1. Key information
This privacy notice explains how Bespoke Transactions Ltd (“BT”) collects and processes your personal data, including data you provide directly, through our website or through an authorised third party.
We may collect your data when you, or a company or person with whom you are associated, applies to enter into a loan agreement with us. This notice may be updated from time to time and we will notify you of material changes.
2. Personal data
Personal data means information from which an individual can be identified. We may collect identity, contact, identification, technical, family, employment, financial, residency and health data, together with information you choose to provide in connection with a loan.
If you apply on behalf of a company or other entity, or have a guarantor, we may also hold and process personal data relating to directors or guarantors.
3. Data retention
We hold data for as long as necessary for the purpose for which it was collected. If an application is not accepted or you do not take out a loan, we may retain it for a further 18 months. Where you invest with or borrow from us, the law requires us to keep basic information for at least six years.
4. How we use your personal data
We use personal data where needed to perform a contract, pursue legitimate interests that do not override your rights, or comply with a legal or regulatory obligation. We rely on consent for certain marketing communications, which you may withdraw at any time.
5. Legal grounds
Our legal grounds include performance of a contract, legitimate interests in administering finance, your consent, compliance with legal obligations, and substantial public interest where sensitive data is needed to make reasonable adjustments.
6. What we do with your personal data
We may use your information to assess and manage a loan, confirm identity and application details, prevent fraud and money laundering, comply with legal obligations, assess risk, calculate payments, recover debts, respond to queries and legal rights requests, improve services and processes, and send permitted marketing.
7. Disclosures of personal data
We may share information on a limited basis with companies in our group, introducers, professional advisers, suppliers, credit reference and fraud prevention agencies, regulators, law enforcement and other parties where required to assess or administer finance, enforce an agreement, respond to a legal request or complete a business reorganisation.
8. International data transfers
Where personal data is transferred outside the UK, we ensure a similar degree of protection and appropriate safeguards, including approved contractual clauses, are in place.
9. Your legal rights
You may request access, correction, erasure, restriction or transfer of your personal data; object to certain processing; withdraw consent; request human intervention in automated decisions; and complain to the Information Commissioner’s Office. BT does not currently use fully automated decision-making or profiling systems.
10. Data security
We use appropriate measures to prevent personal data from being lost, misused, accessed without authorisation, altered or disclosed. Access is limited to people with a business need to know, and we maintain procedures for suspected data breaches.
11. Cookie policy
Cookies are small amounts of information stored on your computer. They can make the site easier to use, help monitor traffic and personalise content. You can configure your browser to reject cookies, although some site features may then be unavailable.