Privacy Policy
Version 4 - 1st June 2022
1. Introduction
We are HS Capital Ventures Limited, and we are the data controller in respect of your personal data. This policy explains when and why we collect personal data, how this information is used, the conditions under which it may be disclosed to others, and how it is kept secure.
This policy explains how we will use the personal data that you provide to us when you apply for finance via an application or a broker, or that we have obtained about you through our use of your information when you make such an application and, where applicable, when you enter into a finance agreement with us.
Where this policy refers to "we," "our," or "us," unless mentioned otherwise, it’s referring to HS Capital Ventures Limited. Where this policy refers to "you," it’s referring to the person applying for finance.
2. What Personal Data We Collect and How We Collect It
The personal data you provide to us may include:
- Name
- Date of birth
- Residential address and address history
- Contact details such as email address and telephone numbers
- Financial information
- Employment details
- Security property details
- Assets and liabilities
- Device identifiers such as IP addresses
We may also receive personal data from credit reference and fraud prevention agencies. If you fail to provide us with any mandatory information that we request, we will not be able to proceed with the credit reference and fraud prevention checks, and subsequently, we will not be able to consider your application.
3. How We Use Your Personal Data
We use your data for the following purposes and under the following legal bases:
- Performance of a contract : To manage, administer, and take decisions regarding your agreement(s) with us, including verifying your identity, assessing your application, and providing account management services.
- Legitimate interests : For marketing activities, assessing service quality, and staff training.
- Compliance with a legal obligation : To comply with legal and regulatory responsibilities, including fraud prevention, credit reference checks, and compliance with legal obligations related to vulnerable individuals.
4. Use by Credit Reference and Fraud Prevention Agencies
We will perform credit and identity checks with one or more credit reference agencies (CRAs). They provide information on your financial situation and credit history. CRAs will place a search footprint on your credit file, which may be seen by other lenders.
We will use this information to:
- Assess your creditworthiness
- Verify the accuracy of your data
- Prevent fraud and money laundering
- Manage your account
- Trace and recover debts
CRAs will continue to exchange information about you while you have a relationship with us. If you do not repay your debt in full and on time, CRAs will record the outstanding amount, which may be supplied to other organizations. If you make a joint application or declare a financial associate, your records may be linked.
5. Automated Decisions
Your personal data may be used for automated decision-making, such as credit scoring. This involves assessing credit risk based on various factors and assigning a total credit score.
Fraud prevention checks may result in an automated decision that you pose a fraud, credit, or money laundering risk if:
- Your behavior is consistent with known fraudsters or high-risk borrowers
- You have provided inconsistent or misleading information
- We conclude that approving finance would not be responsible
6. Use by Third Parties
We may disclose your information to:
- Other corporate entities within our group for internal processes such as audits
- Credit reference and fraud prevention agencies
- Government authorities and law enforcement agencies when required by law
- Brokers to assist in administering your application
- Third-party debt/asset recovery agencies
- Any third party to whom we sell your debt (you will be notified in such cases)
- Third-party service providers, such as IT, database hosting, and communication fulfillment providers
- Courts and legal authorities if necessary
- Any third party involved in the restructuring, sale, or acquisition of our business or assets
These third parties may share your information with us, which we will use in accordance with this policy. Where required, they will be acting as data controllers, and we recommend reviewing their privacy policies.
7. Data Storage and Transfers
We store your personal data on servers within the United Kingdom. If data is transferred outside the UK or the European Economic Area (EEA), we will ensure appropriate safeguards are in place.
Whenever fraud prevention or credit reference agencies transfer your personal data outside the EEA, they impose contractual obligations on recipients to ensure data protection to the required standard.
8. Retention of Your Personal Data
We retain personal data for different periods, depending on its purpose and legal obligations:
- Fraud prevention agencies may hold your data for up to 6 years
- Credit reference agencies retain account information for 6 years after account closure
- Legal obligations or ongoing claims may require extended retention
We may hold your information for longer or shorter periods in certain cases, such as legal requirements or your request for data erasure.
9. Marketing
We may send marketing information to you about contract renewals and similar products or services. You have the right to opt out at any time.
10. Your Rights
Under data protection laws, you have the following rights:
- To be informed about the processing of your data
- To object to processing and automated decisions
- To request data erasure or restriction
- To correct or update your data
- To request access to your data
- To transfer your data to another provider
- To file a complaint with the Information Commissioner’s Office (ICO)
For more information or to exercise your rights, please contact us.
11. Changes to This Policy
We may update this policy from time to time. Any changes will be communicated to you in writing and will take effect 7 days after notification. If you do not agree with the updates, you must notify us immediately and cease using our services.