This Policy (together with our Website Terms and Conditions of Use and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data.
SME Loans is a registered Trading name of JPM Capital Finance Ltd which is entered on the Financial Services Register under reference number: 786117. JPM Capital Finance Ltd is registered in England and Wales (Company number: 09679459), Registered Office; Military House, 24 Castle Street, Chester, CH1 2DS Licensed by the Information Commissioner’s Office, (registration number: ZA308680). For the purposes of the General Data Protection Regulation (GDPR), we are the data controller of the personal data you submit via our websites.
1. Information we may collect from you
1.1. We may collect and process the following personal information about you:
1.1.1. General personal details, which may include:
Your contact details (email address and your telephone number)
1.1.2. Communications you send to us (by telephone, email or otherwise), for example, to report a problem or to submit queries, concerns or comments regarding the Website, our service, or general comments
1.1.3. Surveys that we use for research purposes, which we have asked you to complete, although you do not have to respond to them
Information we collect about you
1.2. With regard to each of your visits to the Website we may automatically collect the following information:
1.2.1. Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system;
1.2.2. Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from the Website (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
1.3. We may receive information about you if you use any of the other websites we operate or the other services we provide.
1.4. The information detailed above will not constitute personal data.
2. What do we do with your data?
We use your personal data for the following purposes:
Providing our services to you
2.1. We need to process certain personal information in order to provide our services to you, including the following:
2.1.1. To enable us to process and submit your Application Form to lenders and/or third party marketing partners (the "Advertising Partners");
2.1.2. To enable us to contact you regarding your application or any inquiries
2.1.3. To help us find you the most appropriate product(s)
2.1.4. To ensure that content from our Sites is presented in the most effective manner for you and for your computer
2.1.5. To detect, prevent and investigate potential or actual fraud and related activities
2.1.6. To notify you about changes to our products and services
2.1.7. To validate, suppress or enhance data
Contacting you about our services
2.2. If you have given us your contact information, we may use these details to get in touch with you about the services we offer such as by following up on an incomplete registration process or to email you details of offers you may be interested in.
2.3. You may opt out of this at any time by telling us, or if we have contacted you via email, you will be given an option to opt out by clicking the relevant email link.
Improving our services
2.4. We may use your personal data to analyse how you are using our service and to gain insights into how we can improve our products and services.
Customer Support and account administration
2.5. We may use your personal data to provide you with customer support or to investigate complaints or concerns about your account.
Related products and services
2.6. We may use your personal data to provide you with information on related products and services that you may be interested in.
2.7. We will not transfer any of your personal data to third parties for this purpose unless you give us your explicit consent.
3. Who might we share your information with?
3.1. In order to deliver our services, your personal data may be transferred to the following third parties:
Companies within the JPM Capital Ltd, including
- JPM Capital Ltd
Business Loans Providers
3.2. We may need to share your information for legitimate interests with the following third parties, operating as data controllers or data processors:
Debt collection agencies
Debt purchase companies
Credit Referencing Agencies
Data aggregation companies
Identity and Verification service providers
3.3. We may also share your personal data with advertising networks and social media companies such as Facebook and Google in order to present you with relevant advertisements. We may create ‘audiences’ of users that fit within a certain demographic in order to target our marketing. You can visit the Facebook GDPR Portal which explains these services in detail.
3.4. Our Sites may, from time to time, contain links to and from the websites of our advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
3.5. We will store and process your information on our computers and in any other way we consider appropriate. By "your information" we mean personal and financial information we (a) obtain from you or from third parties, such as credit reference agencies (who may search the Electoral Register), fraud prevention agencies or other organisations when you apply for a loan.
3.6. We will use your information to provide our services, for research, assessment and analysis and to develop and improve our services to you and other customers and protect our interests.
3.7. Calls between us may be recorded and/or monitored.
3.8. If you were introduced to us by a third party, we will give them your contact details and sufficient information about you for their accounting and administration purposes.
