Privacy notice

Privacy Notice

Your privacy matters to us and we ensure that we comply with the General Data Protection Regulation and Data Protection Act 2018 when storing or processing your data.

It’s important to us that you understand which data we collect, and how we use it, so that you can make informed decisions about providing your data to us. This privacy notice (also sometimes referred to as a “Fair Processing Notice”) has been written to help you to do that.

In this notice “we” and “us” refer to Liberis Ltd. You can find details of our registered address, as well as how to contact us with questions regarding data protection or privacy, at the end of this notice.

Many of the individuals about whom we collect personal data provide it to us as representatives of a company that they own or that they are engaged by.  References to “your business”, “your account”, “your application”, “your enquiry” and other similar terms below, are deemed to include references to the business, account, application or enquiry of the entity that you represent, as applicable.

The data we collect

You’re free to browse our website without providing us with any personal information. Please review the section below on our use of Cookies, as these are stored on your computer or other device if you continue to use our website without taking any action to remove or block Cookies.

Data you provide directly to us 

We process all personal data that you provide to us, including all data provided: when  you use our website to request further information about our products or services; when you apply (online or otherwise) for one of our products; or, thereafter, in connection with the performance of any contract with you. Such data could include the items included in the list below (where the data relates to you as an individual) and will include all other information provided to us by you.

Data we will collect indirectly, or request from third parties

We collect a variety of data about you from third parties.  This includes the data listed below, and may include other data that we notify you about from time to time.

How we use your data

Our lawful basis for processing your data

We always ensure that we have a fair and legal basis for processing your data. Below we have set out our legal bases for processing your data at various stages in your journey with us. You can find out more about the various lawful bases for processing on the ICO website if this terminology is unclear.

When you make an application or enquire about one of our products (on your own behalf or on behalf of your business) we, so we have a  legitimate interest in using your personal data in order to assess your, or your business’s, suitability for the product, to process your application and to respond.

In the event that you complete only part of the application process or fail to submit the application completely (but having provided us with your contact details as a clear demonstration of interest to form a relationship with us) we will try to make contact with you to help you complete your application. We have a legitimate interest in following up with you in this way, to ensure that those people who are interested in using our products are enabled to apply.

Should you give us explicit permission to provide your data to other organisations who may provide you with details of other products that may interest you, our legal basis for doing this is consent.  We may, from time to time, ask for your consent for other uses of your personal information and, where we do so, this will be the legal basis on which we rely for such uses.

We process a wide variety of data, some of which will be personal data, for the ongoing management of your account, to provide you with updates and remain in contact with you, and for all other activities directly relating to our serving you and your business throughout the duration of the contract between us and you or your business. Where the contract is with you directly, our legal basis for such processing is performance of a contract with the data subject.  Where our contract is with your business our legal basis is legitimate interest, and our legitimate interest is the performance of a contract with your business.

Categories of Data Purposes of Processing
Your business name

Our products are for businesses, not individuals, and so this is the most important piece of information for us. We’ll need this to provide you with an accurate quote, to provide you with a contract, and to make sure we can contact you regarding the products or services you express an interest in. If you don’t complete your application online, we’ll try to reach you to see if you need any further help, and we’ll offer you the opportunity not to be contacted again.

Information regarding the industry or sector in which your business operates

We will use information regarding the sector your business operates in to help us understand your business and the way it operates, as well as to ensure that we offer our products and services responsibly. We may also use this information to ensure we offer you the best pricing for your business.

Details about your business’ financial revenues.

We’ll use your revenue to help assess your eligibility for our products, and to decide on the right amount or pricing that we should offer to you.

If we enter into a contract with you and/or your business for one of our products, we may need this information to perform that contract.

Personal information of directors/shareholders/Persons of Significant Control of your Limited company or, in the case of sole traders and partnerships, the proprietor(s) of your business:

  • Name
  • Address
  • Date of Birth
  • Home Ownership
  • Identity Documents

We’ll use this information to undertake checks for the purposes of preventing fraud and money laundering, and to verify the identity of your business’ directors before we provide any products or services to your business.

If you provide us with personal information relating to a third party, you must notify them about this and direct them to read this Privacy Notice.

