About Tradeplus24 Limited

Tradeplus24 Limited (referred to as “Tradeplus24”, “we”, “our’, “us”) is the controller responsible for your personal data and is bound by applicable data protection laws where we operate, including the UK Data Protection Act 2018 and the UK General Data Protection Regulation (“UK GDPR”) and the General Data Protection Regulation (“GDPR”). We recognise the importance of ensuring the confidentiality and security of your data, including personal data. Our customers (who borrow directly from us) are business customers. We primarily collect information about your organisation, though we may collect certain personal data about representatives, directors, employees, and agents of our customers as described in this Policy.

This Privacy Policy at a glance. 

We are committed to protecting your privacy and have established this Privacy Policy, which covers:
  • Our data processes, including what information we collect and store, how we collect and store it, and why we do so;
  • How we use your information, including sharing with third parties, and how long we retain it; and
  • Your rights in relation to your information, and how to exercise them.
Key terms used in this Privacy Policy are defined in the “Definitions” section. Copies of this Policy are available free of charge on our website or by contacting us. If you have any questions about this Policy, please see the section on “Contacting Us.” This Policy addresses each of the following topics in detail as it relates to your privacy:

Collection of Personal Data

We may collect and hold a range of information about you, including personal data, that is reasonably necessary for, or directly related to, one or more of our functions or activities.

The kind of personal data we collect and hold

We may collect, use, store and transfer different kinds of personal data about you, including:
  • Website Data: Website data includes Website use and activity information collected via cookies (often on an aggregate basis) about you and other users who use our Website;
  • Email Data: If you choose to correspond through email, we may retain the content of your email messages (including any personal data you have provided) together with your email address and all responses sent through our Website;
  • Identity Data: Identity data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender. It also includes information we obtain to verify representations made by you, such as your passport, government-issued photo identification, and bank account details, as well as organisation details, such as anti-fraud information (KYC and AML checks), identity verification and credit checks of the individual applicant acting on behalf of the organisation (e.g., the director of the business).
  • Contact Data: Contact data includes billing address, delivery address, email address and telephone numbers;
  • Profile Data: Profile data includes your username and password, Transaction data per below, and feedback and survey responses;
  • Financial Data: Financial data includes bank account data, accounting software data and payment card details, tax relevant data and data from your organisation’s annual accounts. It may also include Credit Bureau Data.
  • Credit Bureau Data: Credit bureau data includes information related to your commercial and/or consumer creditworthiness obtained from credit reference agencies that is used for running credit checks of the individual applicant acting on behalf of the organisation (e.g., the director of the business applying for financing).
  • Tradeplus24 Transaction Data: Tradeplus 24 transaction data includes details about payments made to and from you and Tradeplus24 and related details of products and services you have purchased from us;
  • Business Transactions Data: Details about specific transactions conducted in the course of your business, such as mergers and acquisitions, entering into partnerships, or other transaction data apart from the Financial Data we collect. This also excludes Tradeplus24 Transaction Data regarding your transactions with us.
  • Technical Data: Technical data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on your device that together create a digital footprint of the device you use to access our Website for anti-fraud detection purposes;
  • Marketing and Communications Data: Marketing and communications data includes your preferences in receiving marketing or advertising materials from us and our third parties and your communication preferences; and
Any other personal data you choose to provide us We may receive other personal data that you choose to provide us. We destroy or de-identify (e.g., anonymize) all unsolicited personal data we receive unless it is relevant to our purposes for collecting personal data. We may retain additional information we receive about you if it is combined with other information we are required or entitled to collect. If we do this, we will retain the information in the same way we hold your other personal data.