3.9. We may give information about you and how you manage your account to the following:
3.9.1 People who provide a service to us or are acting as our agents on the understanding that they will keep the information confidential. If they are located in another country we will make sure that they agree to apply the same levels of protection as we are required to apply to information held in the UK and to use your information only for the purpose of providing the service to us;
3.9.2. Anyone to whom we transfer or may transfer our rights and duties under this agreement;
3.9.3. We may also give out information about you if we have a duty to do so or if the law allows us to do so.
3.10. Otherwise we will keep information about you confidential.
4. Our lawful basis for processing your personal data
4.1. Under Article 6 of the EU General Data Protection Regulation (GDPR) we are required to tell you about the legal basis under which we collect and process your data.
4.2. We will only collect and process your personal data in accordance with one of the below lawful bases:
** Performance of a contract: This is where the processing is necessary for a contract we have with you, or you have asked us to take specific steps before entering into a contract, such as providing you with a quote. This lawful basis covers the following purposes:
- Providing our services to you
** Our legitimate interests: This is where we collect and process data in accordance with our “legitimate interests”. Our legitimate interests include:
Improving our service
Providing you with marketing information about our services
Providing you with customer support and administering your account
Providing you with information about related products and services offered by JPM Capital Ltd
Providing you with information about related products and services offered by our commercial partners
** Consent: You may be given the option to explicitly consent to share your data with selected third parties for marketing purposes or to sign up for related products and services. This will be via a separate notice via the website. We will never assume that we have your consent unless you have explicitly opted in, and you can withdraw your consent at any time by contacting us.
** Compliance with our legal obligations: We may be required to process or share your personal data in compliance with a legal obligation, such as in response to a request by law enforcement or when investigating a civil claim.
5. Data storage and international transfers
5.1. All information you provide to us is, as far as reasonably practicable, stored on our secure servers. Any financial information, such as credit/debit card numbers will be encrypted using SSL and 3-D Secure technology. We ask you not to permit anyone to use your name.
5.2. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Sites; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.
6. IP addresses and cookies
6.1. We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.
6.2. A "cookie" is a small electronic file that collects information when someone visits a website. A cookie can identify the pages that are being viewed, and this can assist us to select the pages that the viewer sees. Some cookies only exist whilst viewers are online, but "persistent" cookies -- which are not session-based -- remain on the viewer's computer, so that he or she can be recognised as a previous visitor when he or she next visits our website. This allows us to collect information about a viewer's browsing habits whilst on our Sites, and this can be useful in assisting us to monitor and improve our services.
6.3. The Company may release browsing data and information gathered using cookies in the aggregate, such as publishing a report on trends in the usage of the Sites. The report will only contain statistical data and will not identify any individual.
6.4. We do not store sensitive information such as account numbers or passwords in "persistent" cookies, and cookies in themselves, do not contain enough information to identify you. You will only acquire a personal identity in relation to your browsing habits after you have formally provided us with your personal data for the purposes outlined at 2 above.
6.5. In addition to using cookies, we might also use web tools to collect information about your browsing activities whilst on our Sites. In this respect the information that is provided is similar to the information supplied by cookies, and we use it for the same purposes.
6.6. Any information that we acquire about you using cookies or web tools is subject to the same restrictions and conditions as any other information we collect about you.
7. Your rights
The right to be informed You have the right to be informed over what personal data we hold and how we are using it. This information is contained within this privacy notice.
The right of access You have the right to request a copy of the personal data we hold under the GDPR by making a “subject access request” to us in writing. We will comply with all valid subject access requests within 30 days, unless the request is particularly complex; in this case we will contact you within 30 days with further information. You will not be charged for making a subject access request unless we reasonably deem this to be a manifestly unfounded or excessive request, in which instance you will be charged a reasonable fee based on the administrative costs of providing the information.
The right to rectification If some of the personal data we hold is inaccurate or incomplete, you can request that we rectify our records by writing to us. We will comply with all requests within 30 days unless the request is particularly complex; in this case we will contact you within 30 days with further information.
The right to erasure If you have consented to particular uses of your personal data, you have the right to withdraw this consent at any time.
The right to restrict processing You have the right to restrict the processing of your personal data in certain circumstances, such as when you object to us using your data in accordance with our legitimate interests or when you contest the accuracy of the data we hold on you.
