Privacy Notice

1. Introduction

1.1 Buzz Capital (“Buzz, “We” “us”, “our”) takes the protection of your privacy and personal data seriously. The purpose of this Privacy Notice is to inform you about the types of information we gather about you when you visit the www.buzzcapital.co.uk website (the “Website”), provide us with information through other means and how else we may capture information about you and how we may use that information, whether we disclose it to anyone, and the choices you have regarding our use of, and your ability to correct, that information. By using the Website or any other means of contacting us either directly or via an intermediary, you consent to this Privacy Notice. If you do not accept the terms of this Privacy Notice, do not use the Website or provide information to us through other means.

1.2 Please note that, unless specified herein, the definitions used in this Privacy Notice are defined in the Terms and Conditions on the Website.

1.3 For the purpose of the Data Protection Act 2018 (the “Act”), the data controller is Buzz Capital.

1.4 ‘Buzz Capital’ refers to all companies in the Buzz Capital group, including parent, subsidiaries and associates. These include Buzz Capital Limited, Buzz Capital Services Limited, Buzz Capital A Limited, Buzz Capital Finance Limited and Buzz Capital Property Finance Limited.

2. Collecting data from you – when you make contact

2.1 By phone – We will capture information that you give us for our records and in order to deal with your enquiry and process it in accordance with our processing basis as set out below.

2.2 By email or website enquiry form – If you send us an email that is not encrypted any personal data within it may be at risk. We will capture and process the information in the email (including any application form) for our legitimate interest and legal purposes as set out below, and it may also be used to assist decision making and provision of any service or performance of any contract that we may enter into with you. When we send emails we encrypt some emails or their content in order to protect personal data.

2.3 By post – When we receive an enquiry or a paper application it will contain personal information for applicant(s) and possibly other parties in connection with the property(ies) or for funders.

3. Providing information to us on other people including via intermediaries

3.1 In providing information to us about other people you warrant that you have their permission to give us their data and that you have provided them with our Privacy Notice so that they are aware of the basis on which we will process their information. We store information provided to us in both electronic and paper-based systems.

4. Other parties we may obtain information from

4.1 We may obtain information from:

• People who introduce you to us or provide information to us on your behalf,
• Your professional advisers.

4.2 We may obtain information about you from other providers such as:

• credit reference agencies (see below),
• via google and other websearch tools,
• social media,
• other providers of public information services such as land registry.

4.3 We only do this when we are considering whether or not to offer you a loan or manage any loan offered, to meet any legal or regulatory obligations, or work with you as an investor or service provider.

5. Data we may collect and process

• your name, address, telephone numbers, email address(s), date of birth, place of birth, nationality, tax/residency status, passport/driving licence, employment, banking and financial details;
• demographic and lifestyle information;
• information we receive when making a decision about you, your loan or your application for such a loan or investment requirements;
• information that you provide by completing forms that we provide to you;
• details of the loan(s) or investments you have and have had with us and all transactions;
• details of when you contact us and when we contact you (e.g. copies of any correspondence and recordings of telephone calls);
• details of how you applied for your loan or investment, together with any other information (including where obtained from third parties) which we reasonably need to operate your loan or investment, make decisions about you or fulfil our legal or regulatory obligations;

• technical information via our website which will include information such as the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
• website information about your visit including the full Uniform Resource Locators (URL) clickstream to, through and from our Website (including date and time) 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;
• statistical information about your visit to the Website including the pages you visited and which browsers are used to visit the Website.

6. Senstive Data

6.1 We may capture sensitive data about you with regards to your or a related persons health if you advise of an issue that we may need to take into account in dealing with your loan or investment. We may retain this information where it would be in your best interests for us to do so or in order to protect us from a claim.

