The following is the Privacy Policy referred to in the Platform Terms and Conditions:

Our approach to privacy

For the purposes of this Privacy Policy “you” refers to individuals who are natural persons who are accessing or using the Site or the Platform.

This Privacy Policy sets out who we are, what information we might collect, and what we do with that information. It also explains what your rights are. This Privacy Policy informs you how we use, store, protect and disclose your personal information when it is in our hands.

Because our business entails providing a platform for the exchange of information between business users (Users), who are aiming to enter into transactions between each other, we principally collect and process your information in accordance with their instructions, and we act as data processors for our Users. We are required to comply with our Users’ directions as to how they want us to use your information and the terms of any assurances they have given you about privacy, subject always to applicable laws. We may share your personal information with our Users who have asked us to collect and process it. They have their own Privacy Policies that apply to your information once it is passed to them. Whilst we will process such data in accordance with this Privacy Policy, the ownership of such data vests in the User providing it and it is the responsibility of Users to have an appropriate legal basis for processing your data and otherwise to comply with the Data Protection Legislation.

The only time when we process personal data as data controllers are:

1. Where we gather relevant information for the purposes of compliance with the Anti-Money Laundering Regulations
2. Where we gather information relating to individual users of the Site and Platform, to confirm that they are authorised by specific Users or where Users provide point of contact information to us
3. Where we gather data from user devices by means of cookies. Our cookie policy, including details on how we manage cookies, is available on our Site at https://findango.loans/cookie-policy/.

Our legal basis for processing your data for the above purposes are based on a) compliance with relevant legal obligations on us; or b) on the basis that the processing is necessary for our legitimate interests.

Who we are

Findango (UK) Ltd (trading as Findango and referred to in this Privacy Policy as “Findango” or “we”). Findango (UK) Ltd is a provider of a platform to facilitate business to business property loan finance transactions between third party borrowers and lenders. Our company is headquartered in London, UK and we trade in the UK, though our Users may be global or multinational organisations. 

The information is as important to us as it is to you, and we take very seriously our responsibility to safeguard it and use it fairly and responsibly.

You acknowledge that we have no knowledge or control of the location in which our Users choose to access the Platform and as a result this privacy policy applies only to our use and processing of your data once it is uploaded by you to our systems. 

Where Findango gets your personal information

We collect your personal information from a range of sources:

• When you visit our Site
• When you agree to receive our Service or act as a point of contact for a User receiving our Service
• When you input data to our Platform

What information Findango collects

Personal data may include:

• Biographical information that you have supplied to us or to our Users.
• Location information, meaning data which reveals the geographic location of you and your device. We will only collect your location information where you have explicitly agreed to our doing so.
• Platform Metadata, which means information about the way in which our Platform is used and how it functions on your system. Metadata does not include any personal information about you. We collect metadata via Google Analytics in order to improve the usability and performance of our app.
• Password and other authorisation or validation data used by you to access the Platform or Site or upload material to the Platform.

Sharing information with third parties

We do not disclose any information about you to any third party for marketing, advertising or promotional purposes, unless you have given us express consent to do so or unless otherwise described in this Privacy Policy.

 We may share your personal information with:

• Our Users who have asked us to collect it on their behalf.
• Our partners, who provide us with IT and support services to help us manage and store information, and who may require such information for the performance of any contract we enter into with them.
• Our group companies, who may provide related or ancillary services.

We may also share your personal information in the following circumstances:

• If we believe that it is reasonably necessary to comply with a law, regulation or legal request.
• If we sell, transfer or otherwise share some or all of our assets in connection with a merger, acquisition, reorganization or sale of assets, or in the event of bankruptcy. We will endeavour to provide you with notice prior to the transfer of your personal information to the new entity.

Security

The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, for example by providing data encryption, we cannot guarantee the security of your data transmitted to our website or app. Any transmission is at your own risk. However, we take the privacy of your personal information very seriously and use a number of methods to try to keep your personal information secure from loss or unauthorized use or access when it is in our possession or control. These methods include reasonable physical, technical and organizational measures to restrict access to your personal information. For example, your personal information is encrypted when stored or transmitted by us.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website and/or apps, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Where required by applicable law, we will notify you of any loss of or unauthorized access to your personal information, and we will cooperate with the appropriate authorities to investigate such incidents.

International transfers of information

We are a UK company with a UK trade. Some of our service providers will be based in South Africa. We use “cloud-based” storage solutions. We will never process your data outside the UK or the European Economic Area except in strict compliance with the Data Protection Legislation, for example by ensuring that we have a contract with our service providers located outside the UK or EEA which incorporates standard contractual clauses dealing with data protection.

We take steps to try to ensure that your personal information is kept secure regardless of its location, in compliance with applicable laws. your consent to this Privacy Policy followed by your submission of personal information represents your agreement to that transfer.

Retention of your information

We retain your personal information for as long as it is necessary for us to provide the Service or for the purposes for which the personal information was gathered.

Your rights

Privacy legislation gives you the right to access all information we have about you. Findango being the processor of data will help our Users to service any data access request from you. If you want to review any data we might have on you, please contact the User that gave you access to our services and they will facilitate the data access request to us. 

You also have the right of erasure, meaning you can request data we hold on you to be deleted in certain circumstances. To do this please reach out to the User that gave you access to our services and they can make an official request to remove any data you have requested we remove. 

Compliance and Updates

Technologies, privacy laws and our way of doing business change from time to time, and so do your rights and expectations. To make sure we are up to speed, we make updates to this Privacy Policy from time to time. When we make those changes we will always publish the updated versions on our website here. 

We work with regulatory authorities to ensure that we are up to the standards set out. Your feedback is important to us and if you feel that we can improve please email us at contact@findango.loans.          

Your Assent 

When you use one of our services, or provide us with personal information in a survey or questionnaire, you will be asked to indicate that you have read and agreed to this Privacy Policy. Your use of our Platform is also subject to this Privacy Policy. In giving your assent to the terms of this privacy policy, you agree to:

• The collection and use of your personal information by Findango and the third parties described in this Privacy Policy
• The disclosure of your personal information to the third parties described in this Privacy Policy
• The transfer of your personal information to countries around the world, including outside the UK or the European Economic area, where such transfer is permitted by and in strict accordance with applicable data protection legislation.

Contact us

If you have any questions, comments or concerns about this Privacy Policy, or our approach to privacy generally, you can email us at contact@findango.loans or write to us at our registered office Salisbury House, London Wall, London EC2M 5PS.or the contact details given on the Site.