How we collect personal data

We use different methods to collect data from and about you, including: Direct Interaction We generally collect commercial and personal data directly from you when you communicate with us via internet, phone (e.g., recorded calls), or mail. In seeking financing for your organisation, we may also collect certain personal data from you about representatives or directors of your organisation. For example, personal data, such as your Identity, Contact and Financial Data, will be collected through: our registration or application processes when you apply for products or services; filling in registration forms; and other interactions with you in the course of providing you with our products and services, including when you visit our website, call us or send us correspondence. This includes personal data you provide when you:
  • Apply for our products or services;
  • Register and create an account on our website;
  • Subscribe to our service or publications;
  • Request marketing to be sent to you;
  • Complete a survey; or
  • Give us some feedback.
Third parties or publicly available sources Depending on the services we provide to you, we may also collect personal data about you from third parties, including banks and other financial institutions, credit agencies, governmental agencies, and marketing agencies. This includes various types of third parties and public sources as set out below:
  • Identity, Contact, and Financial Data:  As a lender, we have in place contractual protections with the borrowers that we do business with.  For example, we require borrowers that share their individual customers’ personal data with us to provide affected individuals with written notice in their privacy policy that their data may be shared with third party lenders. Additionally, in the event of default, we will directly inform borrowers in writing via email regarding the event of default and provide a link to or copy of this Privacy Policy. We also may collect information about you and your organisation from public sources and other third-party affiliated and non-affiliated sources, such as business credit rating agencies like Dun & Bradstreet.
  • Technical Data from:
    • Analytics providers;
    • Advertising networks; and
    • Search information providers.
  • Contact, Financial and Tradeplus24 Transaction Data from providers of technical, payment and delivery services:
    • Identity and Contact Data from data brokers or aggregators; and
    • Identity and Contact Data from publicly available sources.

About whom we collect personal data

We use different methods to collect data from and about you, including:
  • Customers and potential customers;
  • Directors or applicants of a Business;
  • Visitors to our website; and
  • Service providers or suppliers.
Children’s data We do not knowingly solicit data from or knowingly market to individuals under the age of 18 years. Similarly, we do not knowingly collect, process, store, use or share personal data of individuals under the age of 18.

Cookies and other data collection tools

We use cookies, which are small data files often stored on your device when you browse the web. They are widely used to make websites work more efficiently, and to provide a more personalised online experience. Cookies help us to better understand how you are using our services, to keep track of your preferences, such as the region you are in, and provide you with the best possible browsing experience. We leverage this information to offer you personalised features and to optimise our advertising and marketing efforts. We use five types of cookies: necessary, preferences, statistics, marketing and unclassified.
  • Necessary – Necessary cookies are the basic cookies a website needs to function properly.
  • Preferences – Preference cookies allow a site to remember your preferences, like language.
  • Statistics – Statistic cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.
  • Marketing – Marketing cookies are used to track visitors and to display ads that are relevant and engaging for the user.
Some cookies are placed by third party services that appear on our pages. The data transmitted by you when using our website is anonymised and we do not identify you nor do the services of third parties that we use. We also share information about your use of our site with our social media, advertising and analytics partners who may combine it with other information that you’ve provided to them or that they’ve collected from your use of their services. We use retargeting technology enabled by cookies. This means we collect personal data through cookies and share it with third parties for targeted marketing purposes. For instance, we can tailor our online marketing (e.g. banner ads) on the websites of our online marketing partners, such as Google Adwords, to better suit your needs and remind visitors of our website about our services. We also use Google Analytics, which is a web analysis service provided to us by Google which gives us a more holistic understanding of how you use our website and services. Google Analytics collects information about our users in an anonymised manner. Google may use the data collected on our website to personalise ads from its own network. Google’s usage of this data is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. If you want to opt-out of this process, you can do so here. Opting out If you don’t want us or our online marketing partners to use cookies to collect, store and analyse data related to your usage of our website to provide a more personalised experience, you can opt-out at any time by installing an opt-out cookie on your browser.

Browser controls and managing cookies

Each browser provides tools to help you handle cookies, whether you want to accept them, reject them or delete them entirely. You can typically access these settings through the ‘preferences’ or ‘options’ menu of your browser. You can find out how to Install an opt-out cookie. We have provided links to the settings pages of some common browsers below: Please remember that the opt-out cookie will only be applied to the browser you are using when you install it. If you use a different device or browser, you will need to install the opt-out cookie again.

How We Use Your Personal Data

Purposes and legal bases for which we use your personal data

We only use your personal data for a specific purpose, and only process the personal data that is relevant to achieving that purpose. Most commonly, we collect and hold personal data about you for the following purposes:
  • Registering and on-boarding customers;
  • Verifying customer identities to prevent fraud and money laundering;
  • Assessing customer creditworthiness;
  • Providing our products and services to you, including managing payments, fees and charges and collecting and recovering any money owed to us;
  • Managing our relationship with you and learning more about you as a customer, including asking you to leave a review or take a survey;
  • Improving our products and services, including through data analytics;
  • Delivering relevant website content and advertisements to you and assessing the effectiveness of the advertising we provide you;
  • Administering and protecting our business and our website, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data;
  • Keeping our records up-to-date;
  • Meeting our legal, regulatory and compliance obligations;
  • Contacting you for marketing purposes and making recommendations about products and service we think may be of interest to you; and
  • Undertaking any other purposes that we notify you about from time to time.
  • Performance of the contract we are about to enter into or have entered into with you by providing you with our products and services;
  • Where it is necessary for our legitimate interests and your interests and where fundamental rights do not override those interests; and
  • Where we need to comply with a legal or regulatory obligation.
We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Credit Reference Agency Information Notice (CRAIN)