7. Basis of processing data and who we share your data with

7.1 Legitimate Interest

7.1.1 We will hold and process your data for our legitimate interests in order to:

• determine whether or not to offer a loan or provide an investment service;
• manage any loan advanced or investment made through to redemption;
• manage any relationship with intermediaries including a record of introductions, payments made and other relevant information appropriate to managing the relationship;
• manage the relationship with funders or anyone applying to become a funder and to maintain appropriate records relevant to that relationship;
• to manage business relationships with our professional advisers, contractors and third party providers and affiliates;
• share information where necessary with funders, our employees, professional advisers, contractors, agents, and third party providers, and anyone who may wish to acquire all or any part of our business or assets and their professional advisers. In the event an acquisition is made the data will be transferred to the new owner and you will be notified accordingly;
• share information with other companies in the same group and associated companies;
• carry out checks with fraud prevention and credit agencies and tracing agencies if required (see below);
• share information with your intermediary or financial adviser about your application or the performance of your loan or investment;
• share information with analytics, platform and search engine providers that assist us in the improvement and optimisation of the Website, including Lead Forensics and Google Analytics;
• carry out statistical analysis on our business, the products and services offered, the performance of products and services which may include but is not limited to breakdowns of geographic location, types of enquirers and customers, profiling of products and service performance.

7.2 Legal Purposes

7.2.1 We will hold and process your data for legal purposes in order to:

• Meet our legal and regulatory obligations;
• Help identify you and meet our anti-money laundering obligations;
• Supply information to any government body, regulatory authority, law enforcement agency as required and to credit and fraud prevention agencies.

7.3 Performance of a contract

7.3.1 We will hold and process your data in order to manage any proposed or actual contract with you in order to:

• carry out pre-contract processing in order to determine whether or not to enter into a contract with you;
• enter into and the performance of a contract including any servicing and performance related matters and meeting contractual obligations during the lifecycle of the contract;
• deal with termination of any contract including redemption of any loan or cashing in of any investment.

7.4 Consent

7.4.1 We will hold and process your data by consent for marketing purposes in order to keep you informed of:

• Our products and services and those of any group or related company that may be appropriate;
• Information contained in any newsletter we may issue;
• Products and services of any selected third parties where you have agreed to this.

7.4.2 We may also gather and analyse information on our marketing in order to understand and measure the effectiveness of it and to make improvements as a result.

7.4.3 You may opt out of marketing at any time by contacting us at info@buzzcapital.co.uk or clicking un-subscribe on any marketing email.

8. Retaining information

8.1 We will retain information for our legitimate interests, legal purposes and performance of a contract as follows:

• Loans advanced – up to 6 years after the loan has redeemed but may be longer where legal action has been taken or is pending to protect ourselves in the event of a claim and meet any legal or regulatory requirements;
• Investments entered into – up to 6 years after the investment has redeemed but may be longer where legal action has been taken or is pending to protect ourselves in the event of a claim and meet any legal or regulatory requirements;
• Enquiries and applications for loans not advanced or investments not made – up to 6 months from the date the enquiry or application is marked not proceeded with. This may be longer where a fraudulent application is made. We may also need to keep any anti-money laundering information gathered for a period of up to 5 years;
• We may also anonymise your data and retain it for use in statistical analysis to help us with our business planning.

8.2 Where you have consented to marketing, we will retain your contact information for marketing purposes until such time as consent is withdrawn.

9. Checking with Credit and Fraud Agencies

9.1 In order to process your application, we will perform credit and identity checks on you with one or more credit reference agencies (“CRAs”). To do this, we will supply your personal information to CRAs and they will give us information about you. This will include information from your credit application and about your financial situation and financial history. CRAs will supply to us both public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information. We will use this information to:

• Carry out identity checks on you:
• Assess your creditworthiness and whether you can afford to take the product;
• Verify the accuracy of the data you have provided to us;
• Help prevent criminal activity, fraud and money laundering;
• Manage your account(s); and
• Trace and recover debts.

9.2 We will continue to exchange information about you with CRAs while you have a relationship with us. We will also inform the CRAs about your settled accounts. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt. This information may be supplied to other organisations by CRAs.

