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Our privacy policy and terms of business.

Privacy Policy

Who we are

Clever Commercial Finance Ltd, 625035, is an independent Commercial Finance Broker based at Shell Store, Canary Drive, Skylon Park, Hereford, HR2 6SR. We act as a broker for our customers. Clever Commercial Finance Ltd is an appointed representative of AFS Compliance Ltd, which is Authorised and Regulated by the Financial Conduct Authority. FRN 625035.

What is the purpose of this document?

Synergy Commercial Finance Limited is the controller and is responsible for your personal data (collectively referred to as "Clever Commercial Finance Ltd", "we", "us" or "our" in this privacy notice). This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

You must read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 14th June 2018, and historic versions can be obtained by contacting us at gdpr@afsuk.com.

The data protection law in the UK changed on 25 May 2018. This privacy notice sets out your rights under the new laws.

The personal data we hold about you must be accurate and up to date. Please keep us informed if your personal data changes during your relationship with us.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you, which we have grouped as follows:

•Identity data: includes first name, maiden name, last name, marital status, title, date of birth, gender, passport (copy), driving licence (copy) and utility bills (copy).

•Contact Data: includes residential address, billing address, email address and telephone numbers.

•Financial Data: includes bank details, details of your income and outgoings, and net worth statements.

•Transaction Data: includes details about payments to and from you and other details of products and services you have purchased from us.

•Marketing and Communications Data: includes your preferences in receiving marketing from our third parties and us, and your communication preferences.

We may also collect, store and use the following "Special Categories" of more sensitive personal information:

Information about your health, including medical conditions, particularly where you are classified as a vulnerable individual as a result of your medical condition.

We also collect, use, and share Aggregated Data, such as statistical or demographic data, for any purpose. Aggregated Data may be derived from your personal data, but is not considered personal data in law, as this data does not directly or indirectly reveal your identity.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel the service you have with us, but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you, including:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you apply for our services either directly or via our web page, or request marketing to be sent to you.

• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources including Contact, Financial and Transaction Data from providers of Business information such as Credit Safe, Experian or Companies House, based inside or outside the EU, and Introducers and other businesses with which we have a trading relationship.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

1. Consent: the individual has given clear consent for you to process their personal data for a specific purpose.

2. Contract: the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract.

3. Legal obligation: the processing is necessary for you to comply with the law (not including contractual obligations).

4. Public task: the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law.

5. Legitimate interests: the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual's personal data which overrides those legitimate interests.

We will process your personal information for the following reasons:

•to find the best source of finance based on your circumstances;

•to undertake credit checks for the purposes of finding the most suitable finance product;

•to confirm your affordability for the financial requirement we are seeking finance for;

•to comply with our anti-money laundering and know your client requirements; and to meet our regulatory responsibilities.

Automated Decision Making

Automated decision-making occurs when an electronic system uses personal information to decide without human intervention. We are allowed to use automated decision-making in the following circumstances:

•where we have notified you of the decision and given you 21 days to request a reconsideration;

•where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights; or

•in limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.

Many of our funders use auto-scoring technology to underwrite deals. You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

Why might we share your information with third parties?

We will share your personal information with third parties where required by law, necessary to administer the contractual relationship with you, or where we have another legitimate interest in doing so.

"Third parties" include third-party service providers (including contractors and designated agents) and other entities within our group. The following third-party service providers process personal information about you for the following purposes:

•the most suitable funders on our panel (a full list of which is available by contacting gdpr@afsuk.com).

•Our IT hosting and maintenance, this information is located on servers within the European Union.

•AFS Compliance Limited to meet our regulatory obligations to our Principal Firm.

•Credit reference agencies for the purposes of ascertaining your financial status.

•Regulatory bodies such as the Financial Conduct Authority for the purposes of meeting our regulatory obligations.

•Other members of our group where needed to process your application.

•Fraud prevention agencies, where we are required to do so.

•Third-party product providers, where you have given us your prior consent to do so.

How long do we keep your information?

We will retain your personal information only for as long as necessary to fulfil the purposes for which we collected it, including satisfying any legal, accounting, or reporting requirements. 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 requirements.

In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

International transfers

We do not transfer your personal data outside the European Economic Area (EEA).

What are your rights?

Under certain circumstances, by law, you have the right to:

•Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

•Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

•Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us to continue processing it.

•Object to the processing of your personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground.

•Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information.

•Request the transfer of your personal information to another party.

•Withdraw consent: In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact gdpr@afsuk.com.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact marc@clevercommercial.co.uk.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your access request is clearly unfounded or excessive.

If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law, you can complain to the Information Commissioner's Office (ICO).

Our Data Protection Officer is Marc Turner, and you can contact him at marc@clevercommercial.co.uk.

Terms of Business

Introduction

This website is provided and operated by Clever Commercial Finance Limited. The copyright in this website and its content belongs to Clever Commercial Finance Limited.

Clever Commercial Finance Limited makes every effort to ensure that the information provided on its website is accurate. However, Clever Commercial Finance Limited cannot guarantee this, and accepts no liability for any information or advice given via its website.

Clever Commercial Finance Limited excludes all liability to the fullest extent permitted by law to you or a third party for any loss or damage of any kind resulting from the use of or the inability to use any information on this website, loss or corruption of data due to computer viruses or otherwise in respect of the use of the website, and howsoever caused.

Any information found on this website is for guidance only, is not intended to constitute a contract, and may change without notice. Nothing on this website will be deemed to constitute an offer to contract. Reasonable care is taken to ensure that the information contained on this website is accurate. We cannot guarantee the accuracy of the information on this website (including these terms and conditions) and reserve the right to change it at any time without notice. You must check these terms and conditions for changes each time you intend to use this website.

By accessing any page of any website operated by Clever Commercial Finance Limited, you are deemed to have read, understood and agreed to be legally bound by the conditions of use set out below each time you access such website.

Copyright

Clever Commercial Finance Limited's website and its contents are protected by copyright. You may view or download for private purposes. Still, you may not otherwise or for any commercial purpose use, reproduce, copy or transmit any part of this site or publish without obtaining the prior written consent of Clever Commercial Finance Limited.

Viruses

Whilst Clever Commercial Finance Limited makes reasonable attempts to exclude viruses from this site, it cannot guarantee such exclusion and no liability is accepted for viruses. It is your responsibility to check all materials for possible viruses before downloading from this website for any purpose.

You are advised to take all appropriate safeguards before downloading information from this site.

Links

This website may contain links to other websites operated and controlled by parties other than Clever Commercial Finance Limited.

These links are provided to enhance the interest of other featured content. They are not intended to signify that Clever Commercial Finance Limited endorses or otherwise has any responsibility for the content of the linked website. Clever Commercial Finance Limited therefore do not take responsibility for nor assume any liability for the contents of other websites or home pages which are linked to Clever Commercial Finance Limited web pages.

Governing Law

This Site is intended for UK residents only and only in relation to their activities within the UK. The information on this Site may not be accurate or relevant in relation to activities outside the UK.

These terms and conditions and your use of this website are governed exclusively by English law, and any disputes arising from or in connection with these terms and conditions and your use of this website shall be subject to the exclusive jurisdiction of the courts of England and Wales.