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1.

Introduction

Assetz Exchange is committed to protecting the information that we hold about you. We also wish to be transparent about how we collect, hold, retain and use your information in line with applicable laws and regulation.

This privacy policy describes:

  • What information we collect from you and hold about you.
  • How long we retain this information and why.
  • Who we may share your information with and why
  • How we may use your information and our bases for doing so.
  • Our use of cookies.
  • Where we may send your information.
  • Your rights in relation to this information.

For our lenders, Assetz Exchange Limited, trading as Assetz Exchange, is the Data Controller for your personal data. This means it is responsible for deciding how your personal data is used.

The scope of this privacy notice is limited to personal data. ‘Personal data’ is information that relates to an identifiable natural person who can be directly or indirectly identified from that information, for example, a person’s name, address, date of birth, an identification number, location data and so on.

Please note that Assetz Exchange will never sell your personal data to a third party.


2.

Information we collect from you and hold about you

The information that we hold about you typically will come from you directly, often when you register as a lender on the platform or when you apply for a business loan as a borrower. The information that we collect from you will include the following:

  • Your personal details (such as name, date of birth, and possibly other information required to confirm your identity in accordance with applicable laws and regulation);
  • Your contact details (such as e-mail address, postal address, telephone number, mobile number).
  • Transactional details relating to your Assetz Exchange account (such as deposits and withdrawals, details of investments in loans);
  • Financial information (such as bank account details to process payments or withdrawals).

If you choose not to provide information that we tell you is essential for the creation or maintenance of a lender account or the monitoring and servicing of a loan, we may be unable to provide you with the requested service(s) or it may affect our ability to perform our obligations under an agreement with you. Where this is the case, we will tell you and explain why.

If you give us information about other people (such as asking us to allow another person to access or operate your account on your behalf whether by Power of Attorney or other means) which we will use in the provision of our services, you confirm that they are aware of this privacy notice and the information contained herein regarding the use of their data.

In addition to information which you give to us directly, we will also hold information we collect from other sources. This will include:

  • The way you use your account(s) with us (such as information about the specific products, features or services you use, the way you use our website, mobile applications, telephone services, live chat).
  • Any other interactions you have with us (such as forum use, Q&A participation, event attendance, through social media or other channels);
  • We may collect details from devices you use when connecting to our web site or through mobile apps (such as identifying the IP address a device connects from, the device type and the way you interact with our web site or mobile app
    • this information may be used in the interests of the security of your account and/or to allow us to improve our service and offering to you);
  • Records of checks we conduct to comply with legal and/or regulatory requirements (such as checks to confirm identity in line with Money Laundering Regulations).
  • People or organisations who you appoint to act on your behalf;
  • Other financial institutions who may allow you to access your Assetz Exchange account via their web site or app using an API or some other interface where the provision of their service to you requires them to provide information to us.

3.

How long we keep the information we collect from you and hold about you

We retain your information for as long as we continue to have a relationship with you. For a lender, this means as long as you continue to have an account with Assetz Exchange.

When our relationship with you has come to an end (for example, following the closure of a lender’s account) we will only retain your information for as long as we have a lawful reason for doing so. Similarly, if a lender decides not to proceed with a registration, we will only retain data for as long as it is legitimate for us to do so.

Once our relationship with you has ended, we will retain information that allows us to:

  • Comply with record-keeping requirements under law or regulation (for example, as required under the Money Laundering Regulations);
  • Deal appropriately with any complaints regarding the services we have provided.
  • Defend (or potentially bring) any existing or future legal claims;
  • Maintain records of anyone who does not want to receive marketing from us to prevent us from inadvertently ignoring your wishes in the future.

The period over which we may lawfully retain information is often linked to the record- keeping requirement (for example, five years from the end of the relationship in the case of checks made to comply with the Money Laundering Regulations) or to the amount of time available to bring a legal claim (typically six years for claims in relation to a contract).

We would retain your information after this time only if we are required to do so to comply with law or regulation, or if there are complaints or claims outstanding which reasonably require your information to be retained for longer.

