Privacy Policy

This Privacy Policy (the “Policy”) has been prepared by Equiflux Capital Group (the “Company”) to meet the requirements of the UK’s Data Protection Act 1998 and the General Data Protection Regulation (GDPR) and it only relates to the collection, protection, disclosure and use of personal data belonging to living individuals. The Policy is applicable to all services provided by the Company and does not relate to data which emanates from companies or other entities, although the general principles regarding our collection and use of data is broadly the same irrespective of whoever is the user of our website, or our customers.

This Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. We gather various types of information from our users, as explained in detail below, and we use this information in connection with our services, including to personalise, provide and improve our services, to fulfill your requests for certain products and services and in some cases, to analyse how you use those services.

(a) The terms set out in this policy apply to any information you give Equiflux Capital Group from time to time and to any information you have already provided.

(b) We may update our policies from time to time for any of the following reasons:

• to provide for the introduction of new or improved systems, methods of operation, services or facilities; to reflect an actual or expected change in market conditions or general banking practice;
• to comply with or anticipate any changes in any legal or regulatory requirement;
• to ensure that our business is run prudently;
• to make our policies clearer or more favourable to you; or to rectify any outdated information
If you do not wish to accept the new Privacy & Cookies policy, you should contact us immediately. Otherwise your continued use of Equiflux Capital Group services shall indicate your acceptance of the updated policy.

(c) You must not send us personal information about someone else without first getting the individual’s consent for it to be used and disclosed in the ways set out in our Data Protection Statement. If you give us information (including personal information) on behalf of someone else, you confirm that the other person has given you permission to act on their behalf and has agreed that you can:

• provide their personal information to Equiflux Capital Group;
• give consent on their behalf to the processing of their personal data;
• receive on their behalf any data protection notices; and
• give consent to the transfer of the individual’s personal data abroad should this be required

Where you provide information about someone else, or someone else discloses a connection with you, that information may be taken into account along with your other personal information when assessing your application to receive our products or services.

(d) We treat your privacy very seriously and we understand that you will wish to know how we will use the information we collect from or about you. We use your personal information in accordance with our Data Protection Statement and will fully comply with all applicable UK data protection legislation (including the EU General Data Protection Regulation as amended or replaced). It is important that you take all necessary and appropriate steps to protect your data yourself (for example, by ensuring that all passwords and access codes are kept secure).

Please read the following carefully to understand our views and practices regarding your personal data.

We may collect and process the following personal information about you:

a) Information you provide (either directly or through an agent such as a solicitor, independent financial advisor or introducer) by completing an application for our products and services, whether in writing, via our website, over the telephone or by any other means. This information may include your name, address, contact details, date of birth, bank details, details about your employment and financial information and may extend to copies of identification documents (such as passport, driving licence and/or utility bills).

b) Other personal data supplied by you when you contact us by other means (such as by email or telephone), and records of any correspondence from you or anyone acting on your behalf.

c) Personal details provided via our website (for example, via the Application form). We process data that you provide to us when you complete our online form (such information may include, but may not be limited to, your name, telephone number, postal address and email address).

d) Details of transactions you carry out with us.

e) Your credit history, Credit report data, Mortgage balance, other loans, Default payments, Missed payment history, other credit searches where you have applied for credit or where we have agreed to provide credit to you.

f) Monthly company revenue, Business type, Business sector, Business bank & business bank statements

g) Communications you send to us (by telephone, email or otherwise), for example, to report a problem or to submit queries, concerns or comments regarding the Website, our service, or general comments

h) Surveys that we use for research purposes, which we have asked you to complete, although you do not have to respond to them

a) We may process, transfer and disclose your information for the purposes of:

• providing you with services, managing your accounts and complying with your instructions;
• verifying your identity;
• making credit decisions, where you have applied for credit or where we have agreed to provide credit to you;
• To detect, prevent and investigate potential or actual fraud and related activities;
• complying with laws and regulations (including the rules of any regulatory authority) and public duties;
• monitoring and/or recording your telephone calls and other electronic transactions in order to accurately carry out your instructions; assisting in improving our services and in the interests of security and crime prevention;
• market research and providing you with information via post, email, telephone or other means about Equiflux Capital Group’s products or services from time to time
• We may use your personal data to analyse how you are using our service and to gain insights into how we can improve our products and services.

b) Where you have applied for credit or where we have agreed to provide credit to you, we may from time to time make searches of your record at a credit reference agency (‘CRA’). You hereby consent to the processing of your personal data in this manner and confirm that you have obtained specific authority from the partners/co- directors of your business to give consent on their behalf to their personal information being processed in this manner. If the beneficial owners of your business are not the partners or directors of your business, you hereby confirm that you have notified the beneficial owners that we will also conduct due diligence checks on them to prevent fraud and money laundering. CRAs will supply to us both public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information.

c) We use your personal data on the following legal bases, depending on the purpose of our processing:

• to enable us to perform the contract between you and us (if you have entered into a contract with us for products or services);
• your consent;
• to fulfil your requests for certain products and services;
• otherwise in our legitimate interests (for example, to make available the website to you); or
• to comply with a legal obligation.

