply for a job with us, we will record your references, the outcome of your Disclosure and Barring Service (DBS), credit and background checks, copies of your passport, driving licence and/or national ID card, and a copy of your work permit before you are appointed. If you are appointed as our employee, we will provide you with a copy of our employee data privacy policy that explains how we will process your data as your employer.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. 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. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice. We collect, use and share the following data as Aggregated Data only:

We will only collect Special Category Data or Criminal Convictions Data about you if you apply for a job with us and have disclosed this to us or a DBS check has been carried out and brought to our attention via a background check.

Special Category Data is considered as being sensitive personal data, which requires a higher level of protection. We need to have further justification for collecting, storing and using this type of personal data.

We will only collect Criminal Conviction Data if it is appropriate given the nature of the role and where we are legally able to do so. If a DBS check has been carried out and is brought to our attention via a background check, we will collect Criminal Conviction Data as part of the recruitment process. We may also be notified of such Criminal Conviction Data directly by you as part of the recruitment process or in the course of you working for us.

Please see the ‘Purposes for which we will use your personal data’ section below for more information about our processing of Special Category Data or Criminal Convictions Data.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with funding or consider you as a candidate for a vacancy). In this case, we may have to cancel your application for funding or a job application you have with us, but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you, including through:

Direct interactions with you

By filling in forms on our website or by corresponding with us by post, phone, email or otherwise, you may give us your Identity, Contact, Profile, Financial and Marketing and Communications Data. This includes personal data you provide when you apply for funding from us, contact us or communicate with us in any way, sign up to receive emails and other communications from us, create or manage your account on our website, or apply for a job with us.

Automated technologies or interactions

As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using the cookies described in the ‘Cookies’ section below, server logs and other similar technologies.

Third parties

We receive personal data about you from various third parties including Identity, Contact and Profile Data from:

• AML verification providers such as SmartSearch,
• credit check report providers such as Experian and Creditsafe,
• publicly available sources such as Companies House,
• other lenders, our introducers and agents,
• social media and other technology providers. For example, when you click on one of our ads.
• online lead generation databases, and
• our contractors

the majority of which are based inside the UK.  Some of our introducers, agents and contractors are based outside of the UK.  Where we share your personal data with them or they share data  with us, we will ensure appropriate safeguards are in place in respect of that transfer of personal data across border.  Please see section 9 on international data transfers below.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• where we need to perform a contract that we have entered into with you. This means processing your personal data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
• where it is necessary for our legitimate interests. This means our interests in conducting and managing our company to enable us to give you the best service and to promote our services. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• where we need to comply with a legal obligation. This means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out a description of all the ways we plan to use your personal data and which of the legal bases we rely on to do so in the table below. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Processing Special Category Data and Criminal Conviction Data

We may process Special Category Data in the following circumstances:

• in limited circumstances, with your explicit written consent;
• where we need to carry out our legal obligations or exercise rights in connection with employment;
• where it is needed in the public interest; and/or
• where it is necessary to protect you or another person from harm.

We may process Criminal Conviction Data in the following circumstances:

• to assess your suitability for a role;
• where it is necessary in relation to legal claims,
• where it is necessary to protect your interests (or someone else’s interests) and you are not capable of giving your consent;
• where you have already made the information public; and/or
• with your explicit written consent.

Marketing and promotional information

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us, applied to be an introducer who will bring clients to us, contacted one of our introducers, agents or contractors about the type of services we provide or applied for funding from us directly, any of our marketing campaigns (social media, email, Google PPC etc) and you have not opted out of receiving that marketing from us or our introducers, agents or contractors.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us to stop sending you marketing messages at any time by emailing ‘STOP’ in the subject line to privacy@fundingalternative.co.uk or using the opt-out or unsubscribe link in the marketing messages, or by contacting us on +44 800 652 1977 at any time.

Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of you applying for funding from us, contacting us or communicating with us in any way other than to request marketing messages, creating or managing your account on our website, or applying for a job with us.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Credit Reference Agencies

In order to process your application, we will perform credit and identity checks on you with one or more Credit Reference Agencies (CRAs). We may also carry out further periodic searches at CRA’s to allow us to manage your account with us.

To do this, we will supply your personal information to CRAs. This will include your name, date of birth and residential address. It may also include additional information such as your salary, previous residential addresses and other information you provide as part of your credit application.

The CRAs will match this information to the records they hold about you, and provide in return, both public information (including the electoral register) and shared credit information in relation to your financial situation and financial history.

CRA’s 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:

• Assess your creditworthiness and whether you can afford to take the product;
• Verify the accuracy of the data you have provided to us;
• Prevent criminal activity, e.g. fraud and money laundering;
• Manage your account(s);
• Trace and recover any debts; and
• Ensure any offers provided to you are appropriate to your circumstances.

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

When CRA’s 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 of a 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. CRA’s will also link your records together and these links will remain on your and their files until such time as your partner successfully files for a disassociation with the CRA’s to break the link.

The identities of the CRA’s, their role also 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 CRA’s are explained in more detail at www.cifas.org.uk/fpn,  http://www.experian.co.uk/crain/index.html or www.equifax.co.uk/crain

6. FRAUD PREVENTION

The personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance, or employment. Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights, can be found by visiting Cifas.

We and fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime

We process your personal data on the basis that we have a legitimate interest in preventing fraud and money laundering, and to verify 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 or financing you have requested.

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.

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.

