Security

We understand the importance of data security, how we collect personal data from you and how it is managed thereafter. All information that you provide to us, or that is collected about you, is stored on our secured servers. We use safeguards such as firewalls and physical access barriers to ensure that your personal data is protected. Our systems use role based authorisation and authentication where any action made is logged (e.g. to view, edit or delete data of any kind) as an enhanced security measure. Any repayment transactions that take place will be encrypted using secure socket layer (SSL) technology, and all debit card details are encrypted on our system to comply with PCI DSS (Payment Card Industry Data Security Standard) requirements.

Disclosure of your information

Any personal data held about you may be disclosed for the following purposes:

• Personal data will be shared with credit reference agencies to verify your identity, help make our lending decisions, prevent fraud and/or money laundering and to manage accounts once we begin our relationship
• Account information will be shared with credit reference agencies regarding your repayment history and account status
• Personal data may be transferred to a third party, such as a debt collection agency if repayments are not met as outlined on your contract for a prolonged period of time (you will be notified prior to the transfer)
• Personal data may be transferred to law enforcement (such as the police) or other public bodies if there is a legal obligation to do so

Members of staff at Merchant Finance London Limited or appointed representatives (such as a debt collection agency) may be passed your data in order to service your account for the above purposes. Data will only be shared with these recipients on the basis that we have a legitimate interest in which to do so. Personal data may be accessed by members of staff at Merchant Finance London Limited or appointed representatives who operate outside of the EU. Any data processed in this manner will be accessed and used via our secure servers to ensure there is no risk to the confidentiality of your personal data, and any activity is logged to ensure security and accountability. We will not pass on any of your details for marketing purposes, whether internal marketing or externally, unless you actively consent to marketing.

Fair Processing Notice (Fraud Prevention)

GENERAL

• 1. Before we provide services, goods or financing to you, we undertake checks for the purposes of preventing fraud and money laundering, and to verify your identity. These checks require us to process personal data about you.
• 2. The personal data you have provided, we have collected from you, or we have received from third parties will be used to prevent fraud and money laundering, and to verify your identity.
• 3. Details of the personal information that will be processed include, for example: name, address, date of birth, contact details, financial information, your business details, device identifiers including IP address and vehicle details.
• 4. We and fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.
• 5. We process your personal data on the basis that we have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the services or financing you have requested.
• 6. 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 six years.

AUTOMATED DECISIONS

• 7. As part of the processing of your personal data, decisions may be made by automated means. This means we may automatically decide that you pose a fraud or money laundering risk if our processing reveals your behaviour to be consistent with money laundering or known fraudulent conduct, or is inconsistent with your previous submissions, or you appear to have deliberately hidden your true identity. You have rights in relation to automated decision making: if you want to know more please contact us using the details above.

CONSEQUENCES OF PROCESSING

• 8. 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.
• 9. 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 about this, please contact us on the details above.

DATA TRANSFERS

• 10. Whenever fraud prevention agencies transfer your personal data outside of the European Economic Area, they impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the European Economic Area. They may also require the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing.

YOUR RIGHTS

• 11. Your personal data is protected by legal rights, which include your rights to object to our processing of your personal data; request that your personal data is erased or corrected; request access to your personal data.
• 12. For more information or to exercise your data protection rights, please contact us using the contact details above.
• 13. You also have a right to complain to the Information Commissioner’s Office which regulates the processing of personal data.

Complaints regarding use of your personal data

If you are unhappy with the manner that we handle your personal data you can make a complaint directly to us. A copy of our full complaints procedure can be located here, although you can find the contact details to raise a complaint outlined below:

Phone: +44 203 727 2572

Email: complaints@mclfinance.com

Post: 188, Brent Street, London, NW4 1BE

If you remain dissatisfied with the manner that we have handled the complaint you may have the right to refer your complaint to the Financial Ombudsman Service (FOS). More information can be located by reviewing our complaints procedure or by contacting the Financial Ombudsman directly. You can also refer your concerns regarding the handling of personal data to the Information Commissioner’s Office (ICO). You can contact them using the following methods:

Phone: +44 300 123 9123

Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF

Website: https://www.ico.org.uk/

Third party links

Our site may contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own terms of use and privacy policies, and we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites and please note that we are not responsible for the services or representations of third parties.

Information we collect about you

We will collect and process the following data about you from our application form:

• Your full name, date of birth and address
• Contact details including your mobile telephone number, email address and home telephone number
• Financial information including your income and expenditure, residential status, number of dependants, bank details and purpose of the loan
• Business details including your business name and all your business details
• The IP Address used to make the application

Upon completion of the application form we may also request the following data from you: Debit card details or a signed Direct Debit Mandate Updated personal data (such as updated address, updated contact details, updated business details etc.) If you contact us via email, SMS, post of telephonically we may keep a record of the correspondence or conversation. We may also collect data from third party sources, such as social media, credit reference agencies, third party tracing services and debt collections agencies. This data will only be collected and stored if deemed necessary and will not affect your rights. The personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance, or employment. Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights, can be found by accessing the full notice available under the heading “Fair Processing Notice (Fraud Prevention), below.

