Collection and use of Personal Data
You can always visit our websites without informing us who you are or disclosing any information about yourself. We obtain Personal Data about you if you choose to provide it. This site allows you to contact us through our Contact Us form, Quick Start form, Apply Now page form, Become a Broker form, via email or when you make an application using the Service. Whether through the Contact Us form or sending an email using the email links contained in the web page, you may be providing us with your name, email address, phone number and any information you choose to include in the text of your message. For instance, if you send us an e-mail message requesting information about Boost Capital, we will use your e-mail address and other information you supply to respond to your request via email or via telephone.
We collect, use and keep the information we receive via our website to fulfil the visitor’s requests. We will use your information to respond to a request submitted by you, to provide the Service to you and to carry out our obligations from any contracts entered into between you and us; Contact you and provide you with information regarding Boost Capital and our products and services; Correspond with you; Comply with applicable laws, regulations and rules, and requests of governmental agencies.
We will not sell, rent or lease your Personal Data. We share your Personal Data with third parties only in the ways that are described in this Privacy Notice and with our business partners, suppliers and sub-contractors in order to provide you with our services and perform any contract we enter into with them or you. We may provide your Personal Data to companies that provide services to help us with our business activities such as to obtain credit reports from credit reference agencies or processing your transactions through financial institutions. These companies are authorised to use your Personal Data only as necessary to provide these services to us.
You agree that we have the right to share your Personal Data with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
Personal Data Boost Capital collects
If your business (“Customer”) apply for our Service, we will collect and process certain personal data about the following individuals associated with the Customer (referred as “Related Parties”):
- Yourself, such as where you are operating as a sole trader
- Individual members of a partnership
- Individual members of a co-ownership
- Individual directors, company secretaries or other equivalent individual office holders and beneficial owners of the company
- Guarantors and third-party security providers
- Individuals associated with the directors and beneficial owners of the business.
- Any employees, contractors, representatives, officers or agents of the business.
- Legal representatives and other individuals authorised to act on behalf of the business.
Boost Capital collects personal data directly from the Customer and Related Parties and also from other sources including those described below:
- Boost will check its own records for information about (i) any accounts belonging to the Customer or any associated businesses and (ii) the Customer’s shareholders who are beneficial owners of the businesses
- Boost Capital may carry out searches using credit reference agencies and financial crime prevention agencies for information relating to the business and Related Parties
- Boost Capital may search publicly available sources, such as media stories, for information relating to the business and Related Parties.
The categories of information that Boost Capital collects about the business and Related Parties include:
- Personal details (e.g. name, date of birth, identification information,)
- Contact details (e.g. phone number, email address, postal address, mobile number)
- Business-related details (e.g. relationship with the business or Related Parties, business information, information about any shareholdings, business contact details)
- Transactional details (e.g. information about services, requests, queries or complaints)
- Financial details (e.g. information about business accounts, financial history, information from credit reference agencies and fraud prevention agencies).
Some of the information that Boost Capital collects are special categories of personal data (also known as sensitive personal data). For example, the customer due diligence checks Boost Capital carries out may reveal information about criminal convictions or offences about customers and Related Parties. In addition, if incorrect information is provided or fraud is suspected, Boost Capital will record this. Boost Capital may also pass this information to financial crime prevention agencies where it may be accessed by law enforcement agencies globally. Where Boost Capital processes such sensitive personal data, it will usually do so, on the basis that it is necessary for reasons of substantial public interest or to establish, exercise or defend any legal claims. In any case, Boost Capital will carry out the processing in accordance with applicable laws.
Boost Capital may be required by law to collect certain personal data, or as a consequence of its contractual relationship with its customers. Failure to provide this information may prevent or delay the fulfilment of these obligations.
