Robert Owen Community Banking Fund Ltd & Start Up Loans Company Privacy Notice

1. PRIVACY NOTICE

Who is Responsible for Your Personal Data?

1.1 Start-Up Loans Company, a company registered in England with company number 08117656, whose registered office is 60 Grosvenor Street, London W1K 3HZ (“SULC”) is responsible for your personal data and will comply with the Data Protection Act 1998 (“DPA”) in respect of your personal data. Please refer to SULC’s Privacy Policy (available on request) for details of how SULC may process your personal data.

1.2 SULC has appointed us, Robert Owen Community Banking Fund Ltd, a company registered in England with company number 05832750, whose registered office is Unit H, The Vastre Enterprise Park, Newtown, Powys, SY16 1DZ and has and may appoint certain other service providers to process your personal data on SULC’s behalf in connection with the services SULC provides and/or that we will provide to you on behalf of SULC.

1.3 In some cases we may also appoint an organisation or individual to provide you with guidance in relation to the services that you will receive from us (“Mentor”). If a Mentor is appointed the Mentor will also process your personal data on behalf of SULC. You will enter into an agreement directly with any such Mentor, however the provisions of this Privacy Notice will also apply to the processing of your personal data by the Mentor.

What Information is Collected About You and How is it Collected?

1.4 We and/or any Mentor on behalf of SULC, and/or SULC and its agents, may collect personal information about you (including your name, address, telephone number(s) (fixed line and mobile), email address, age, gender, ethnicity and details of your existing financial commitments and any other information that is required to assess or review lending risks, to recover debts, or to prevent or detect fraud) from you, from each other and from third parties, including SULC’s finance partners (StreetUK), credit reference agencies and your current and/or previous employers (with your consent).

1.5 This will include information you provide when you apply to us, and any additional information provided by you or others in various ways, including: in applications, emails and letters, during telephone calls and conversations, when registering for services, in customer surveys, when you participate in competitions and promotions, through our or the SULC website and during financial reviews and interviews and from analysis (for example, the amount, frequency, and origin) of your payments.

How Will Your Personal Data be Used?

1.6 We and/or any Mentor on behalf of SULC, and/or SULC and its finance partners (StreetUK) and other service providers, will only use your personal data to:
1.6.1 communicate with you by mail, telephone, email, text (SMS) message or other electronic means;
1.6.2 assess lending and insurance risks and/or obtain a credit reference;
1.6.3 manage our or their relationship with you;
1.6.4 update, consolidate, and improve the accuracy of our records;
1.6.5 provide services to you on behalf of SULC, which may include a loan and/or business support and/or mentoring services and dealing with your inquiries and requests;
1.6.6 make a decision about the payment methods or other arrangements we offer you on behalf of SULC and/or administer any loan provided to you and any payments relating to it;
1.6.7 undertake financial reviews;
1.6.8 test new systems and check upgrades to existing systems;
1.6.9 help SULC improve its products and services (including through the use of customer modelling, statistical and trend analysis), for quality control, security, internal record keeping and other business needs and/or to notify you about changes to SULC’s services;
1.6.10 undertake transactional analysis, evaluate the effectiveness of marketing and for market research and training;
1.6.11 comply with our, any Mentor’s and/or SULC’s obligations under applicable law, to exercise our, any Mentor’s or SULC’s legal or contractual rights, to manage or recover arrears and debts, and/or to respond to any disputes or legal claims or for crime prevention, detection or prosecution; and/or
1.6.12 comply with SULC’s auditing and/or reporting requirements.

1.7 We and/or any Mentor on behalf of SULC, and/or SULC may record any telephone communications with you for training and compliance purposes.

1.8 We and/or any Mentor on behalf of SULC, and/or SULC, will only use information about your gender or ethnicity for the purposes of monitoring and promoting equal opportunities.