We’ll also use the address you’ve provided to us to contact you via post for any matters relating to an application for our products in respect of the business or for the performance of the resulting contract that we enter into with you and/or your business. We may write to you in future with offers for similar products provided by us.

Email address

We’ll ask you for your email address so that we may provide you with a link to electronically sign your contract with us. We may also use your email address to keep you updated regarding the status of your application. If you do not complete your application having provided us with your email address, we may contact you to try and assist you with completing the application process and also to send you monthly statements should you take out one of our products.

Business phone number

We’ll use the phone number that you provide to contact you regarding your application, and if you do not complete your application having provided us with your phone number we may contact you to try and assist you with completing the application process.

We may use your phone number to contact you about the performance of any contracts that we enter into with you or your business.

Intended use of funds

We need to record and assess your intended use of funds for the purposes of preventing fraud, money laundering and crime. We may also use details regarding your intended use of funds to aid our decision making on your eligibility for our products.

Bank account details

We will need your bank account details in order to provide you with funds. We may also ask you for additional documentation regarding your bank account so that we can verify your ownership of the account, and to verify your identity.

Bank Statements

We may ask you for copies of bank statements during your application process to help us verify your business’ revenues, and to confirm your eligibility for our products.

Open Banking authorisation

We may ask you for an electronic authorisation to connect to your bank and retrieve information using Open Banking. We will use this information during your application process to help us verify your business’ revenues, and to confirm your eligibility for our products.

VAT information

We may request that you provide us with an up to date statement of your VAT returns. We will use this information to help us determine your eligibility for our products.

Publicly Accessible Information

We may review information regarding your business and its directors that is freely available in the public domain; for example media coverage, your public website and business social media accounts, and any industry specific review or registration information.

Additional information

Whilst we have made every endeavour to provide an explicit list of all the data that we will collect, depending on the circumstances of your business we may from time to time request additional information from you during our processing of your application that are unique to your circumstances. Should we require additional information from you, we will inform you of the type and purpose of this at the time.

Data we collected indirectly or from third parties 

To make your application process as smooth as possible, to fulfil our legal and regulatory obligations, and to perform any contract that we enter into with you or your business, we will obtain additional data about you and your business from third parties.

Categories of Data Source of Data Purpose of processing

Credit history. Identity details.In both cases relating to you, your business, and its directors

Regulated credit bureaux, such as Equifax of Experian

We use this information to understand whether our products are affordable and suitable for you and your business, and to verify the identities of your business’ directors.

Financial transaction details that have been processed through your card terminal from your processor

Your payment processor

We use this to verify the affordability of our products for you or your business, to decide on the right price to offer you, and to provide you with an estimate of the duration of repayments.If contract with us for one of our products, we will use this information to perform the contract.

Various data

Fraud prevention agencies

We will use this for the prevention of fraud and money laundering.

Company registration information, and published accounts

Companies House

We will use this to verify that your business is correctly registered, and to help with our affordability checks by reviewing your published accounts.  This information is part of a public record.

Company registration information, and published accounts

The device that you use to access our website

We will collect technical information during your visit to this website to help us detect and resolve problems on our website. This information includes such information as your IP address, browser (including its version), and the type of device that you are using.

Landlord References

Previous or existing business landlords

We will use these references to verify that you and your business do not have outstanding liabilities or other concerns that would affect your eligibility for our products.

Land Registration Details

Land Registry

We will use this information to help identify your, and your business’s, current assets when reviewing your eligibility for our products. This information is part of a public record. This applies to England, Wales and Scotland.

Sharing data with third parties

In the process of providing you with a quote, in reviewing your application for one of our products, and in performing the contracts that we enter into with you, we may share your data with third parties. Details of these third parties are below.

• We’d share your details with Credit Reference Agencies if you apply for one of our products. Should you require further information regarding the use of data by Credit Reference Agencies in the UK, they have provided a shared document regarding their use of personal data – you can find it here: https://www.equifax.co.uk/crain.html

• We will share your information with Fraud Prevention agencies, and we (or they) may also allow law enforcement agencies to access and use this personal data to detect, investigate, and prevent crime.

• If your details were provided to us by a third party (such as a financial broker, or via a referral website) then we may provide updates regarding the status of your application back to them.