Fraud prevention agencies may allow the transfer of your personal data outside of the UK. This may be to a country where the UK Government has decided that your data will be protected to UK standards, but if the transfer is to another type of country, then the fraud prevention agencies will ensure your data continues to be protected by ensuring appropriate safeguards are in place.

7. Cookies

For full details on what cookies are, what they do, and which cookies are used by us, please see our Cookie Policy.

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. We use them get information like how many times you have visited our site, how long you stayed and what you did. We keep a particular cookie from a few minutes to two years depending on what it is used for.

8. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the purposes for which we will use your personal data table above.

• Third party providers such as SmartSearch and Experian, who provide background check and AML verification services.
• Third party providers such as Experian and Creditsafe, who provide credit check services.
• Third parties to whom we may choose to sell, transfer or merge parts of our group or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our group, then the new owners may use your personal data in the same way as set out in this privacy notice.
• Third parties to whom we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements or to protect the rights, property, or safety of you or others.
• Professional advisers such as lawyers, bankers, auditors and insurers based in the UK who provide consultancy, legal, banking, accounting and insurance services.
• HM Revenue & Customs, regulators and other authorities based in the UK who require reporting of processing activities in certain circumstances;
• Our business partners specifically other lenders, introducers, agents and contractors based both in and outside of the UK who work with us in relation to our business, our services and our relationship with you.
• Social media sites such as LinkedIn, Meta and google for the purposes of conducting market research and running marketing campaigns (it is important to note that, when sharing data with these sites, we ensure that your data is only used in accordance with our instructions).

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

If your funding application is unsuccessful with us, we may pass your application to Funding Xperts to seek funding from a wider network of lenders.

9. International transfers

We transfer your personal data to third parties who may, in turn, transfer your personal data to databases or office locations outside of the UK such as Experian or directly to introducers, agents and/or contractors who may be based in or outside of the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK for example, international data transfer agreements or international data transfer addendum.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

10. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. Our employees also undertake regular data security training.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

11. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our clients (including Contact and Identity Data) for six years after they cease being clients for tax purposes.

In some circumstances you can ask us to delete your data: see the section below called “Your legal rights” for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

12. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out below, please contact us at privacy@fundingalternative.co.uk. You have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate personal data we hold about you corrected, though we may need to verify the accuracy of the new personal data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your personal data unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your personal data which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  
  • if you want us to establish the personal data’s accuracy;
  • where our use of the personal data is unlawful, but you do not want us to erase it;
  • where you need us to hold the personal data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  • you have objected to our use of your personal data, but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated personal data which you initially provided consent for us to use or where we used the personal data to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain events, products or services to you. We will advise you if this is the case at the time you withdraw your consent.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Contact details

Funding Alternative Limited, ICO reference number: ZA599363

Email address: privacy@fundingalternative.co.uk

Postal address: 104 Roebuck Road, Chessington, KT9 1EU

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). Before contacting the ICO we would like the chance to deal with your concerns so please contact us first.

Third-party links

Our website may include links to third-party websites, plug-ins and applications. If you click on those links or enable those connections this may let third parties collect or share data about you. We do not control these third-party websites and are not responsible for what they do with your personal data.

You and your personal data

We do not provide services to individuals only to businesses [that are limited companies]. We refer to those businesses and any individual within them who have authority to deal with us as “you”.

When you share personal data with us which is not about you but about another individual e.g. an employee, director or owner you confirm you have their permission to do so and that they understand how we will use their personal data.

Personal data, or personal information, is information about an individual which can identify who that person is. It does not include data where the identity has been removed (anonymous data).

Information we collect and hold about you

We get information about you in a number of different ways.

Direct Interactions

This is information that has come directly from you such as:

• our own records of your shareholders (and any beneficial owners), suppliers and companies you use or deal with
• directors, partners, beneficial owners, signatories or employees in your business
• people you have appointed to act on your behalf

Information from our website:

• Details you give when you apply for funding like your name, home address, date of birth, email, phone number, geographical location, ID, photograph.
• Details about your business such as its size, industry, and financial information to check if it qualifies for funding.
• Your login details and the settings you choose for our website and your card, so that you can use these securely.
• Your IP address for security reasons.
• Your device ID, which we may share with companies that help us with online advertising.

When you get in touch

We collect information so we can answer your questions or help you like:

• The phone number you use to call us and information you give us during the call (we record all calls).
• The email address you use and contents of your email (and attachments).

When you use our services:

We collect information to give you services which are safe and lawful and to improve them including:

• Details about payments you have made and money paid to you
• How you use our services
• How you use our website
• as part of our services or assessing an application from you we may require access to the platforms you use to run your business (such as banking, sales, advertising, and accounting) and use the data shared to determine eligibility and monitor performance

From external sources

These include third party service providers and publicly available sources such as:

• Our Open Banking Partner, Plaid (please see their Privacy Policy, Terms of Service for more information)
• Our Payments Partner, Axcess Payment Services (please see their Privacy Policy, Terms of Service for more information)
• Anti-Money Laundering and Know Your Customer service providers
• Companies House and the Electoral Register
• Fraud prevention agencies
• Our introducers, other lenders, agents and contractors.

How and why we use your personal data

We will only use your personal data when the law allows us to. Usually we use your personal data in the following situations:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

Plaid

Funding Alternative is an agent of Plaid Financial Ltd., an authorised payment institution regulated by the Financial Conduct Authority under the Payment Services Regulations 2017 (Firm Reference Number: 804718). Plaid provides you with regulated account information services through Funding Alternative as its agent.