1.9 We will treat your personal data as private and confidential. We, any Mentor or SULC will not disclose your personal data to anyone other than in the following circumstances:
1.9.1 We and/or any Mentor on behalf of SULC, and/or SULC and/or its other service providers (including any credit reporting agencies and debt collection agencies) may disclose your personal data to each other.
1.9.2 SULC may:
(a) contact you directly for the purposes of monitoring its, our or any Mentor’s performance and/or the Start-Up Loans Programme;
(b) use your personal data in case studies for the purposes of advertising and marketing the Start-Up Loans Programme;
(c) disclose your personal data to its finance partners (StreetUK), legal advisers and/or auditors or other advisers auditing or advising on any of its business processes;
(d) disclose your personal data to the Department for Business, Innovation and Skills (“BIS”) and other government departments, bodies, agencies or authorities where required to do so by BIS or other government departments, bodies, agencies or authorities; and
(e) disclose your personal data to third parties if it is under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation, or in order to enforce or apply these terms or its or our or any Mentor or finance partner’s (StreetUK) separate terms and conditions of supply or relating to a loan or other agreements, or to protect the rights, property, or safety of SULC, us or any Mentor or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction or law enforcement or the administration of justice.

Credit Reference and Fraud Prevention Agencies

1.10 When you apply for a loan or any of the services SULC provides and/or that we provide on behalf of SULC we and SULC will check our own records for information about you and may also carry out a search through credit reference agencies on you.

1.11 Credit reference agencies collect and maintain information about consumers’ and businesses’ credit behaviour. This includes Electoral Register, fraud prevention, and credit information (including details of previous applications and the conduct of your bank accounts) and public information such as County Court Judgements, decrees, and bankruptcies. Credit reference agencies may form a link between any previous or subsequent names that you use in the records they hold about you.

1.12 The information that we and/or SULC and other organisations provide to credit reference agencies about you, your financial associates and your business (if you have one) may be provided to other organisations and used by them and us to: 1.12.1 help make decisions, for example when:
(a) checking details on applications for loans or other credit and credit-related or other facilities;
(b) managing loan, credit and credit-related accounts or facilities;
(c) recovering debt;
(d) checking details on proposals and claims for all types of insurance;
(e) checking details of job applicants and employees;
1.12.2 detect and prevent crime, fraud and money laundering;
1.12.3 check your credit history;
1.12.4 verify your identity if you, or someone financially linked with you, applies for loan or services;
1.12.5 trace your whereabouts; and
1.12.6 undertake research, statistical analysis and systems testing.

1.13 If we and/or SULC need to make a credit decision when you apply for a loan or to review the amount of credit we provide under an existing agreement, your records will be searched, along with those of anyone who is financially associated with you such as your spouse or partner. The credit reference agency will keep a record of this search and place a “footprint” on your credit file, whether or not your application proceeds.

1.14 We and/or SULC may give details of your loan account and how you conduct it to credit reference agencies, including if you borrow and do not repay in full and on time. If you fall behind with your payments and a full payment or satisfactory proposals are not received within 28 days of a formal demand being issued, then a default notice may be recorded with the credit reference agencies. Any records shared with credit reference agencies will remain on file for 6 years after your loan account is closed, whether it has been settled by you or as a result of a default. Other organisations may see these searches and updates if you apply for credit in the future, and these may affect your ability to borrow from other lenders.

1.15 You have a right to apply to the credit reference agencies for a copy of your file.

1.16 We and SULC carry out most of our credit searches using Experian, but details of how you have run your loan account may be disclosed to all the credit reference agencies. The information they hold may not be the same and there is a small fee that you may need to pay to each agency that you apply to. Their addresses are: 1.16.1 CallCredit, Consumer Services Team, PO Box 491, Leeds LS3 1WZ or call 0870 060 1414 or log on to www.callcredit.co.uk.
1.16.2 Equifax plc, Credit File Advice Centre, PO Box 1140, Bradford BD1 5US or log on to www.myequifax.co.uk.
1.16.3 Experian Consumer Help Service, PO Box 9000, Nottingham NG80 7WP or call 0844 481 8000 or log on to www.experian.co.uk.

