PRIVACY POLICY

General

We observe the highest standards of practice in all our activities and we are committed to protecting all the personal information we collect whether through our website, in person, over the telephone or in any application form you submit to us.

We will treat all your personal information as private and confidential. None of the personal information you provide to us, in any form, will be disclosed to anyone other than as permitted by law or as described below.

This policy sets out how we will process any personal information we collect from you, or that you provide to us, including any information we receive about your employees, customers or suppliers. It is important that you read the following information carefully, together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal information about you, to understand our practices regarding your personal information and how we will treat it.  This privacy policy supplements any other notices and is not intended to override them.

We collect, use and are responsible for certain personal information about you. When we do so we are subject to the UK General Data Protection Regulation in the United Kingdom and any other applicable data protection laws in the United Kingdom.  We are responsible for your personal information as ‘controller’ of that personal information for the purposes of those laws.

Changes to our Privacy Policy

Our privacy policy is regularly reviewed to make sure that we continue to best serve your privacy interests.  We reserve the right to change this policy at any time and we encourage you to periodically review our website (www.ultimatefinance.co.uk) for the latest information on our privacy practices.

Your duty to inform us of changes

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

Who we are

 

Any reference to “we” or “us” means Ultimate Finance Group Limited with company registration number 04350565 and its registered office at First Floor, Equinox North, Great Park Road, Bradley Stoke, Bristol BS32 4QL and its subsidiaries which include:

·       Ultimate Finance Limited	·       Ultimate Bridging Finance Limited
·       Ultimate Asset Finance Limited

Personal information we collect about you

We collect and process different kinds of personal information about individuals including: the directors/members at our clients or prospective clients, clients who may be sole traders or partners of a partnership; our clients or prospective clients’ employees, customers and suppliers; and candidates who apply for a job with us, which we have grouped together as follows:

• Identity Data – including name, right to work in the UK, nationality, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data – including telephone number (home and mobile), home address and email address.
• Employment & Education Data – including employment history, references and education.
• Financial Data – including bank account data, financial records, debt information and credit card information.
• Transaction Data – including details about payments between you and us and details of any products or services we provide to you.
• Technical Data – including 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 – including any usernames and passwords which you create for your service accounts, any preferences you express to us and any feedback you provide to us.
• Usage Data – including information about how you use our website and our products.
• Marketing and Communications Data – including your preferences in receiving marketing from us and our third parties and your communication preferences.
• Device identifiers Data – including vehicle details.

We do not usually collect any Special Categories of personal information, such as information about your health, political beliefs or sexual orientation. We will notify you at the point of collection if we do need any Special Categories of personal information.

Criminal Convictions/Records

We may only process information relating to criminal convictions or criminal records where the law allows us to do so. This will usually be 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 or where the information is publicly available.  We do not conduct DBS checks, however, as part of our pre lending process we do carry out searches with agencies such as Experian and Lexis Nexis to establish creditworthiness and to detect fraud. Such searches may reveal some publicly available information about criminal records or convictions.

If you do not provide the personal information we request

Where we need to collect personal information by law or under the terms of a contract we have with you and you fail to provide that personal information 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 one of our products). In this case, we may have to cancel a product you have with us but we will notify you at the time if this is the case.

How we will collect your information

We collect information about you in a number of ways including through:

• Direct Interactions – You may provide us with Identity, Contact, Employment & Education, Financial, Marketing and Communications Data through any applications you make to us or through communications with us; whether by post, phone, email, through our website or otherwise.  This includes: product applications, creating accounts, filling in contact us forms, providing feedback, job applications, telephone queries or completing surveys.  It also includes ID documents including passports, driving licences and utility bills you provide to us.
• Automated Technologies or Interactions – As you interact with our website we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal information by using server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies or by interacting with us through third party platforms such as Twitter, Facebook, LinkedIn and You Tube.
• Third Parties or Publicly Available Sources – We may receive personal information about you from various third parties and publicly available sources including: (i) Contact, Financial and Transaction Data form sources such as lawyers, accountants, banks, analytics businesses who have access to your Financial Data via the Open Banking initiative, Account Information Service Providers and credit reference agencies based inside the EEA; (ii) Technical Data from analytics providers such as Google based outside the EEA; (iii) Identity and Contact Data from publicly available sources such as Companies House, the Land Registry and the Electoral Register based inside the EEA and (iv) Identity, Contact and Employment & Education Data from recruitment agencies or previous employers.