• We share your information with payment processors that process financial transactions on your behalf.

• We use cloud computing providers to store your data, and to help us process your application efficiently.

• We may use mailing houses to send you marketing or account information. To do this we would need to provide them with your name and address at a minimum.

• We use a third party help and support system to help us respond to your questions quickly when you’re using our website, your data are shared here only when you request assistance.

• We may use third party contact centres to help us contact you by phone, and we would need to pass your information to them to enable them to reach you. They will additionally record the information that you provide to them and pass it back to us.

• We may use third party operational fulfilment centres to process some parts of your application.

• We use cloud based electronic signature providers during our application process, we will provide all details required to produce your contract to these providers in order to provide you with this service.

• If our business (or the majority of our company assets) is acquired by another party, your information will be part of the transfer of assets.

• If we sell or buy any business or assets, we may share your data with the prospective buyer or seller.

• We share your business name and contact details with other organisations that may offer you services of interest to you – but only if you explicitly provide us with permission to do so.

We also disclose your data in the following circumstances:

Service Providers

We work with a third party service provider who provides multi-touch attribution reporting and other services for us. This third party may have access to, or process Personal Data or Client Data as part of providing those services for us. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality of such information.

Service providers include:

Fospha; 

Translation & Innovation Hub, Imperial College White City Campus, 80 Wood Lane, London W12 0BZ

Non-Personally Identifiable Information

We may make non-personally-identifiable information available to third parties for various purposes. This data maybe automatically-collected and would be analysed to create an aggregated view of the data, ensure the reported information was anonymous.

We may also disclose information to third parties if you consent to us doing so.

Retention of your data

We’ll keep your data only for as long as we need to – that time period may be different in different circumstances. Here are our most common scenarios:

We’ll keep records of any financial transactions, and details regarding the information that you provided to us while making an application for one of our products, for a minimum of 7 years from the end of our relationship with you. We need to do this so that we can respond to any complaints or disputes.

We’ll keep the information that’s needed to provide you with the service that you’ve requested for as long as it takes us to provide the services and for 7 years from termination of the contract for provision of the services.

If you’ve asked us not to use your details for marketing purposes, we will need to keep some details to make sure our systems and processes reflect your preferences.

In addition, we will retain any data about you which we need in order to comply with our legal obligations.

Consequences of processing

Should you choose not to provide us with your personal data, we will not be able to assess your eligibility for one of our products, and we will be unable to enter into a contract with you.

If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services and financing you have requested, or we may stop providing existing services to you.

A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you. If you have any questions about this, please contact us – you’ll find all of our details in the “Contacting us” section of this notice.

Your rights

Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:

• access to your personal data and to certain other supplementary information that this Policy is already designed to address

• require Us to correct any mistakes in your information which We hold

• require the erasure of personal data concerning you in certain situations

• receive the personal data concerning you which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations

• object at any time to processing of personal data concerning you for direct marketing

• object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you

• object in certain other situations to our continued processing of your personal data

• otherwise restrict our processing of your personal data in certain circumstances

claim compensation for damages caused by our breach of any data protection laws.

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.

Automated decisions

As part of the processing of your personal data, decisions may be made by automated means.

We may automatically decide that you pose a fraud or money laundering risk or if our processing reveals your behaviour to be consistent with that of known fraudsters or money launderers; or is inconsistent with your previous submissions; or you appear to have deliberately hidden your true identity.

We also make automated decisions based on the information that you provide, and that we gather from third parties, as part of your application to determine your financial profile. We may use automated decisions to provide you with a price reflecting your profile. The outcome of these automated decisions may mean that we do not approve your application for one of our products, or that our pricing is adjusted based on the information we have.

You have rights in relation to automated decision making: if you want to know more please contact us.

Data transfers

Whenever we, or anyone we share your data with, transfer your personal data outside of the European Economic Area, we impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the European Economic Area. We may also require the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing.

Data security

The security of your information is important to us and we will do our best to protect your data.

Unfortunately, the transmission of information via the internet is not completely secure and we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk.

