- IMPORTANT INFORMATION & WHO WE ARE
- THE DATA WE COLLECT ABOUT YOU
- HOW IS YOUR PERSONAL DATA COLLECTED?
- HOW WE MAY USE YOUR INFORMATION
- DISCLOSURES OF YOUR PERSONAL DATA
- INTERNATIONAL TRANSFERS
- DATA RETENTION
- DATA SECURITY
- YOUR LEGAL RIGHTS
- HOW TO CONTACT US
IMPORTANT INFORMATION & WHO WE ARE
Who we are
BizBritain is a group of companies, which includes BizBritain Finance; an FCA authorised financial brokerage and national delivery partner for the Government’s Start Up Loans Scheme. The Company is registered in England with company number 08354773, whose registered office is 96 High Street, Marlow, Buckinghamshire, SL7 1AQ.
For the purposes of data protection legislation, we may be the data controller of your personal data or data processor. We are registered with the Information Commissioners Office in the UK with reference number ZA062551.
About this policy
When you use our services, you’ll share some information with us. We want to be clear about the personal information we collect, how we use it, who we share it with and the choices we give you to control, access and update your information. ‘Personal information' is data that relates to you and that identifies or can be used to identify you – this might be your name, email address, or other digital identifiers relating to you, such as cookies, IP addresses or logs. Sensitive personal data can include your gender and ethnicity.
Third Party Links
Our website and other documents you receive from us may include links to third-party websites, plug-ins and information. Following these links 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 notices.
Changes to this privacy notice and your duty to inform us of changes
This version was last updated in June 2020. Any updates to this Privacy Notice will be published on the BizBritain website.
Please keep us informed if your personal data changes during your relationship with us as it’s important that the personal data we hold about you is accurate.
You also 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. Go to ico.org.uk/concerns to find out more. We would, however, like to deal with any concerns you may have before you approach the ICO so please contact us in the first instance.
- Who we are
THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, 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 as follows:
- Identity Data
Includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, place of birth, age, image, nationality, national insurance number and gender.
- Contact Data
Includes home address, billing address, delivery address, email address and telephone numbers.
- Payment Data
Includes bank account, payment card details and details about payments to and from you, and other details of products and services you have purchased from us.
- Financial Status Data
Includes financial position, benefits received, information taken from identification documents such as your passport or driving licence, credit status, housing status, mortgage outstanding, your insurance, criminal and medical history, and details about additional insured parties and cardholders or joint policyholders.
- Employment & Educational Data
Includes job title, qualifications, employment status, directorships, business interests, CV information, employment records and salary.
- Technical Data
Includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile Data
Includes your username and password, purchases or orders made by you, your interests,preferences, feedback and survey responses.
- Usage Data
Includes information about how you use our website, products and services.
- Marketing and Communications Data
Includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Special Categories of Personal Data
Includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, information about your health.
- Criminal Conviction Data
Includes information about criminal convictions and offences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. 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.
- Identity Data
Our services are not intended for and may not be used by individuals under the age of 18. We do not knowingly collect personal data from Minors or allow them to register. If it comes to our attention that we have collected personal data from a Minor, we may delete this information without notice. If you have reason to believe that this has occurred, please contact us.
- Personal Data
HOW IS YOUR PERSONAL DATA COLLECTED?
We use the following ways to collect data from and about you:
You may give us your Identity, Contact, Employment & Educational, Financial Status, Payment, Special Category, Criminal Conviction, Profile, and Marketing & Communications data in person. This may be by filling in forms on paper, online or electronically, by corresponding with us by post, phone, email or otherwise, face-to-face, or providing information as part of a contract.
This includes personal data you provide when you:
- apply for our services;
- create an account on our website;
- submit information via our website or other web form;
- apply to provide goods and/or services to us;
- telephone us where calls are recorded for complaint handling, monitoring and training;
- subscribe our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey;
- give us some feedback or evaluate our services.
Automated technologies or interactions
Third parties or publicly available sources
We may receive personal data about you from various third parties and public sources as follows:
- Identity, Contact, Payment and Financial Status Data from data brokers or aggregators, including credit reference and fraud prevention agencies.