9.3 When CRAs receive a search from us they will place a search footprint on your credit file that may be seen by other financial institutions. If we only carry out an identity check this will only leave a soft footprint on your credit file and will not impact your credit score.

9.4 If you are making a joint application or tell us that you have a spouse or financial associate, we will link your records together, so you should make sure you discuss this with them, and share with them this information, before lodging the application. CRAs will 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.

9.5 The identities of the CRAs, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRAs are explained in more detail at www.experian.co.uk/crain.

9.6 CRAIN is also accessible from each of the three CRAs – clicking on any of these three links will also take you to the same CRAIN document: Callcredit www.callcredit.co.uk/crain; Equifax www.equifax.co.uk/crain; Experian www.experian.co.uk/crain.

10. Where we store your data

10.1 All information is retained on our servers within the European Economic Area. Your information may be accessed by (or given to) our consultants and employees – and the third parties referred to above, located within the European Economic Area. Should we ever have a need to transfer your data outside of the EEA we will notify you and we will ensure we put appropriate safeguards in place.

11. Your rights

11.1 You have the right as an individual to request details on the information we hold on you and to ask us to correct any information which may be inaccurate. To exercise your right please contact us and ask for a Data Subject Access Request form.

11.2 You are also able to exercise your right to be forgotten. This does not mean we will have to automatically delete all information held on you as we may still need to keep appropriate information in order to meet our legal obligations and for our legitimate interests.

11.3 There are other rights which, due to the basis on which we process data, you may not always be able to exercise. These include:

• To restrict processing of your data;
• To provide your data in a portable format;
• To object to the processing of your data.

11.4 You might also wish to complain about the way in which we have processed your data. To exercise your rights or to make a complaint please contact us by email at hello@buzzcapital.co.uk.

11.5 You also have the right to make a complaint to the Information Commissioners Office. You can make a complaint to them via their website www.ico.org.uk or by calling them on 0303 123 1113.

12. Protection

12.1 We acknowledge your trust and are committed to protecting the information you provide us. Whilst we cannot guarantee the security of your information at all times, in order to prevent unauthorised access, maintain accuracy, and ensure proper use of information, we have employed physical, electronic, and managerial processes to safeguard and secure the information we collect and store online. Any information that you give us is protected by a password for added security. Within our Website, your information is stored in password-protected, limited-access servers.

13. Cookies

13.1 By using the Website with your browser settings adjusted to accept cookies you consent to our use of cookies on the Website, which include Google Analytics cookies. We may use Google Analytics or other similar cookies to collect information about how visitors use our Website, and we will use this information to improve the Website. These cookies collect information in an anonymous form, and such information includes the number of visitors to the Website, where visitors have come from before visiting the Website and the pages they visit. To learn more about what cookies are set on your computer as you browse the Internet and how to manage or delete them, visit www.allaboutcookies.org.

13.2 A cookie is a small piece of data that a website stores on your computer. Cookies allow your browser to remember some specific information which the web server can later retrieve and use. We do not use cookies to store any personal information that could be read or understood by others.

13.3 We use cookies primarily for administrative purposes, to improve your experience with our Website. We only use cookies to capture anonymous analytics to improve your experience of the Website and its performance. This includes compiling statistical information concerning, among other things, the frequency of use of our Website, the pages visited, and the length of each visit, as well as information about your computer, operating system, browser, language, and country.

14. Terms and Conditions

14.1 Use of the Website is subject to our Terms and Conditions – https://buzzcapital.co.uk/terms-and-conditions

15. Contact

If you have any questions or requests in relation to this Privacy Notice, please email hello@buzzcapital.co.uk.

16. Changes to our Privacy Notice

We may revise this Privacy Notice from time to time. You should check the Website from time to time to review the current Privacy Notice because it is legally binding on you.

17. Governing Law and Jurisdiction

This Privacy Notice is governed by and is to be construed in accordance with law of England & Wales. The courts of England shall have exclusive jurisdiction to settle any dispute arising out of or in connection with this Privacy Notice.