Legal grounds for processing your information and data retention

The data protection laws allow use of personal data for the purpose of legitimate interests which does not outweigh the interests, rights or freedoms of customers. Any data collected from you will be processed lawfully, fairly and in a transparent manner. The lawful basis for processing the following data is legitimate interests:

• Your full name, date of birth, address, IP Address, and all employment details will be processed for fraud prevention purposes and to assess your affordability. A record of all of this information will be retained for a period of 6 years after the end of our business relationship
• Financial information will be processed to assess your affordability, which will ensure any loan approved is affordable and sustainable for you. A record of all of this information will be retained for a period of 6 years after the end of our business relationship
• Contact details will be processed for customer contactability, whether that be processing the application, verifying information that has been input or collecting repayment arrears. A record of this information will be retained for a period of 6 years after the end of our business relationship
• All of the above data may be transferred to a third party, such as a debt collection agency, if repayments are not met as outlined on your contract for a prolonged period of time (you will be notified prior to the transfer)
• Your bank details will be processed to deposit the funds if your application is successful. A record of all of this information will be retained for a period of 6 years after the end of our business relationship
• Your debit card details will be processed to debit repayments using continuous payment authority . A record of all of this information will be retained for a period of 6 years after the end of our business relationship, although this information will be encrypted

Credit reference agencies (CRA’s) and fraud prevention

When assessing your application, like most companies in commercial credit, we will run a credit check to verify your identity and assess your creditworthiness. Credit reference agencies (CRA’s) have compiled their own privacy notice which we recommend reviewing, titled Credit Reference Agency Information Notice (CRAIN). CRAIN will give you further information about how your data is handled by CRA’s. You can find out more information by visiting https://www.transunion.co.uk/c… If you have any further queries in regards to the above, you are able to contact the three main CRA’s in the UK using the following details:

Transunion, Consumer Services Team, PO Box 491, Leeds, LS3 1WZ or call 0870 060 1414 or log on to transunion.co.uk.

Equifax PLC, Credit File Advice Centre, PO Box 1140, Bradford, BD1 5US or call 0844 335 0550 or log on to equifax.co.uk

Experian, Consumer Help Service, PO Box 8000, Nottingham NG80 7WF or call 0844 481 8000 or log on to experian.co.uk

If you believe that we are reporting inaccurate information regarding your credit activity to any of the above agencies we would urge you to contact us to discuss the inaccuracy.

If you believe that we are reporting inaccurate information regarding your credit activity to any of the above agencies I would urge you to contact us to discuss the inaccuracy. You can send us an email using the address hello@mcl finance.co.uk or contact our office on +44 203 727 2572. More information is available by visiting the section entitled “YOUR RIGHTS”.

Your rights

Under the General Data Protection Regulations you have the following rights regarding the processing of your data:

Right to be informed: We aim to be completely transparent in the manner that we process your data. This privacy policy and our pre-contract information are written to provide a full overview of how we use your data. If you wish to query any aspect of this notice, or you have any questions not addressed in this notice, please email our dedicated mailbox hello@mcl finance.co.uk.

Right to restrict processing: If you believe that any of the personal data that we hold on you, have processed about you, or will process about you is unlawful you can request that we restrict processing while we look at the points you have raised. You can request for the data to be restricted by emailing hello@mcl finance.co.uk. Please include the personal data that you want to be restricted, why you want this data restricted and details that allow us to locate your data (such as full name, reference number etc.) Alternatively, you can request to restrict use of your data by contacting us on +44 20 3727 2572 or writing to us 188, Brent Street, London, NW4 1BE.

If we refuse your request you will be informed of the reason why, and you will be able to raise a complaint to the supervisory authority or to a judicial remedy. More information is available by visiting the section entitled “COMPLAINTS REGARDING THE USE OF PERSONAL DATA”. Right to rectification: If you believe that any of the personal data that we hold on you, or have processed about you (such as credit reference agency data) is inaccurate you have the right to request that we correct the information. You can request for the data to be rectified by emailing hello@mcl finance.co.uk. Please include the specific information that you are disputing, alongside details that allow us to locate your data (such as full name, reference number etc.) Alternatively you can request data rectification by contacting us on +44 20 3727 2572 or writing to us 188, Brent Street, London, NW4 1BE. You can object to the data being processed by emailing hello@mcl finance.co.uk. Please include the specific reason you are objecting to us processing your data, alongside details that allow us to locate your data (such as full name, reference number etc.) Alternatively you can object to use of your data by contacting us on +44 20 3727 2572 or writing to us 188, Brent Street, London, NW4 1BE If we refuse your request you will be informed of the reason why, and you will be able to raise a complaint to the supervisory authority or to a judicial remedy. More information is available by visiting the section entitled “COMPLAINTS REGARDING THE USE OF PERSONAL DATA”. Right to access: Please refer back to the section entitled “ACCESS TO YOUR INFORMATION” which explains your rights to obtain personal data. The following rights will not be applicable if you opt to proceed with your application: Right to erasure: In certain circumstances where personal data is processed you will be able to request that your information is erased. Due to the legitimate interests involved in our processing of your personal data (such as fraud prevention and possible debt recovery), we will be unable to erase any data permanently unless there is an exceptional circumstance in which to do so that overrides the legitimate interests for processing. Right to data portability: Due to the legitimate interests involved in our processing of your personal data we will be unable to transfer your data as outlined by the General Data Protection Regulation. You can contact us by emailing hello@mcl finance.co.uk if you wish to obtain more information regarding the right to data portability, and why it does not apply in this instance. If you are unsatisfied with our explanation you will be able to raise a complaint to the supervisory authority or to a judicial remedy. More information is available by visiting the section entitled “COMPLAINTS REGARDING THE USE OF PERSONAL DATA”.

Contact us

For any additional queries regarding this notice or how we intend to use your data please contact us using the details below:

Phone: +44 203 727 2572

Email: hello@mcl finance.co.uk

Post: 188, Brent Street, London, NW4 1BE