This privacy policy sets out how SnapCap LTD uses and protects your personal data. This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Alternatively, you can download a copy of the policy.
This privacy policy gives you information about how SnapCap LTD collects and uses your personal data through your use of this website, including any data you may provide when you apply for a product and service, make ongoing payments, visit our website or contact us by phone and email.
This website is not intended for children and we do not knowingly collect data relating to children.
SnapCap LTD is the controller and responsible for your personal data (collectively referred to as "COMPANY", "we", "us" or "our" in this privacy policy). If you have any questions about this privacy policy, including any requests to exercise your legal rights (paragraph 9), please contact us at info@snapcap.co.uk
Includes first name, last name, any previous names, date of birth; nationality, citizenship status, politically exposed person (PEP) status, information about your identity provided by identity documents you submit such as passport and drivers licence numbers and copies of such documents.
Includes email address, postal address; mobile and telephone numbers.
Includes bank account details, bank transactions & live access to bank statements; tax details; home ownership; credit reports; company directorship and shareholding; business name; details about your financial situation, which may include information about income, assets, expenses and any debts may have (including by the collection of bank statements, credit report information and payments history); details of any securities given to us or another person; information about a business you are involved in, including its size and business type; details of your loan with us including the date, due date, date of repayment, date of default, loan balance, repayment period, missed payments and defaults; and details of specified transactions with which you are involved.
Includes details about payments to and from you and other details of products and services you have purchased from us.
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, device ID and other technology on the devices you use to access this website.
Includes your username and password.
Includes information about how you interact with and use our website, products and services.
Includes your preferences in receiving marketing from us and our third parties and your communication preferences. We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.
We use different methods to collect data from and about you including through:
You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. The personal data we collect from you may be collected through various means including:
As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
We will receive personal data about you from various third parties and public sources as set out below:
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
Performance of a contract with you:
Where we need to perform the contract we are about to enter into or have entered into with you.
Legitimate interests:
We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Legal obligation:
We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
Consent:
We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.
We may share your personal data where necessary with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.
Internal Third Parties
such as our related companies.
External Third Parties
such as the credit reference agencies detailed above, our business partners, service providers, subsidiaries and affiliates, other financial institutions that are assisting in the review or processing of a credit application with which you are connected or in connection with your dealings with us or with the provision of our services, such as by providing data storage and other similar services; our agents, the person who introduced you to us, contractors or other third-party service providers, to enable them to provide administrative and other support services to us; credit reference agencies; credit providers; your authorised agents or executor, administrator or legal representative; government agencies and regulatory bodies as part of our statutory obligations, or for law enforcement purposes; debt collection agencies, lawyers or insolvency professionals as well as other creditors for the purpose of conducting the collection and recovery of outstanding debt.
Sharing with business partners:
our business partners with whom you have an existing business relationship. Our business partners refer your details to us for the purpose of inviting you to apply for a business loan. If you apply for a loan, we will disclose certain personal information (including credit-related personal information) and business-related information to the relevant business partner. The information we disclose to the business partner is collected by us during the application process, and in servicing your loan. Our business partners use this information for the purposes of internal reporting, assessing and improving the customer experience, and for marketing and promotional activities. The types of information we typically share with the relevant business include the following:
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 privacy 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.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.
We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, 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, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see paragraph 9 below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
You have a number of rights under data protection laws in relation to your personal data.
You have the right to:
Request access to your personal data
(commonly known as a "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 in certain circumstances.
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) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
You also have the absolute right to object
Any time to the processing of your personal data for direct marketing purposes (see OPTING OUT OF MARKETING in paragraph 4 for details of how to object to receiving direct marketing communications).
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
(see the table in section 4 for details of when we rely on your consent as the legal basis for using your 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.
Request restriction of processing of your personal data
This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
If you wish to exercise any of the rights set out above, please contact us via email at info@snapcap.co.uk No fee usually required.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
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. Occasionally it could 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.
If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:
Email address: info@snapcap.co.uk
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
We keep our privacy policy under regular review.
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, for example a new address or email address.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.