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Version last updated: 14 June 2018

Privacy notice.

This privacy notice explains how AssetFi, a trading style of Vernova Finance Ltd, holds and uses your personal information and the rights available to you under data protection law.

Who we are

AssetFi is a trading style of Vernova Finance Ltd (company number: 16128132), a Commercial Finance Broker based at Unit 1E, Leaworks House, 10 Ronald Street, Nottingham, England, NG7 3GY. Vernova Finance Ltd is an Appointed Representative of AFS Compliance Limited, which is Authorised and Regulated by the Financial Conduct Authority (FRN: 625035). We act as a broker for our customers.

What is the purpose of this document?

Vernova Finance Ltd is the controller and responsible for your personal data (collectively referred to as AssetFi, Vernova Finance Ltd, we, us or our). We are responsible for deciding how we hold and use personal information about you and are required under data protection legislation to notify you of the information in this notice.

Read this notice together with any other privacy or fair processing notice we may provide when collecting or processing personal data. This notice supplements those notices.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 14 June 2018. Historic versions can be obtained by contacting gdpr@afsuk.com.

The data protection law in the UK changed on 25 May 2018. Please keep the personal data we hold about you accurate and current, and inform us if it changes during your relationship with us.

The data we collect about you

Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed.

Identity data: first name, maiden name, last name, marital status, title, date of birth, gender, passport copy, driving licence copy and utility bills copy.
Contact data: residential address, billing address, email address and telephone numbers.
Financial data: bank details, details of your income and outgoings, and net worth statements.
Transaction data: details about payments to and from you and other details of products and services purchased from us.
Marketing and communications data: preferences in receiving marketing from us and our third parties and communication preferences.

We may also collect, store and use special categories of more sensitive personal information, including information about your health and medical conditions, particularly where you are classified as vulnerable.

We may collect, use and share aggregated statistical or demographic data. If combined with personal data so that you can be identified, it will be treated as personal data under this notice.

If you fail to provide personal data

Where we need to collect personal data by law or under a contract and you fail to provide it when requested, we may not be able to perform the contract or provide our services. We will notify you if this is the case.

How is your personal data collected?

We collect data through direct interactions, including forms, post, phone and email. This includes data provided when you apply for our services directly or through our web page, or request marketing.

We may also receive contact, financial and transaction data from business information providers such as Credit Safe, Experian or Companies House, and from introducers and other businesses with which we have a trading relationship.

How we use your personal data

We use personal data only where the law allows us: with consent; where necessary for a contract; to comply with a legal obligation; to perform a public task; or where necessary for our legitimate interests or those of a third party unless your interests override them.

We process personal information to find the best source of finance for your circumstances, undertake credit checks, confirm affordability, comply with anti-money laundering and know-your-client requirements, and meet our regulatory responsibilities.

Automated decision making

Automated decision-making may be used where we have notified you and given you 21 days to request reconsideration, where it is necessary to perform a contract with you and appropriate safeguards are in place, or in limited circumstances with your explicit written consent and appropriate safeguards.

If an automated decision is based on particularly sensitive personal information, we must have your explicit written consent or a public-interest justification, together with appropriate safeguards. Many of our funders use auto-scoring technology to underwrite deals. You will not be subject to a decision with a significant impact based solely on automated decision-making unless we have a lawful basis for doing so and have notified you.

Why might we share your information with third parties?

We share personal information where required by law, necessary to administer our contractual relationship with you, or where we have another legitimate interest. Third parties may include the most suitable funders on our panel; IT hosting and maintenance providers; AFS Compliance Limited to meet regulatory obligations to our Principal Firm; credit reference agencies; regulatory bodies such as the Financial Conduct Authority; other group members; fraud prevention agencies; and third-party product providers where you have given prior consent.

We have a data protection regime in place to oversee effective and secure processing of personal data. More information is available on our website.

How long we keep your information

We retain personal information only for as long as necessary to fulfil the purposes for which it was collected, including legal, accounting and reporting requirements. Details of retention periods are available from gulshan@vernovafinance.co.uk.

We consider the amount, nature and sensitivity of the data, the risk of unauthorised use or disclosure, the purposes of processing, whether those purposes can be achieved another way, and applicable legal requirements. We may anonymise information so it can no longer be associated with you and then use it without further notice. Once you are no longer an employee, worker or contractor of the company, we will retain and securely destroy your personal information in accordance with applicable laws and regulations.

International transfers

We do not transfer your personal data outside the European Economic Area (EEA).

What are your rights?

Under certain circumstances, by law you have the following rights:

  • Request access: receive a copy of the personal information we hold about you and check that we are lawfully processing it.
  • Request correction: have incomplete or inaccurate information we hold about you corrected.
  • Request erasure: ask us to delete personal information where there is no good reason for us continuing to process it.
  • Object to processing: object where we rely on a legitimate interest or process your personal information for direct marketing.
  • Request restriction: ask us to suspend processing, for example while we establish its accuracy or reason for processing.
  • Request transfer: request the transfer of your personal information to another party.
  • Withdraw consent: withdraw consent for specific processing at any time where consent is our lawful basis.

To review, verify, correct or request erasure of your personal information, object to processing, or request transfer, contact gdpr@afsuk.com.

You will not normally have to pay a fee. We may charge a reasonable fee or refuse a request if it is clearly unfounded or excessive. We may request specific information to confirm your identity and protect personal information from unauthorised disclosure.

Complaints

If you wish to raise a complaint about how we have handled your personal data, contact our Data Protection Officer, Gulshan Khan, at gulshan@vernovafinance.co.uk.

If you are not satisfied with our response, or believe we are processing your data unlawfully, you can complain to the Information Commissioner's Office (ICO).

Schedule 1 - Processing activities and lawful basis

The following table describes the planned processing activities, the categories of personal data involved, and the lawful basis relied upon.

Purpose or activityType of dataLawful basis
To find the best source of finance based on your circumstances.Identity; Contact; Financial; Transaction; Marketing and communicationsContractual; legitimate interest: to promote financial products we believe may be of interest to you.
To undertake credit checks for the purposes of finding the most suitable finance product.Identity; Contact; Financial; Transaction; Marketing and communicationsContractual
To confirm your affordability for the financial requirement you have proposed to us.Identity; Contact; Financial; Transaction; Marketing and communicationsContractual
To comply with our anti-money laundering and know your client requirements.Identity; Contact; Financial; Transaction; Marketing and communicationsLegal obligation
To meet our regulatory responsibilities.Identity; Contact; Financial; Transaction; Marketing and communicationsLegal obligation