Cookies

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. For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy https://www.ultimatefinance.co.uk/legals#CookiesPolicy

How and why we will use your information

Under data protection laws we can only use your personal information if we have a proper legal basis for doing so.  Most commonly we will use your personal information in the following circumstances:

• to comply with our legal and regulatory obligations;
• for the performance of our contract with you or to take steps at your request before entering into a contract;
• for our legitimate interests (or those of a third party); or
• where you have given consent.

 

Where we are relying on consent as the legal basis for processing your personal information you have the right to withdraw consent at any time by contacting us at UFG-DataProtection-Mailbox@ultimatefinance.co.uk.

 

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own fundamental rights and interests.

Purposes for which we will use your personal information

We may use the personal information held about you for various purposes and which of the legal bases we rely on to do so are set out in the following table:

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To sign you up as a new customer either online, in person or over the phone	(a) Identity (b) Contact (c) Financial	Performance of a contract with you
To process any service requested by you, deliver a product or service to you and perform any obligations we have in relation to those products or services: (a) Manage payments, fees and charges (b) Collect and recover money owed to us (c) Consider suitable repayment options	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications (f) Special Category	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to manage our business including to recover debts due to us) (c) Consent (d) What is in the substantial public interest
To manage our relationship with you which will include: (a) Notifying you about changes to our terms and conditions or privacy policy (b) To carry out compliance checks such as KYC checks using passports, other ID documents and online tools (c) Asking you to leave a review, provide feedback or take a survey in relation to our products or those of third parties (c) To provide you with information, products or services that you request from us	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Special Category	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) (d) What is in the substantial public interest
To assess your suitability for a role with us and to ensure you are legally entitled to work in the UK	(a) Identity (b) Contact (c) Employment & Education	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to manage our business)
To administer and protect our business (including complying with our legal obligation to prevent money laundering, fraud and other criminal or illegal activity) and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Technical (f) Profile (g) Usage	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation (c) What is in the substantial public interest
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	Necessary for our legitimate interests (to develop our products/services and grow our business)
Assess risk and carry out credit scoring	(a) Identity (b) Contact (c) Financial	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to ensure we are only lending money to customers who are able to repay it and ensuring that third party suppliers and connected parties are financially sound)
Prevent, fraud, money laundering, financial crime and the funding of terrorism	(a) Identity (b) Contact (c) Technical (d) Financial (e) Usage (f) Profile	(a) Necessary to comply with a legal obligation (b) Necessary for our legitimate interests to protect our business (to avoid losses caused by financial crime)
To verify your identity	(a) Identity (b) Contact (c) Technical (d) Financial	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests to protect our business (to avoid losses caused by financial crime)

 

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.

In order to process your application we will supply your personal/business information to credit reference agencies (CRAs) and they will give us information about you/your business, such as financial history. We do this to assess creditworthiness and product suitability, check your identity, manage your account, trace and recover debts and prevent criminal activity.

We will also continue to exchange information about you with CRAs on an ongoing basis, including about your settled accounts and any debts not fully repaid on time. CRAs will share your information with other organisations. Your data will also be linked to the data of your spouse, any joint applicants or other financial associates.

The identities of the CRAs, and the ways in which they use and share personal information, are explained in more detail at www.experian.co.uk/crain

Marketing

We strive to provide you with choices regarding certain personal information uses, particularly around marketing and advertising.

Marketing from us

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 products, 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 or purchased products from us and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We do not share your personal information with any company outside the Ultimate Finance Group for marketing purposes but if we decide to do so in the future we will get your express opt-in consent.

Opting out

If you do not want to receive marketing communications from us please submit a request to unsubscribe by (a) emailing communications@ultimatefinance.co.uk or (b) clicking on the unsubscribe link in the next marketing email you receive from us. Once you unsubscribe you will not receive any further marketing communications from us. You will continue to receive communications from us via email if it relates directly to a service or product we provide to you.

Who we may share your personal information with

We may disclose your information to the following third parties:

• Other members of Ultimate Finance Group, all of which are located in the United Kingdom.
• Credit reference or fraud prevention agencies (including Cifas) within the EEA to:
  • undertake a search in order to verify your identity (and a record of this search will be retained);
  • check the details and information you have supplied to us against any database, public or otherwise;
  • assist other companies with verification and identification;
  • to identify, investigate and prevent fraud, money laundering and other criminal activity (and 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, please contact UFG-DataProtection-Mailbox@ultimatefinance.co.uk );
  • to comply with our obligations to the relevant agency by exchanging information about you, which will include your repayment history;
  • to protect our business; and
  • to comply with laws.