In order to process your registration and application for credit, we will perform credit and identity checks on you with one or more credit reference agencies (“CRAs”), such as [Experian, Equifax, and/or TransUnion] as described in more detail below. To do this, we will supply your personal data to CRAs and they will give us information about you. In particular, we may provide CRAs personal data from your credit application and information about your financial situation and financial history. CRAs may provide us with both public information and information on your shared credit, financial situation and financial history, as well as fraud prevention information. To assess your creditworthiness By registering on our website for our products or services, we may process and exchange creditworthiness information with CRAs as described in this Policy and pursuant to our Terms and Conditions on our website. For example, we collect, hold and use, information related to your commercial and consumer creditworthiness from Experian Limited, a credit reporting body, for all purposes permitted by law. This activity is conducted for the purpose of assessing your credit capacity, eligibility or history in connection with an application (e.g., to see whether you can afford to take the product). Creditworthiness information includes information that is both positive (like payment information) and negative (like defaults or serious credit infringements). To prevent and detect fraud 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. 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 Cifas.These checks require us to process personal data about you and may include contacting third parties about your information or exchanging your information with third parties.
  • Details of the personal data that will be processed, include for example: name, address, date of birth, address, contact details, financial information, employment details, device identifiers including IP address and vehicle details.
  • We and fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.
  • 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.
To manage our credit relationship with you We also use information provided by CRAs to manage our credit relationship and your accounts, help us collect payments from you, trace and recover any debts, and to ensure any offers we provide you are appropriate to your circumstances. Information we provide CRAs We inform CRAs about your settled accounts. If you borrow from Tradeplus24 and do not repay in full and on time, we may disclose to CRAs that you failed to pay. CRAs record the outstanding debt. This information may also be supplied by CRAs to other third parties. [When CRAs receive a search from us they may place a search footprint on your credit file that may be seen by other lenders.] We may continue to exchange information about you with CRAs while you have a relationship with us. Please be aware that CRAs may continue to hold and use your information following termination of your relationship with Tradeplus24. For more information about how CRAs such as Experian may use your data, please see their privacy notices available on their websites. Information about Experian, its role also as fraud prevention agency, the data it holds, the ways in which it uses and shares personal information, data retention periods and your data protection rights are explained in more detail on the CRAIN section of Experian’s website: www.experian.co.uk/crain.

If you fail to provide requested personal data

If you do not provide us with the personal data we request, we may not be able to perform the contract we have or are trying to enter into with you and to provide you with our products or services. In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time. We do not give you the option of dealing with us anonymously or using a pseudonym if you intend to enter into a business relationship with us. This is due to anti-money-laundering provisions which make it illegal for us to deal with individuals who are not identified and our principle to know our clients very well.

Change of purpose

We may use and disclose your personal data for any of the purposes named above. We may also use and disclose your personal data for secondary purposes which we reasonably consider when we need to use it for another reason and ensure that the reason is compatible with the original purpose, or in other circumstances permitted by law. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Marketing

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you, and we call this marketing. You will receive marketing communications from us if you have opted to do so, or where permitted by law if you have a relationship with us and did not opt out of receiving that marketing. You can choose to receive marketing communications from us by opting in during the registration process. We will get your express consent before we share your personal data with any company outside the Tradeplus24 group of companies for marketing purposes. Opting Out: You can choose to stop receiving marketing at any time by logging in to your account and selecting to opt-out of newsletters and marketing. You can also select to opt out of such marketing during the registration process. Additionally, you can click “unsubscribe” at the bottom of any marketing emails you receive. Where you opt out of receiving e.g., marketing messages, this applies only to marketing messages, and does not stop other processing of personal data that we conduct, for instance as a result of entering into a credit line agreement with us.

