The ways in which we collect information

We will collect the information below in different ways depending on how you choose to make contact with us.

Direct – where you have come directly to use FundColony services through our website or customer services:

  • Information when you apply for any of our products or services
  • Information when you use any of our online forms
  • Information you provide, or we collect when using our website
  • Information you provide when communicating with us, whether in writing, via email, SMS or by telephone
  • Information you provide when completing customer surveys
  • Information we obtain if you engage with us on social media, including blogs and forums Information when you take part in any promotions

Third Party – where a broker has introduced you to the services of FundColony or a third party is acting on your behalf and we have authority for them to act:

  • Information that the third party enters as part of the application process, or on any of our online forms Information the third party provided when using our website
  • Information the third party provided when communicating with us, whether in writing, via email, SMS or by telephone
  • Information provided to us on your behalf by your representatives who might engage with us for you

 

What type of information we collect and store

If you wish to use our full range of services and products, we will collect some or all of the following information:

  • Personal Information – your name and date of birth
  • Contact Information – your address, phone numbers, business name and email address
  • Employment details – your current and previous employer and income details
  • Financial information – your bank account number, bank verification number, bank card details, bank transactions, your financial status, position and history
  • Communication Information – your contact details (whether via letter, email, SMS or telephone)
  • Transactional Information – a record of payments made to or received from FundColony
  • Usage Data – other data about how you use our products and services including your IP Address
  • Contractual Information – details about the services and products we may arrange or set up for you
  • Social Relationships – friends, family and other relationships
  • Documentary Data – details held in documents that are provided to us as part of any application or throughout your relationship with FundColony
  • Consents – any permissions that you provide us with, this may relate passing details onto third parties.
  • Sensitive or special information – we will only collect this information where the law says we have to and even then, only where we have your consent
  • Social Media Information – comments made on blogs and discussion forums in connection with our products and services. We may also collect personal data through your social media accounts, however we will only access your social media data with your explicit consent
  • Location data – we could use this to verify your address
  • Profile and usage data – This includes the profile you create to identify yourself when you connect to our internet and mobile services. It also includes other data about how you use those services.

 Information we collect from other sources

We will also on occasion obtain information from other sources, to enable us to offer you our products and services and to be able to operate our platform. This will, on occasion, include personal information and will be obtained from:

  • Companies that introduce you to us
  • Financial Advisors
  • Credit Bureaus
  • Insurers
  • Retailers
  • Social Networks
  • Fraud Prevention Agencies
  • Land Registry
  • Agents working on our behalf
  • Government Agencies
  • Law Enforcement Agencies
  • Public Information services such as Company affairs commission

How we will use your information

We only use personal information if we have a genuine reason to do so. This includes providing it to third parties outside of the FundColony.

FundColony will only use your personal information for one of the following reasons:

  • To fulfil a contract, we have with you
  • When it is our legal duty
  • When you consent to it
  • When it is in our legitimate interest

A legitimate interest is when we have a business or commercial reason to use your information. We will only use this reason when we think it is in your best interest so that you can have the best possible experience with FundColony.

 

Credit Bureau Agencies and Fraud Prevention Agencies

We carry out credit and identity checks when you apply for a product or service, for you or your business. We use Credit Bureau Agencies to help us with this.

If you use our products or services, from time to time we may also search information that the Credit Bureau Agencies have about you, to help us manage those accounts.

To do this, we will supply your personal information to Credit Bureau Agencies and Fraud Prevention Agencies and they will give us information about you in return. This will include information about your financial situation and financial history. Credit Bureau Agencies and Fraud Prevention Agencies will give us publicly available information about you and privately held information which will include your credit history, your current financial situation, financial history information and fraud prevention information.

When we use your information and share it with Credit Bureau Agencies and Fraud Prevention Agencies, we do so as a necessary step to assess whether we can enter into a contract with you. Where your loan application is approved, and you choose to enter into a loan through FundColony, it will continue to be necessary for us to carry out these checks from time to time to perform the contract we have with you.

We will use the information that we receive from Credit Bureau Agencies and Fraud Prevention Agencies to:

  • Help us understand whether or not we think you can afford to take out the loan that you have requested through us
  • To assess if we believe you will be able to meet your loan obligations
  • Make sure that the offers we are able to provide to you are fair and appropriate to your circumstances and check the information that you have provided to us is accurate
  • Meet our legal obligations to help prevent criminal activity, fraud and money laundering
  • Manage your account(s)
  • Trace and recover debts where we have been unable to make contact with you via any other means that we hold your information (i.e. phone, email, letter)

When Credit Bureau Agencies receive a search from us they will place a search footprint on your credit file that may be seen by other lenders and other similar companies or organisations.

