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.
We are committed to protecting your privacy and have established this Privacy Policy, which covers:
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:
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.
We may collect, use, store and transfer different kinds of personal data about you, including:
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.
We use different methods to collect data from and about you, including:
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:
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:
The personal data we may collect and hold, includes personal data about the following individuals:
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.
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.
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.
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.
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.
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:
and hosting of data;
The legal bases for our processing of your date include:
We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
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.
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).
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. 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.
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.
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 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.
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.
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.
In the case of journalists and influencers, we collect and store contact details for the following purposes:
Unless expressly specified with regard to specific information that we collect from you, we may disclose personal data to:
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.
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, for example to the United States, 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:
Where personal data is shared with fraud prevention agencies that transfer your personal data outside of the European Economic Area, these agencies impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the European Economic Area. They may also require the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing.
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:
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.
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.
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.
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.
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.
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.
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).
This Policy was last updated on 16 May 2022 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.