Under Article 6 of the EU General Data Protection Regulation (GDPR) we are required to tell you about the legal basis under which we collect and process your data. Therefore, we will only collect and process your personal data in accordance with one of the below lawful bases:

a) Performance of a contract:
This is where the processing is necessary for a contract we have with you, or you have asked us to take specific steps before entering into a contract, such as providing you with a quote. This lawful basis covers the following purposes:

b) Our legitimate interests:
This is where we collect and process data in accordance with our “legitimate interests”. Our legitimate interests include:
• Improving our service
• Providing you with marketing information about our services
• Providing you with customer support and administering your account
• Providing you with information about related products and services offered by Equiflux Capital Group
• Providing you with information about related products and services offered by our commercial partners

c) Consent:
You may be given the option to explicitly consent to share your data with selected third parties for marketing purposes or to sign up for related products and services. This will be via a separate notice via the website. We will never assume that we have your consent unless you have explicitly opted in, and you can withdraw your consent at any time by contacting us.

d) Compliance with our legal obligations:
We may be required to process or share your personal data in compliance with a legal obligation, such as in response to a request by law enforcement or when investigating a civil claim.

We will not retain your personal data for longer than is necessary for the purposes for which the personal data is processed. This means that your information will only be held for as long as we need to process it to provide you with services, is necessary for legal reasons or in accordance with our legitimate interests, and in accordance with UK data protection laws.

When calculating the appropriate retention period for your data, we consider the nature and sensitivity of the data, the purposes for which we are processing the data, and any applicable statutory retention periods. Using these criteria, we regularly review the personal data which we hold and the purposes for which it is held and processed.

When we determine that personal data can no longer be retained or where you request us to delete your data in accordance with your right to do so, we ensure that this data is securely deleted or destroyed.

We may find it necessary to transfer your personal information outside the European Economic Area (which currently comprises the Member states of the European Union plus Norway, Iceland and Liechtenstein), where any of Our Partners are either based outside the EEA, or where they use data processors based outside the EEA. Where this is the case, we have in place data-transfer agreements, which incorporate certain standard model protection clauses. We will take all necessary steps in order to ensure that the correct security measures are taken, and that your personal data is treated securely and in accordance with this Privacy Policy.

Subject to exceptions, you have a right to access personal data that is held about you. To obtain a copy of the personal information we hold, you should write to the Head of Data at Equiflux Capital Group. We will respond to you within thirty days of receipt of the request. You may also request from us details of the credit reference agencies and fraud prevention agencies with which we may have carried out searches.

If there are any inaccuracies in the information we hold about you, please notify us of this in order that we may correct the information we hold about you. Under the GDPR, or any equivalent rules in the UK, you may be entitled to additional rights in relation to our handling of your personal data. For example, the right to have your personal data erased, the right to object to or restrict us from processing your personal data, and the right to data portability. If you would like to exercise these rights once they come into force, please contact the Head of Data.

Right to access
You have the right to request a copy of the personal data we hold under the GDPR by making a “subject access request” to us in writing. We will comply with all valid subject access requests within 30 days, unless the request is particularly complex; in this case we will contact you within 30 days with further information. You will not be charged for making a subject access request unless we reasonably deem this to be a manifestly unfounded or excessive request, in which instance you will be charged a reasonable fee based on the administrative costs of providing the information.

Right to rectification
If some of the personal data we hold is inaccurate or incomplete, you can request that we rectify our records by writing to us. We will comply with all requests within 30 days unless the request is particularly complex; in this case we will contact you within 30 days with further information.

Right to erasure
You have the right to request that we delete your personal information from our records. Please note that we will not be able to delete your personal information whilst we are still providing our services to you. We will be able to delete your personal information once you cancel the service or once the service is completed.

Right to restrict processing
You have the right to restrict the processing of your personal data in certain circumstances, such as when you object to us using your data in accordance with our legitimate interests or when you contest the accuracy of the data we hold on you.

Right to object
You have the right to object to the collection and use of your personal information at any time however, this could impact your application process.

Right to data portability
You have the right to obtain a copy of your personal information in a legible and compatible format such as Excel or Word. You have the right to “portability” of your personal data that we have collected with your consent or in performance of a contract that is used in automated decision-making. This means that you can request copies of all the personal data we hold for this purpose in a structured, commonly used, and machine readable form, and we will supply this to you free of charge on request. We will respond to these requests within one month, unless the request is particularly complex, in which case we will inform you of how long it will take as soon as possible.

Right to be informed
You have the right to be informed over what personal data we hold and how we are using it. This information is contained within this privacy notice.

If you feel that we have not been complying with our obligations on data protection law or you wish to assert one of your rights, please contact us without delay using the contact details provided below.

If you have any concerns, questions or requests regarding this Policy, then please send an email to: admin@equifluxcapital.com.