1.17 We and SULC have processes and systems that protect our customers and ourselves against fraud and other crime. Customer information can be used to prevent crime and trace those responsible. We will share your personal information from your application with fraud prevention agencies. If false or inaccurate information is provided and fraud is identified, details of this fraud will be passed to these agencies. Law enforcement agencies may access and use this information. We and other organisations may also access and use this information to prevent fraud and money laundering, for example when:
1.17.1 checking details on applications for credit and credit related or other facilities;
1.17.2 managing credit and credit related accounts or facilities;
1.17.3 recovering debt;
1.17.4 checking details on proposals and claims for all types of insurance; and
1.17.5 checking details of job applicants and employees.

1.18 We and other organisations may access and use from other countries the information recorded by fraud prevention agencies.

2. MARKETING

2.1 Where your consent has been obtained we and/or any Mentor on behalf of SULC, and/or SULC, may disclose your personal data to SULC and/or SULC’s corporate partners (a list of SULC’s corporate partners is available at the website address: www.startuploans.co.uk/corporate- partner-list/ who may contact you by electronic means, including by email, text (SMS) message and/or voicemail, with offers about goods and/or services which they consider may be of interest to you. If you would like to receive this information, please tick the OPT-IN box below.

2.2 We and/or any Mentor on behalf of SULC, and/or SULC, may disclose your personal data to SULC and/or SULC’s corporate partners (a list of SULC’s corporate partners is available at the website address: www.startuploans.co.uk/corporate-partner-list/ who may contact you by post or by telephone with offers about goods and/or services which they consider may be of interest to you. If you do not wish to receive such marketing materials by post or by telephone please tick the OPT-OUT box below.

How Long We Keep Your Information For

2.3 How long we and/or any Mentor on behalf of SULC, and/or SULC, keep your information will depend on the purpose for which we and/or any Mentor on behalf of SULC, and/or SULC, use it. We and/or any Mentor on behalf of SULC, and/or SULC, will only retain your information for as long as is necessary for those purposes. In particular we and/or any Mentor on behalf of SULC, and/or SULC, will keep:
2.3.1 information about you that is necessary for us and/or any Mentor on behalf of SULC, and/or SULC, to provide you with a service or product you have requested, for as long as it takes us and/or any Mentor on behalf of SULC, and/or SULC, to provide that service or product;
2.3.2 your contact details for marketing purposes and/or pass your contact details to third parties, e.g. SULC’s corporate partners, for as long as we and/or any Mentor on behalf of SULC, and/or SULC, have your consent to send you marketing information by electronic means or until you tell us, any Mentor or SULC that you do not wish to receive marketing materials by post or by telephone;
2.3.3 records of any agreements you enter into with us, any Mentor and/or SULC or services, loans or products you receive (or payments you make) for up to six years. This is so that we and/or any Mentor on behalf of SULC, and/or SULC, can respond to any complaints or disputes that arise in that period; and
2.3.4 other information about you if it is necessary for us and/or any Mentor on behalf of SULC, and/or SULC, to do so to comply with legal or regulatory requirements or to protect our or another person’s interests.

Access to Your Information

2.4 Upon payment of a fee of £10 and by written request to The Data Protection Officer at: Start-Up Loans Company, Alhambra House, 2nd Floor, 27-31 Charing Cross Road, WC2H 0AU, you may access details of the personal data we and/or any Mentor on behalf of SULC, and/or SULC, hold about you.

2.5 You also have the right (without charge) to require SULC to correct any inaccuracies in your information and we and SULC encourage you to do so to ensure the information we and/or any Mentor on behalf of SULC, and/or SULC, have about you is up-to-date.

Changes to this Privacy Notice

2.6 SULC reserves the right to amend or modify this privacy notice at any time, including in response to changes in applicable data protection and privacy legislation. We or SULC will notify you of any such changes.

3. CONSENT

By providing us with your personal data and selecting the checkbox on our website to say you wish to enquire about a Start Up Loan you agree to your personal data (including information about your ethnicity) being used and disclosed in accordance with the Privacy Notice above.