If we do retain your information for lawful reasons, we will continue to ensure that your privacy is protected.


4.

Who we may share your data with and why

We will protect your information and keep it secure and confidential, but we may share it with third parties (who generally also have to protect it and keep it secure and confidential) under certain circumstances.

Those with whom we may share your data include:

  • Any other person who you have properly authorised to use your Assetz Exchange account or to give us instructions on your behalf (such as under a Power of Attorney).
  • Banks, payment service providers and other financial institutions that allow us to process payments to and from your Assetz Exchange account in accordance with your instructions, or for borrowers, payments in relation to a loan.
  • Other financial institutions who you (or a third party properly authorised to give instructions on your account) ask us to share information with (for example, if you authorise, set up and use another company’s web portal or app to access and manage your Assetz Exchange account via an API).
  • UK authorities, law enforcement agencies and regulators in connection with the execution of their duties (and, where required to do so, their overseas equivalents).
  • HM Revenue and Customs (‘HMRC’) insofar as we are required to do so by law.
  • Our service providers (including their subcontractors). This may include, for example, third parties who help us to perform identity verification checks or who help us to communicate with you. Where we use service providers, we ensure that they protect your data as we would.
  • Other companies in the Assetz Group (for example, to offer you products or services which may interest you and for marketing purposes, provided you have consented to receive marketing communications from us).

Please note that if information is shared at your request with a third party, we will have no control over how that information is used. You will need to understand and agree the scope of any such use directly with the third party before making the request.


5.

How we use your information and the bases upon which we do so

By law, we are allowed to process your personal data only if we have a proper reason to do so. The law says we must have one or more of the following reasons:

  • Consent – you have given us clear consent for us to process your personal data for a specific purpose.
  • Contract – the processing is necessary to fulfil a contract we have with you, or because you have asked us to take specific steps as a precursor to entering into a contract.
  • Legal obligation – the processing is necessary for us to comply with the law.
  • Legitimate interests – we have a business or commercial reason of our own to use your information, known as a legitimate interest, which we tell you about and which does not unfairly go against your interests.

This section summarises our processing and our reasons for doing so.

How we use your personal information Our reasons Our legitimate interests
Providing our service to you and managing our relationship with you as a customer
  • Fulfilling our contract with you
  • Our legitimate interests
  • Fulfilling our contractual duties efficiently
  • Keeping our records up to date
  • Working out which of our products and services may be of interest to you
  • Developing new products and services
Communicating with you
  • Your consent
  • Fulfilling our contract with you
  • Our legitimate interests
  • Fulfilling our contractual duties efficiently
  • Keeping our records up to date
  • Telling you about products and services that may interest you
Managing our operations associated with delivering our products and services, making and receiving payments.
  • Fulfilling our contract with you
  • Our legal obligations
  • Our legitimate interests
  • Fulfilling our contractual duties efficiently
  • Complying with applicable law and regulation
Exercising our rights as set out in agreements or contracts
  • Fulfilling our contract with you
Running our business in a proper way including managing our financial position, corporate governance, business capabilities, risk and compliance, testing and deploying systems and processes, managing communications properly and appropriately
  • Our legal obligations
  • Our legitimate interests
  • Fulfilling our contractual duties efficiently
  • Complying with applicable law and regulation
Detecting, investigating, reporting and preventing financial crime.
  • Fulfilling our contract with you
  • Our legal obligations
  • Our legitimate interests
  • Protecting our business and its customers
  • Improving our products, services and systems
  • Complying with applicable law and regulation
Complying with law and regulation more broadly, including cooperating with the proper authorities in the execution of their duties and remits
  • Our legal obligations
Responding to your feedback and concerns, including dealing appropriately with complaints or legal claims.
  • Fulfilling our contract with you
  • Our legal obligations
  • Our legitimate interests
    Understanding your concerns and improving our products or services
Studying how our customers use our products and services, managing our products, services and brand
  • Our legitimate interests
  • Developing new products and services
  • Improving existing products and services
  • Working out which of our products and services may be of interest to you
  • Enhancing our brand
Developing and carrying out marketing activities
  • Your consent

6.