- Identity, Contact, Special Category, Employment & Educational, Marketing & Communications and Technical Data from third party partners, including those who fund, licence and co-deliver our activities and those who refer clients to us. Examples include government bodies like the Start Up Loans Company, non-departmental public bodies, private companies, membership organisations and external consultants.
- Identity, Employment & Educational, Financial Status and Contact Data from publicly availably sources like Companies House, and the Electoral Register.
- Technical Data from analytics providers and advertising networks.
- Identity, Contact, Profile, Usage, Marketing & Communications, Employment & Educational, Payment and Financial Status Data from third party website portals into which you have entered your personal data.
- Direct interactions
HOW WE MAY USE YOUR INFORMATION
We will only process or share your personal data when the law allows us to and most commonly under the following lawful bases:
Processing is necessary for a contract you have or because you have asked us to take specific steps before entering into a contract with ourselves or a third party. For example, in a finance enquiry/application.
Where processing is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where processing is necessary to comply with the law or our regulatory obligations, to prevent illegal activity or to protect our interests.
Where you give us consent to process your data for direct marketing communications. You have the right to withdraw consent to marketing at any time by Contacting us.
More information about the lawful basis we use are found in the Glossary at the end of this document.
Purposes for which we will use your personal data
We have set out below, in a table format, 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. 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.
Purpose/Activity Type of data that may be used Lawful basis for processing including basis of legitimate interest To register you as a new customer or supplier a) Identity
d) Financial Status
e) Employment & Educational
a) Performance of a contract with you
b) Necessary for our legitimate interests in developing our relationship with you as a potential client
To deliver agreed services including
i) to prepare and deliver our services to you
ii) to prepare you for and enable the delivery of external services
iii) for complaint handling or to meet our legal obligations e.g. phone recordings
e) Financial Status
h) Marketing & Communications
i) Special Category Data*
j) Criminal Conviction Data*
a) Performance of a contract with you
b) Necessary for our legitimate interests in:
i) delivering a service we offer
ii) tracking and reporting on contract progress
To manage our relationship with you which will include:
- Managing youraccount and providing services support
- Notifying you about changes to our terms or privacy notice
- Asking you to leave a review or take a survey
d) Marketing & Communications
a) Performance of a contract with you
b) Necessary to comply with a legal obligation
c) Necessary for our legitimate interests in
keeping our records updated and studying how customers use our products/services
To manage consultancy or advisory services you provide to us or our clients a) Identity
c) Financial Status
e) Financial Status
a) Performance of a contract with you To use data analytics to measure and report on the performance of our services a) Identity
a) Performance of a contract with you To administer our day-to-day business operations, including
i) enabling you to access our
facilities and/or services,
our legal obligations in carrying out our business,
iii) assessing applications to deliver services to us, and
iv) appointing oversight bodies to govern and advise on our activities
d) Financial Status
a) Performance of a contract with you
b) Necessary for our legitimate interests in ensuring our business functions are cost-effective, compliant and accessible
c) legal obligations
To enable you to take part in a prize draw, competition or complete a survey a) Identity
e) Marketing & Communications
a) Performance of a contract with you
b) Necessary for our legitimate interests in studying how customers use our products/services, to develop them and grow our business
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data), including measure or understand the effectiveness of our website and products / service a) Identity
e) Marketing & Communications
a) Necessary to comply with a legal obligation
b) Necessary for our legitimate interests
i) in running our business, providing administration and IT services, ensuring network security, preventing fraud and in the context of a business reorganisation or group restructuring exercise,
ii) instudying how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy
To make suggestions and recommendations to you about goods, services, opportunities or events that may be of interest to you a) Identity
f) Marketing & Communications
a) Necessary for our legitimate interests in developing our products/services and growing our business
b) Your consent, where this is required by law
*Where Special Category or Criminal Conviction Data is used, this currently only processed for Equality Monitoring purposes in the Start Up Loan scheme.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
PROMOTIONAL OFFERS FROM US
You will receive marketing communications from us if you have requested information from us or if we can demonstrate that we have a legitimate interest in sending marketing material to you (and you have not opted-out).