You should be aware that if fraud is detected, you could be refused certain services, finance, or employment.  Further details of how your information will be used by these fraud prevention agencies, and your data protection rights, can be found by accessing the full Fair Process Notice at www.cifas.org.uk/fpn .

 

We use Experian as our preferred credit reference agency.  They have prepared a Credit Reference Agency Information Notice which explains how they obtain, process and share personal data about consumers and businesses. You can find a copy of their CRAIN notice here: https://www.experian.co.uk/legal/crain/.

Please note that credit reference or fraud prevention agencies may transfer your personal data outside of the UK. This may be 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.

• Law enforcement agencies within the EEA (please note the fraud prevention agencies we use may also disclose your information to law enforcement agencies) to enable them to access and use your personal information to detect, investigate and prevent crime.
• Other financial services companies within the EEA (to help prevent, detect and prosecute unlawful acts and fraudulent behaviour).
• the Secretary of State for Business, Energy and Industrial Strategy its agents and auditors;

the British Business Bank plc, any affiliate of the British Business Bank plc and any of their advisers, agents or contractors including professional advisers and consultants, auditors and advisers carrying our due diligence; processing agents, fund managers, delivery partners and companies providing services to the British Business Bank and its affiliates; and Government departments and Devolved Administrations (including but not limited to the National Audit Office, Office for National Statistics, HM Treasury and the Department for Business, Energy and Industrial Strategy) and other politicians or government members (i.e. ministers).

• Third party service providers including IT service providers based both inside and outside the UK
• Our bankers in order to comply with their regulatory and legal obligations and to provide financing to the Ultimate Finance Group.
• Our professional advisors including our lawyers, auditors, accountants and consultants so that they can provide services to us and/or advise us accurately in relation to any agreement we may have with a client. Our current external auditors are RSM Audit LLP and a copy of their privacy policy is available here: https://www.rsmuk.com/privacy-and-cookies.
• If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, to establish or defend any legal claims or to enforce any terms of any contracts entered into between you and us.
• In the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets.
• Third party service providers who assist us with establishing and managing our employment relationship with you, including managing payroll services, our pension scheme operators and life, private medical and private health insurance companies.
• Where you have confirmed to us that you are happy for us to do so.

Transfer of information

We may transfer your personal information abroad to other countries outside of the UK.  If we so do we will ensure that a similar degree of protection is afforded to your information, including where we use certain service providers, we will use specific contractual clauses approved by the European Commission and the UK Government which give personal information the same protection it has in Europe.

Your rights in relation to your personal information

Inform us of changes

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

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.

If you want more information or want to review, verify, correct or request erasure of your personal information, object to the processing of your personal information, or request that we transfer a copy of your personal information to another party, please contact UFG-DataProtection-Mailbox@ultimatefinance.co.uk.

 

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is unfounded or excessive. Alternatively, we may refuse to comply with the request in such 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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact UFG-DataProtection-Mailbox@ultimatefinance.co.uk. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Data security

We have put in place measures to protect the security of your information. Details of these measures are available upon request.

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

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

Data Retention

We will only retain your personal information 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. Details of retention periods for different aspects of your personal information are available in our retention schedule which is available from UFG-DataProtection-Mailbox@ultimatefinance.co.uk.   To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer a customer we will retain and securely destroy your personal information in accordance with our data retention policy.

Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to 6 years.

Candidates who apply for a job with us

If your application is successful and you become an employee you will be provided with a copy of our Employee Privacy Policy which will provide you with further information on data protection as an employee.

If you send us your CV but your application is unsuccessful you consent to us keeping a copy of it in our records for 6 months so that we can consider you should another role become available which we feel may be suitable for you. Your CV will be permanently deleted after 6 months. If you would rather we did not do this please do let us know when you submit your CV to us.

Need to speak to us?

We hope that we can resolve any query or concern you may raise about our use of your information. If you have any questions about the contents of this privacy policy or have a concern you would like to discuss, you can email us at UFG-DataProtection-Mailbox@ultimatefinance.co.uk

You also have the right to lodge a complaint with a supervisory authority. The supervisory authority in the UK is the Information Commissioner’s Office whose contact details can be found on the website: https://ico.org.uk.

This privacy policy was last updated in [August] 2021.