Public relations 

In the case of journalists and influencers, we collect and store contact details for the following purposes:
  • To share press releases and corporate news
  • To provide commentary from spokespeople on relevant topics and events
  • To arrange meetings, or interviews with spokespeople
  • To share invitations to events, webinars, or to participate in campaigns

Sharing Your Personal Data

To whom we disclose personal data 

Unless expressly specified with regard to specific information that we collect from you, we may disclose personal data to:
  • A related entity of us;
  • An agent, professional advisor or service provider we engage to carry out our functions and activities (such as, but not limited to, lawyers, accountants, IT contractors, marketing companies);
  • Credit reference agencies, such as Experian in relation to your commercial and consumer creditworthiness (e.g., defaults or serious credit infringements for failure to pay us)
  • Organisations involved in a transfer or sale of our assets or business;
  • Financial institutions involved in managing our payments, such as banks;
  • Regulatory bodies, government agencies, law enforcement bodies and courts;
  • Anyone whom you authorise us to disclose it; and
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Policy.
If we disclose your personal data to service providers that perform business activities for us, they may only use your personal data for the specific purpose for which we supply it. We will ensure that all contractual arrangements with third parties adequately address privacy issues and will make third parties aware of this Policy. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Sending your data internationally

In general, we keep your personal data within the European Economic Area (“EEA”) and the UK. If we need to transfer your personal data out of the EEA, we work with our vendors to ensure a similar degree of protection is afforded to your data by implementing at least one of the following safeguards: Data transfers by third parties Fraud prevention agencies may allow the transfer of your personal data outside of the UK. This may be to a country where the UK Government has decided that your data will be protected to UK standards, but if the transfer is to another type of country, then the fraud prevention agencies will ensure your data continues to be protected by ensuring appropriate safeguards are in place.

Your Rights, and How to Exercise Them

Your legal rights

You have a range of rights under data protection laws in relation to your personal data. These rights are not absolute, but under certain circumstances you may have the right to:
  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Exercising your legal rights

If you wish to exercise any of the rights set out above, please contact us. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month (and in any event within the deadlines set out under applicable law). Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. You also have a right to complain to the Information Commissioner’s Office or other relevant supervisory authority which regulates the processing of personal data.

Data Security

We recognise the importance of securing the personal data we collect. While we cannot eliminate potential security risks to your data, we take steps to ensure your personal data is protected from misuse, interference or loss, and unauthorised access, modification or disclosure. We have put in place appropriate technical and organisational security measures, such as passwords, encryption, and restricted access to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. We limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. Any third parties we share data with will only process your personal data on our instructions, and they are subject to a duty of confidentiality and must keep your data secure. In the event of any suspected personal data breach, we have security procedures to deal with the incident and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We retain and delete data according to the data retention policy and protocols we have in place. To determine the appropriate retention period for personal, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Aggregated Data

We also collect, use, and share aggregated data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

Automated Technologies and Decision-making

As you interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites using our cookies. Please see the section about cookies for further details. As part of the processing of your commercial and consumer personal data, certain decisions may be made by automated means. For example, we may automatically decide that you or your organisation poses a fraud or money laundering risk if: (i) our processing reveals that your behaviour is consistent with that of known fraudsters or money launderers, or inconsistent with your previous submissions; or (ii) 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 below.

CONSEQUENCES OF PROCESSING

  1. 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.
  2. 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.

Additional Information

Updates to your personal data

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Contacting us

If you have any questions about this Policy, or wish to make a complaint about how we have handled your personal data, you can do so by contacting our Data Protection Officer using the below details: Full name of legal entity: Tradeplus24 Limited Email address: data-protection@Tradeplus24.co.uk Postal address: 30 Newman Street, W1T 1PT, London, United Kingdom. Telephone number: +44 (0) 20 3968 6406 You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO) or the UK supervisory authority for data protection issues (www.ico.org.uk).

Updates to this policy

This Policy was last updated on 25 August 2021 and will be reviewed regularly to take account of new laws and technology, and changes to our operations and the business environment. If the notice has been updated, we will take steps to inform you of the update by appropriate means, depending on how we normally communicate with you.

Definitions

  • Disclosing information’ means providing information to persons outside of us;
  • Personal data’ means any data or information about an identified or identifiable natural person that can be used to identify that person. Personal data can extend to online identifiers such as IP addresses and cookie identifiers. It does not include data where the identity has been removed (e.g., anonymous data).
  • Data Protection Officer’ is the contact person for questions or complaints regarding our handling of personal data; and
  • Use of information’ means our use or processing of information.