If you are making a joint application or tell us that you have a spouse or financial associate, we will link your records together, so you should make sure you have made them aware how their personal information will be used by us, before you complete the application. In addition, you should both also be aware that Credit Bureau Agencies will also link your records together and these links will remain on both of your files until an approved request is received by the Credit Bureau Agencies confirming that the financial relationship no longer exists.

We will continue to exchange information about you with Credit Bureau Agencies and Fraud Prevention Agencies while you have a relationship with us. We will also inform the Credit Bureau Agencies once you have finished repaying a loan with us. If you borrow money through the FundColony platform and do not make all your repayments in full and on time this information will be shared with Credit Bureau Agencies who will record that information as part of your credit history. It is possible that the Credit Bureau Agencies will then share this information with other organisations who have a relationship with them.

If you give us false or inaccurate information or if we suspect or identify fraud, we will record this and will also pass this information to Fraud Prevention Agencies and other organisations involved in crime and fraud prevention, including law enforcement agencies.

We and other organisations may access and use this information in order to prevent fraud, money laundering or other criminal activity. If we, or a Fraud Prevention Agencies, determine that you pose a fraud or money laundering risk, we may refuse to provide our products and services you have requested, or we may stop providing existing services to you.

Fraud prevention agencies can hold your personal data for different periods of time if you are considered to pose a fraud or money laundering risk and may result in other companies or organisations refusing to provide services, financing or employment to you.

 

Automated Decisions

We sometimes use systems to make automated decisions using the personal information we have obtained from you and other sources about you or your business. Automating decisions allows us to make consistent, efficient and quick decisions regarding the products and services we offer. These automated decisions can affect the products and services we may offer you now or in the future, or the price that we charge you for them.

Information Security and Third Parties

FundColony takes the security of your information very seriously. We work hard to protect ourselves and your information from unauthorised access. We also protect against unauthorised disclosure, alteration or destruction of information we hold. In particular:

  • We encrypt the transmission of data to our websites using high grade encryption and digital certificates. We constantly review and test our encryption and security measures to ensure they are appropriate
  • We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorised access to systems
  • We restrict access to areas of our systems where personal information is stored to those FundColony employees, contractors and agents who need to know that information in order for us to be able to carry out our day-to-day business activities. The people who access these areas are subject to strict contractual confidentiality obligations. They may be disciplined or have their contract terminated if they fail to meet the high standards of security and confidentiality that we expect from them

Our website may contain links to other websites operated by third parties. This privacy policy applies only to the personal information that FundColony collects and we are not responsible for personal information that others may collect, store and use through their websites. You should refer to the privacy policy of the third parties’ website for details on how they collect and use your personal information.

It is also important that you ensure that your information is kept secure when you are online. When using our member’s portal, we would advise you to:

  • Keep your login details secret
  • Sign out of your account when you are not using it
  • Maintain good internet security in general
  • Tell us immediately if you think your account has been compromised

 

Retention of Data

We will keep your personal information for as long as is necessary to fulfil the purposes outlined in this privacy policy, unless we are required or permitted by law to retain that information for longer than this.

We will need to keep your personal information for as long as you are a customer of FundColony.

After your relationship with FundColony ends, we may keep your data for up to 7 years for the following scenarios:

  • To respond to any queries or complaints
  • To show that we have acted and treated you fairly
  • To maintain records according to rules and regulations that apply to us

In some circumstances, we will keep your data for longer than 7 years if we cannot delete it for regulatory or legal reasons. If it is required to extend our retention period, we will continue to ensure that your privacy is protected, and we will only use it for the specified reasons.

 

Data Subject’s Rights

You may have some or all of the following rights dependent upon how and why your information was collected and how we are using your information:

  • Right to Rectification– You can request at any time that we update and correct any out of date or inaccurate personal information we hold about you;
  • Right to Erasure – In some circumstances you will be able to request that we remove all personal information we hold about you, if there is no need for us to keep it;
  • Right to Restrict Processing and Object to Processing– If we process your data, you can request that we stop or restrict the processing of your personal information; and
  • Right to Data Portability– You can make a request for us to provide personal information you have supplied to FundColony to a third party

There may be regulatory or legal reasons why we cannot satisfy your requests, but we will advise you of this when a request is made.

 

Marketing

At FundColony we respect our visitors, customers and friends and therefore we will never pass your details on to third parties for marketing purposes without your explicit consent. Where you are an existing customer or have previously requested the use of our products or services, we may use your personal information to tell you about relevant products and offers. You can opt out at any time by clicking unsubscribe on any email communications we send to you, alternatively by emailing us, writing to us or by changing your contact preferences within the members area.

If you choose to unsubscribe, we will still provide you with legal notices and other important information such as changes to your existing products and services to meet our legal and contractual obligations to you.

We will use personal information that has been provided from you and obtained from third parties we work with, to provide you with marketing information about other products and services we feel you may be interested in, based on your previous interactions with FundColony. We may ask you to confirm or update your preferences if you take out any new products or services with us in the future.