The personal information that we may collect about you broadly falls into the following categories:

Information that you provide voluntarily

You may be asked to provide personal information voluntarily: In order to communicate with a borrower, guarantor, security provider, client, a potential client, associate, or other relevant person such as a beneficial owner or authorised representative we may ask for information, including:

• personal details such as your name, date of birth, current postal address;
• personal contact details such as your phone number and email address;
• Business contact details.

As part of the application process for a loan or other financial product we will ask for information, including:

• personal details such as your name, date of birth, current and previous address;
• personal contact details such as your phone number and email address;
• copies of your passport, driving licence, national insurance number or other proof of identity;
• your business name and contact information;
• financial information (including bank or building society account details and details of debit cards used to make payment to us, your accounts, sales records, previous credit applications and the conduct of your accounts and other management information concerning the performance of your business);
• information about your directors, partners, members, shareholders, beneficial owners and guarantors;
• information about your family members, dependants and associates;
• information about the nature of your business and the assets you hold and any other financial indebtedness or security that you have entered into with third parties;
• source of wealth and source of funds;
• credit reference checks;
• electoral register information;
• fraud prevention information (including personal data relating to political affiliations and criminal convictions); and
• passwords and answers to security questions.

We may also keep copies of our correspondence with you.

The personal information that you are asked to provide, and the reasons why you are asked to provide it will be made clear to you at the point we ask you to provide your personal information, but include:

• informing you of changes to our products and services;
• developing and improving our services, products and business, including analysing and improving our credit risk models and our customer service offering;
• ascertaining borrowing needs;
• assessing creditworthiness and making credit-related decisions;
• if any loan repayment or repayment of any other financial product provided by us is missed, tracing your whereabouts and recovering debts or enforcing a loan contract, security interest or personal guarantee and to verify any payment plan proposed or income and expenditure form submitted;
• transferring money;
• carrying out mandatory or other regulatory checks;
• complying with our legal and regulatory obligations;
• carrying out statistical analysis and market research and testing;
• contacting you (including by SMS and e-mail) with products and services which we think may interest you (at all times taking into consideration your rights at law including your right to opt-out from receiving marketing from us);
• verifying your identity and the other information you have provided to us, including your bank account information and (if relevant) the identity of your business associates;
• updating the records we hold about you from time to time; and
• for the prevention and detection of fraud, money laundering, or other illegal or criminal activity.

Information that we collect automatically

When you visit our Website, we may collect certain information automatically from your device. In the UK, this information may be considered personal information under applicable data protection laws.

Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Website, including the pages accessed and links clicked.

Collecting this information enables us to better understand the visitors who come to our Website, where they come from, and what content on our Website is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Website to our visitors.

Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading “Cookies and similar tracking technology” below.

Information that we obtain from third party sources

When we accept you as a client or are considering an application for a borrower, guarantor, security provider, client or associate, we may collect further information about you from third party sources (including credit reference agencies, fraud prevention agencies, insurers, debt brokers and other similar intermediaries, public information sources such as Companies House or Government or law enforcement agencies or information from social media sites which is relevant to your professional activities) but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us.

The types of information we collect from third parties may vary depending on the service we are offering.. They may include your credit and insurance history, and information to verify your identity. We use the information we receive from these third parties to maintain and improve the accuracy of the records we hold about you, to ensure that the products we offer are suitable, and to prevent fraud and money-laundering

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We may disclose your personal information to the following categories of recipients:

• to our group companies, third party services providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Website), or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information.
• to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
• to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, including the transfer or sale of any loan or other financial product, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice;
• (if we are unable to provide a loan or other financial product and if you consent), to third parties who may be in a position to arrange credit;
• to any other person with your consent to the disclosure.

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our business and communicating with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our business, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.

Where we process special category personal information or personal information relating to criminal convictions, additional legal bases for processing are required. These include: (i) where processing is necessary for the purposes of the prevention or detecting of an unlawful act; or (ii) where the processing is necessary for the purposes of complying with, or assisting other persons to comply with a regulatory requirement.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “How to contact us” heading below.

We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use personal information about you. For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookie Notice.

We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information.

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We aim to keep your data in the UK and the European Economic Area. In some situations your personal information may be transferred to and processed in countries outside the UK or the European Economic Area by our third party service providers and partners. It is important to us to protect your personal information. We therefore take all appropriate legal, technical and organisational measures to ensure that your personal information is kept safe. We ensure that appropriate security measures are taken which are comparable to and of the same standard as the protections afforded to individuals in the UK and the European Economic Area.

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

In some instances, our use of your personal information may result in automated decisions being taken (including profiling) that legally affect you or similarly significantly affect you. For example, we may use your personal information to evaluate certain aspects relating to you, such as analysing or predicting matters such as your financial position or reliability. This is done on the basis of our legitimate interest in ensuring that the financial product we provide is suitable and that we are aware of any relevant risks. You have the right to object to such processing, as set out below.

You have the following data protection rights:

• If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the “How to contact us” heading below [link].
• In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below [link].
• You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “How to contact us” heading below [link].
• Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
• You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make.

You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.

If you have any questions or concerns about our use of your personal information, please contact us using the following details: dpo@aroskapital.co.uk or by post at DPO, Third Floor, 8 Pollen Street, W1S 1NG, London

The data controller of your personal information is Aros Kapital Limited.