The right to data portability You have the right to “portability” of your personal data that we have collected with your consent or in performance of a contract that is used in automated decision-making. This means that you can request copies of all the personal data we hold for this purpose in a structured, commonly used, and machine readable form, and we will supply this to you free of charge on request. We will respond to these requests within one month, unless the request is particularly complex, in which case we will inform you of how long it will take as soon as possible.
The right to object You have the right to object to the processing of your personal data in certain circumstances.
Rights in relation to automated decision making and profiling You have a right to object to automated decision making, to express your point of view, ask for human intervention, and to be provided with an explanation of the decision with your option to challenge it. The right is not absolute and is not applicable for the entering into a consumer credit agreement.
The right to lodge a complaint with a supervisory authority You have the right to lodge a complaint with us directly and/or with a supervisory authority. In the UK the relevant authority is the Information Commissioner's Office (ICO). You can find their contact details here: https://ico.org.uk/global/contact-us/
The right to withdraw consent Where we are using your personal data in accordance with our legitimate interests, you can object to further use of your data. This objection should be based on grounds relating to your particular situation. If you object, we will stop using your personal data in this way immediately, unless there are compelling legitimate grounds for processing your personal data which override your interests, rights and freedoms (such as requests by law enforcement) or we need to process your data for the establishment, exercise or defence of legal claims. You may always object to further use of your data for direct marketing purposes by clicking the “unsubscribe” button within marketing emails or by contacting us by writing to us at firstname.lastname@example.org
You can exercise any of your rights by contacting us via the details at the bottom of this page. Please note that we may need to verify your identity before complying with any of the above requests.
8. Credit Reference and Fraud Prevention Agencies
8.1. When you submit an Application Form you confirm that all the information you have given is true and complete. When you submit an Application Form you authorise our Advertising Partners to check the following records about you and others:
8.1.1. our own;
8.1.2. those at credit reference agencies (CRAs); and
8.1.3. those at fraud prevention agencies (FPAs).
8.1.4. Please contact us at email@example.com or write to us at JPM Capital Ltd, Military House, 24 Castle Street, Chester, CH1 2DS, United Kingdom, if you want to receive details of the relevant fraud prevention agencies
8.2. Our Advertising Partners will make checks such as are deemed necessary to assess your application for credit.
8.3. If you tell us that you have a spouse or financial associate, we will link your records together so you must be sure that you have their agreement to disclose information about them. CRAs also link your records together and these links will remain on your and their files until such time as you or your partner successfully files for a disassociation with the CRAs to break that link.
8.4. If false or inaccurate information is provided and fraud is identified, details will be passed to fraud prevention agencies.
8.5. Law enforcement agencies may access and use this information.
8.6. We and other organisations may also access and use this information to prevent fraud and money laundering, for example, when:
8.6.1. checking details on applications for credit and credit related or other facilities;
8.6.2. managing credit and credit related accounts or facilities;
8.6.3. recovering debt;
8.6.4. checking details on proposals and claims for all types of insurance; or
8.6.5. checking details of job applicants and employees.
8.7. We and other organisations may access and use from other countries the information recorded by fraud prevention agencies.
8.8. Your data may also be used for other purposes for which you give your specific permission or, in very limited circumstances, when required by law or where permitted under the terms of the Data Protection Act 1998.
9. How long we will keep your data for
9.1. We will only keep your personal data for as long as is necessary. This means that we will retain your personal data for as long as we have an active contract or business relationship with you, and after this, we will only keep your data for as long as is necessary for the purposes which it is stored.
10.1. If you feel that we have not been complying with our obligations on data protection law or you wish to assert one of your rights, please contact us without delay using the contact details provided below.
10.2. Should you be dissatisfied with our response or wish to complain to the relevant supervisory authority, you can do so by contacting the Information Commissioner’s Office (ICO). Contact details for the ICO can be found here.
11. Contact us
11.1. If you have any concerns, questions or requests regarding this Policy, then please send an email to: firstname.lastname@example.org. Alternatively you can write to us at the following address: 77 New Cavendish Street, London, England, W1W 6XB, UK.