We will get your express opt-in consent before we share your personal data with any company outside BizBritain group for marketing purposes, for example Start Up Loan Companies corporate partners if you apply for a loan.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt out links on any marketing message sent to you or by Contacting us at any time at firstname.lastname@example.org
Where you opt out of receiving marketing messages, this will not apply to personal data provided to us and communications which we need in order to supply our services to you.
- PROMOTIONAL OFFERS FROM 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.
DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table above. These can include:
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
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. We will always work with them to protect your privacy.
In some circumstances we transfer data to, and store data in, countries which are outside the EEA. The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway.
If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA. Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice. Whenever we transfer your personal data out of the EEA, 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 by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
We will retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by Contacting us. In some circumstances you can ask us to delete your data: see Request erasure below for further information.
We will keep records of any personal data, agreements you enter into with us, or services/products you receive for up to six years, save to the extent that we are required to hold records for a longer period in order to comply with an overriding legal obligation. This is so that we can comply with our legal and regulatory obligations and respond to any complaints or disputes that may arise in that period. Such legal/regulatory obligations include our reporting obligations to the Financial Conduct Authority and HM Revenue & Customs, as well as our obligations under applicable legislation including the Money Laundering Regulations, Bribery Act 2010 and the Modern Slavery Act 2015.
In some circumstances we may 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.
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.
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.
YOUR LEGAL RIGHTS
Under the General Data Protection Regulation, you have a number of important rights available to you for free:
- Request access to your personal data (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 data we hold about you corrected, though we may need to verify the accuracy of the new 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 information unlawfully or where we are required to erase your personal data to comply with local law.
Please note, we may not always be able to comply with your request of erasure for specific legal and regulatory reasons which will be notified to you, if applicable, at the time of your request. Please see section 7 about Data Retention for more information.
- Object to processing of your personal data, including automated decision making.
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 may object to the processing of your data. 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 information 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 data’s accuracy;
- where our use of the data is unlawful but you do not want us to erase it;
- where you need us to hold the 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 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 information which you initially provided consent for us to use or where we used the information 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please at email@example.com
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 may refuse to comply with your request in these circumstances.
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.
We try to respond to all legitimate requests within one month. Occasionally it may 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.
For further information on each of these rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individual’s rights under the General Data Protection Regulation.
HOW TO CONTACT US
If you wish to contact us please send an email to the BizBritain Data Protection Officer at firstname.lastname@example.org or via post c/o BizBritain, 96 High Street, Marlow, Buckinghamshire, SL7 1AQ.
Means the interest of our business in conducting and managing our business to enable us to give you the best services/products and the best and most secure experience. 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).
Performance of Contract
Means processing your 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. This includes completing a Financial application to approval before entering into a finance contract with a partner.
Comply with a legal or regulatory obligation
Means processing your personal data where it is necessary for compliance with a legal or regulatory obligation to which we are subject.
Means any freely given, specific, informed and unambiguous indication of your wishes by which you, by a statement or by a clear affirmative action, signify agreement to the processing of personal data.
- Legitimate Interest
- Third Parties
Internal Third Parties
Other companies in BizBritain group acting as joint controllers or processors and who are based in the United Kingdom and provide corporate services including IT and system administration, HR, Marketing and Financial services and undertake management reporting. Information will also be shared within the group for marketing purposes where either you have consented for us to do so or where we are legally otherwise able to share this information. This is in order that we can provide a high quality service across our group and can provide you with advice about our services that are relevant to your interests.
External Third Parties
We may transfer your personal information to our partners, suppliers, insurers and agencies, but only where they meet our standards of data and security. We only share information which allows us to provide their services to us or facilitate them providing our services to you. Examples include:
- Funding partners and licensing bodies who require information in relation to the services that we provide e.g Start Up Loans Company, GC Business Finance
- Contractors, consultants and other advisors who deliver services as a subcontractor or on our behalf.
- Credit check and fraud prevention agencies.
- Service providers who provide professional services to us and those who provide IT and other system Administration, data storage and/or management services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers who require reporting of, or access to, processing activities in certain circumstances.
We won’t ever rent or sell our user’s details to any other organisation or individual.
- Internal Third Parties
- Lawful basis