Automated processing of your data

Assetz Exchange makes very limited use of automatic processing of your data in the provision of our services to you: Example of automatic processing include:

  • Identify verification, anti-money laundering and sanctions checks.
  • Screening of individuals who may be classed as ‘Politically Exposed Persons’.
  • Transaction monitoring for the purposes of preventing fraud and other forms of financial crime.
  • Determining if an account is dormant.

In all instances this automated processing does not lead to automated decision-making: the outcomes of the automated processing are reviewed by a human being who will make any necessary decisions.


7.

Use of Cookies

If your browser security settings allow it, we will store a cookie on your machine which allows us to automatically log you in when you visit our sites. You can destroy the cookie by logging out of your account.

If you do not wish to have the cookie set, you can uncheck the ‘Remember me’ box in the login form.

If you followed a link to us from another web site, we will also set a cookie to allow us to track which website you came from the first time you visited our site. This is purely to monitor the success of our online marketing. Additionally, when using certain sections of our site, we may temporarily store certain information necessary to the functionality of the software. This information will be destroyed when you close your web browser.

Finally, we use cookies to track how visitors interact with our site. This information is not personally identifiable and is used to help us improve the experience for all of our visitors.


8.

Google Analytics

We use a tool called ‘Google Analytics’ to collect information about use of this site. Google Analytics collects information such as how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this site. We use the information we get from Google Analytics only to improve this site. Google Analytics collects only the IP address assigned to you on the date you visit this site, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this site, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can prevent Google Analytics from recognising you on return visits to this site by disabling cookies on your browser.


9.

Sending your data outside of the European Union

Assetz Exchange (and its service providers) hold your data securely in the UK and EU. We do not, in the normal course of business, transfer your information outside of the EU. Should we ever need to transfer data outside of the EU in the normal course of business we would only do so if the organisation receiving the data had provided adequate safeguards (where your rights would be enforceable and effective legal remedies available following the transfer) or where you had provided informed consent.

In the event that we were forced to share data with an organisation outside of the EU and in a jurisdiction that the European Commission does not regard as having adequate levels of protections for personal data – for example because we were required by law to disclose information – we would seek to ensure that the recipient organisation agreed to protect the data to levels equivalent to ours and seek to put in place appropriate safeguards to ensure that the data was adequately protected. If that was not possible, we would ensure the sharing of the data was lawful.


10.

Your rights explained

In this section we provide a brief overview of your rights in respect of privacy and data protection. In each case, we explain how to exercise your rights in the context of your relationship with us.

10.1

Your right to be informed

You have the right to be informed about the collection and use of your personal data, including:

  • our purposes for processing your personal data.
  • our retention periods for that personal data.
  • who it will be shared with.

This privacy notice provides you with this privacy information in a clear and transparent way.

10.2

You have the right to access your personal data – this is commonly referred to as ‘subject access’. You can make a subject access request verbally, in writing or by e- mail.

Please contact our team at helpdesk@assetzexchange.co.uk.

We may seek confirmation of your identity before proceeding in order to protect your privacy and personal data.

We will not normally charge a fee to deal with a request, although the legislation does allow us to charge a fee to cover administrative costs in circumstances where a request (or a series of requests) is manifestly unfounded or excessive.

When you make a request to us, we normally have one month in which to respond. Please note that this can be extended by a further two months if the request is complex or if we have received a number of requests from you.

10.3

Your right to rectification

You have the right to have inaccurate personal data rectified or completed if it is incomplete. You can make a request for rectification verbally, in writing or by e-mail.

Please contact our team at helpdesk@assetzexchange.co.uk.

We may seek confirmation of your identity before proceeding in order to protect your privacy and personal data.

When we receive a request for rectification, we will take reasonable steps to satisfy ourselves that the data is accurate and will rectify the data if necessary. We will take into account the arguments and evidence which you provide to us.

We will not normally charge a fee to deal with a request, although the legislation does allow us to charge a fee to cover administrative costs in circumstances where a request (or a series of requests) is manifestly unfounded or excessive.