Once you provide the information to us, we store this information on our secure servers and we have implemented reasonable administrative, technical, and physical security measures to protect against the unauthorised access, destruction or alteration of your information based on its sensitivity.

Our use of cookies

We use cookies to help provide you a great experience when using our website. A cookie is a small text file that is stored on your computer (or whichever device you use to access this website) that is unique to you, to help us tell you apart from other visitors when you move between pages, or when you come back.

We use a variety of different cookies for different reasons, and you can find details of these below:

Strictly necessary cookies. These are cookies that allow our website to function. Without using cookies such as this, it’s not possible to remember who you are from one page to the next, and we couldn’t allow you to get a quote, or to apply online, for example.

Performance cookies. These are cookies that we use to help us improve the experience of our customers who visit our website, as well as allowing us to remember information that you provided to us last time you visited.

Some of these cookies are for the purposes of analytics and are set using third party software to help us monitor our website traffic. For example – we use Google Analytics for this purpose.

These cookies may, in aggregate, tell us how many of our visitors would fall in to certain broad categories (age, gender, categories of interest) – but this information is not linked to any individual.

We won’t pass these data to any third parties in a way that would allow them to identify visitors personally, however we may combine these data with other information that you later supply to us (for example when you request a quote or apply online) in order to make sure our communications are as relevant to you as possible.

To find out more about the information that Google captures about you, as well as how to update your preferences with them, please visit their site here: https://myaccount.google.com/intro/privacy

You can opt-out of Google Analytics by using their browser add-on here: https://tools.google.com/dlpage/gaoptout

Liberis.co.uk also uses 3rd party vendor re-marketing tracking cookies, including the Google AdWords tracking cookie. This means we may continue to show ads to you across the internet, specifically on the Google Display Network (GDN). As always we respect your privacy and are not collecting any identifiable information through the use of Google’s or any other 3rd party remarketing system.

The third-party vendors, including Google, whose services we use – will place cookies on web browsers in order to serve ads based on past visits to our website. Third party vendors, including Google, use cookies to serve ads based on a user’s prior visits to your website. This allows us to make special offers and continue to market our services to those who have shown interest in our service.

Should you like to opt out of Google’s use of cookies for this kind of service, then you can do so here.

User experience cookies. We use a service provided by MixPanel, Smartlook and VWO to collect information such as heatmaps, form analytics and visitor recordings. We use this service to help us improve our online services; specifically, we use this to look for usability or accessibility issues or unexpected behaviour on our website, to allow us to proactively help you if you have problems when using our website, and to identify user experience changes that would help you, or future customers, to use our website more easily.

To review the privacy policy of MixPanel, as well as their approach to compliance and security, please visit their site here: https://mixpanel.com/legal/privacy-overview/ To opt out of MixPanel across all websites (not just those provided by Liberis), please visit this link:  https://mixpanel.com/optout/

To review the Privacy Policy of Smartlook, as well as their approach to compliance and security, please visit their site here: https://www.smartlook.com/privacy/ To opt out of Smartlook across all websites (not just those provided by Liberis), please visit this link: https://www.smartlook.com/opt-out/

To review the Privacy Policy of VWO, as well as their approach to compliance and security, please visit their site here: https://vwo.com/privacy-policy/   To opt out of VWO across all websites (not just those provided by Liberis), please visit this link: https://vwo.com/privacy-policy/

Children

Our products are not for children and to qualify, you must be over eighteen (18) years of age. You must make sure the details provided by you on registration or at any time are correct and complete. You must inform us immediately of any changes to the information that you provided when registering by updating your personal details.

Changes to this privacy notice

We may amend this notice from time to time; should amendments be made they will be posted to our website. This privacy notice was last updated 23/05/2019.

Contacting us

Should you wish to contact us with any questions or concerns you may have regarding our privacy notice, to request any amendments to the data we hold about you, or to exercise any of your other rights listed in this notice, you can contact us using any of the following methods:

Email

You can contact us via email using the following address: dataprotection@liberis.co.uk

Phone

You can call us using this number: 0208 626 2517

Lines are open from 08:30 – 18:00 Monday to Friday.

Post

You can write to us at the following address:

Data Protection

Liberis Ltd

3rd Floor, Glen House

Glenthorne Road

London

W6 0NG