Borrowers’ Privacy Notice

We take your privacy seriously.

Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain personal information about you as a borrower, or prospective borrower. When we do so we are subject to the UK data protection laws. If you are located in the European Economic Area (EEA), we are also subject to the EU General Data Protection Regulation (EU GDPR) and other local laws in relation to services we offer to individuals in the EEA. We are responsible as ‘controller’ of that personal information for the purposes of those laws.

Discover More Below:

Key terms used in this policy:

We, us, our or Sevcap Sevcap Ltd,  Sevcap I Ltd and/or Sevcap II Ltd.
Personal information Any information relating to an identified or identifiable individual
Special category personal information Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership
Genetic and biometric data
Data concerning health, sex life or sexual orientation

We may collect and use the following personal information about you:

  • your name and contact information, including email address and telephone number;
  • information to enable us to check and verify your identity;
  • location data, if you choose to give this to us;
  • further personal and business financial information also including property information and other assets and liabilities;
  • income and expenditure details including occupation, job details and any associated information you submit to us in order to become a borrower;
  • your professional online presence; and
  • information to enable us to undertake credit or other financial checks on you.

This personal information is required to provide services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing services to you.

We often collect this personal information directly from you—in person, by telephone, text or email. However, we may also collect information:

  • from publicly accessible sources;
  • directly from third parties, such as:
    • credit reference agencies, that provide us with consumer credit record information;
    • customer due diligence providers;
    • brokers;
    • co-lenders;
    • our business network including our advisors;
    • institutions – financial and otherwise;
    • from a third party with your consent, such as your bank or building society; and
    • from cookies on our website—for more information on our use of cookies, please see our cookies policy.

Under data protection law, we can only use your personal information if we have a legal basis for doing so. We only process your personal information:

  • to comply with our legal and regulatory obligations;
  • for the performance of our loan agreement with you or your company or to take steps at your request before entering into a loan agreement;
  • for our legitimate interests or those of a third party (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 rights and interests); or
  • where you have given consent for us to process your personal information for a specific purpose.

Your personal data may be stored and processed by us, always subject to one of the legal bases above, in the following ways, and for the following purposes:

  • To make lending decisions. If you are a prospective borrower, this may include assessing your application and making a credit decision.
  • To verify your identity and prevent any fraud or money laundering. For example, by checking details provided on applications for credit related facilities. If you give us false or inaccurate information and/or we suspect or identify fraud or money laundering risks, we will record this and may allow law enforcement agencies to access and use your personal data to detect, investigate and prevent 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 and/or we may stop providing existing services to you.

  • To provide you with information and services that you request from us. This will include maintaining and updating our records, transferring or receiving money and servicing your loan.
  • For audit purposes. We are required to process certain data to meet our audit obligations.
  • For debt collection. Enforcing loan or security provisions or tracing you in the case of a default.
  • For financial and statistical analysis. For the purposes of aggregating, reporting and other efficiency algorithms
  • For loan monitoring and control. Once we have a loan in place we will monitor repayments throughout the term of the loan.
  • For statutory returns. Your loan details will be included in an information pack sent to our professional advisors in order to produce our annual statutory accounts and associated tax return.
  • For screening for financial sanctions such as embargoes. We are required to screen borrowers to comply with our legal and regulatory obligations.

The above table does not apply to special category personal information, which we will only process with your explicit consent.

We do not engage in direct marketing communications.

We routinely share personal information with:

  • Brokers;
  • Co-lenders, both prospective and existing;
  • Investors, both prospective and existing;
  • Institutions;
  • Professional advisers;
  • Regulators and enforcement agencies;
  • Credit check providers, such as Creditsafe (note that we may share your name, current and previous residential addresses, date of birth and gender);
  • Debt recovery agents and purchasers of debt contracts; and
  • Microsoft, as we use Office365.

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We will impose contractual obligations on any service providers to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

We will not share your personal information with any other third party.

Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).

Some of these third parties may be based outside the United Kingdom and/or European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the UK and EEA’.

We will keep your personal information while we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:

  • to respond to any questions, complaints or claims made by you or on your behalf;
  • to evaluate entering into future contracts with you;
  • for our analysis of prior business performance;
  • to show that we treated you fairly; and
  • to keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

To provide services to you, it is sometimes necessary for us to share your personal data outside the UK and EEA, for example, with our service providers that are either located outside the UK or EEA, or that transfer personal data outside of the UK and EEA.

Transfers of personal data outside of the UK are subject to special rules under UK data protection law. This is because non-UK countries do not have the same data protection laws as the UK.

Transfers of personal data outside of the EEA are subject to special rules under EU data protection law. This is because non-EEA countries do not have the same data protection laws as the EEA.

We will ensure that any transfer of personal data outside of the UK or EEA as applicable, complies with data protection laws and that all personal data will be secure.

As a result, when we transfer personal data outside of the UK and EEA we will ensure that the transfer complies with data protection laws by following one of the below steps:

  • confirming that the recipient is located in a country which has been recognised as having an adequate level of protection for personal data;
  • putting in place safeguards (such as approved standard contractual clauses) so that you have enforceable rights and effective legal remedies; or
  • confirming that a specific exception applies under data protection law.

For more information about our international transfers, please contact us (see ‘How to contact us’ below).

You have the following rights, which you can exercise free of charge:

Access The right to be provided with a copy of your personal information (the right of access)
Rectification The right to require us to correct any mistakes in your personal information
To be forgotten The right to require us to delete your personal information—in certain situations
Restriction of processing The right to require us to restrict processing of your personal information, in certain circumstances, such as if you contest the accuracy of the data
Data portability The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object The right to object:
—at any time to your personal information being processed for direct marketing (including profiling);
—in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests
Not to be subject to automated individual decision-making The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights or if you are located in the EEA, the guidance provided by your local supervisory authority.

If you would like to exercise any of those rights, please:

  • email, call or write to us —see below: ‘How to contact us’; and
  • let us have enough information to identify you; and
  • let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill) if requested; and
  • let us know what right you want to exercise and the information to which your request relates.

We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

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

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

You can contact us by email if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint, using the following details:

Email: ir@sevcap.com

We hope that we can resolve any query or concern you may raise about our use of your information.

You also have the right to lodge a complaint with the ICO or any relevant European data protection supervisory authority. The ICO may be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.

This privacy notice was published on Friday 31st May 2019 and last updated on 5th October 2023.

We may change this privacy notice from time to time—when we do we will inform you via our website.