When you make a request to us, we normally have one month in which to respond. Please note that this can be extended by a further two months if the request is complex or if we have received a number of requests from you.

10.4

Your right to erasure

You have the right to have your personal data erased – also known as ‘the right to be forgotten’. Please note, however, that this right is not absolute and there are circumstances in which the right does not apply and erasure is not possible (for example, we cannot erase your data if you still have a relationship with us or if we have a lawful reason to retain your data).

You can make an erasure request verbally, in writing or by e-mail.

Please contact our team at helpdesk@assetzexchange.co.uk.

We may seek confirmation of your identity before proceeding in order to protect your privacy and personal data.

We will not normally charge a fee to deal with a request, although the legislation does allow us to charge a fee to cover administrative costs in circumstances where a request (or a series of requests) is manifestly unfounded or excessive.

When you make a request to us, we normally have one month in which to respond. Please note that this can be extended by a further two months if the request is complex or if we have received a number of requests from you.

10.5

Your right to restrict processing

You have the right to request the restriction or suppression of your personal data. Please note however that this is not an absolute right and only applies in certain circumstances (for example, you may ask us to restrict the use of certain data if you believe that it is inaccurate, and we are considering your request for rectification).

You can make a request to restrict processing verbally, in writing or by e-mail.

Please contact our team at helpdesk@assetzexchange.co.uk.

We may seek confirmation of your identity before proceeding in order to protect your privacy and personal data.

We will not normally charge a fee to deal with a request, although the legislation does allow us to charge a fee to cover administrative costs in circumstances where a request (or a series of requests) is manifestly unfounded or excessive.

When you make a request to us, we normally have one month in which to respond. Please note that this can be extended by a further two months if the request is complex or if we have received a number of requests from you.

10.6

Your right to data portability

You have the right to receive the personal data that you have provided to us in a structured, commonly used and machine-readable format. You can also request that we transmit this data directly to another Data Controller provided this is technically feasible given our systems and theirs.

You can make a request for a portable copy of your data verbally, in writing or by e-mail.

Please contact our team at helpdesk@assetzexchange.co.uk.

We may seek confirmation of your identity before proceeding in order to protect your privacy and personal data.

We will not normally charge a fee to deal with a request, although the legislation does allow us to charge a fee to cover administrative costs in circumstances where a request (or a series of requests) is manifestly unfounded or excessive.

When you make a request to us, we normally have one month in which to respond. Please note that this can be extended by a further two months if the request is complex or if we have received a number of requests from you.

10.7

Your right to object

You have the right to object to the processing of your personal data in certain circumstances.

You can make an objection verbally, in writing or by e-mail.

Please contact our team at helpdesk@assetzexchange.co.uk.

We may seek confirmation of your identity before proceeding in order to protect your privacy and personal data.

We will not normally charge a fee to deal with an objection, although the legislation does allow us to charge a fee to cover administrative costs in circumstances where an objection (or a series of objections) is manifestly unfounded or excessive.

When you make a request to us, we normally have one month in which to respond. Please note that this can be extended by a further two months if the request is complex or if we have received a number of requests from you.


11.

How to contact us

Please see the sections above for details of your rights and how to exercise them.

Assetz Exchange is committed to working with you to resolve fairly any concern or complaint about privacy. Our Data Protection Officer can be contacted at:

The Data Protection Officer
Assetz Exchange
Assetz House
Manchester Green
335 Styal Road
Manchester
M22 5LW

Or helpdesk@assetzexchange.co.uk

If we are unable to resolve your concern or complaint, you have the right to make a complaint to the Information Commissioner’s Office (“ICO”) which is the data protection authority of the United Kingdom. The ICO’s web site can be found at: https://ico.org.uk .


12.

Changes to this policy

We may update or modify this privacy policy from time to time, particularly if subsequent changes to law or regulation require it.

Where changes to this policy will have a material impact on the nature of our processing or a substantial impact on you, or affect your rights, we will give you sufficient advance notice of such changes.