What Boost Capital uses personal data for and on what basis
Boost Capital must have a legal basis to process business and Related Parties’ personal data. The table below sets-out the purposes for which Boost Capital uses personal data about Customers and Related Parties, and its legal basis for doing so. Where Boost Capital is relying on a legitimate interest, these are also set-out below:
What Boost Capital uses personal data for
The legal basis for doing so
|Customer administration and management, including relationship management, and for account administration and management purposes|
|Transaction processing, monitoring and analysis activities to develop and manage Boost Capital’s products and services|
|Undertaking Customer due diligence checks for the prevention and detection of financial and other crimes and undertaking checks, including on Related Parties, in relation to identity verification, application checks, anti-money laundering, compliance and risk screening|
|Communicating with the Customer and Related Parties from time to time about products, services, events offered by Boost Capital and/or other members of the Boost Capital Group, and other communications such as research and insights, that may be of interest to the Customer and Related Parties. (See paragraph below on how to stop receiving communications of this nature)|
|Complying with legal obligations to which it is subject and co-operating with regulators and law enforcement bodies|
|Exercising its legal rights where it is necessary to do so, for example to protect Boost Capital against harm to its rights and property interests, to detect, prevent and respond to fraud or other violations of law, for legal and dispute management purposes, and for debt collection and recoveries purposes|
When Boost Capital processes Customer and Related Parties’ personal data to meet its legitimate interests, it puts in place robust safeguards to ensure that the Customer and Related Parties’ privacy is protected and to ensure that its legitimate interests do not override the Customer and Related Parties’ interests or fundamental rights and freedoms.
Boost Capital may contact the Customer’s guarantors and security providers in connection with any products and services provided to the Customer by Boost Capital.
Where necessary Boost Capital may provide Personal Data about the Customer and Related Parties:
- to other members of the Boost Capital Group, including internal service companies.
- to its suppliers and agents. Where Boost Capital engages with a supplier or agent to process Customer and Related Parties’ information on its behalf, it will undertake due diligence, monitoring and assurance activities to ensure that the information is appropriately protected, and contractual clauses will be agreed between the parties to ensure that data protection and confidentiality is maintained.
- to anyone as a result of any restructure, sale or acquisition of any Boost Capital Group member or to anyone to whom Boost Capital transfers or may transfer its rights.
- if Boost Capital is required, requested or permitted to do so by law, regulation, court order, or supervisory, regulatory or similar authority.
- for international payments where Boost Capital is required to send details of the payee and the beneficiary with the payment, and to overseas regulators and authorities in connection with their legitimate duties. Because Boost Capital operates as part of a global business, the recipients referred to above may be located outside the jurisdiction in which you are located (or in which Boost Capital provides the services).
Credit reference agencies and fraud prevention agencies
For some Customers, Boost Capital will request searches from credit reference agencies (CRAs) for information about (i) the Customer or Related Parties, (ii) any accounts belonging to the Customer or Related Parties. Boost Capital does this to assess creditworthiness and product suitability, check the identities of Customers and Related Parties, manage the Customer’s account, trace and recover debts and prevent criminal activity.
Boost Capital will also continue to exchange Customer and Related Parties’ information with credit reference agencies on an ongoing basis. Credit reference agencies will share Customer and Related Parties’ information with other organisations.
You can contact the CRAs currently operating in the UK. The information they hold may not be the same so you may consider contacting them all. They will charge you a small statutory fee. They are:
- CallCredit, Consumer Services Team, PO Box 491, Leeds, LS3 1WZ or call 0870 0601414
- Equifax, Credit File Advice Centre, PO Box 3001, Bradford, BD1 5US or call 0870 010 0583 or log on to www.econsumer.equifax.co.uk
- Experian, Consumer Help Service, PO Box 8000, Nottingham NG80 7WF or call 0844 4818000 or log on to www.experian.co.uk
The personal data Boost Capital collects from the Customer and Related Parties will be shared with fraud prevention agencies who will use it to prevent fraud and money laundering and to verify the identity of the relevant individuals. If fraud is detected, the relevant individuals could be refused certain services, finance or employment. Further details of how personal data will be used by Boost Capital and these fraud prevention agencies, and individuals’ data protection rights, can be obtained by contacting Boost Capital at the details below.
International transfer of personal data
We are part of a global group of companies and share infrastructure and functions across our business internationally. We may transfer your information to other countries, including those outside the European Economic Area, either for storage purposes or if we engage suppliers, sub-contractors or third-party data processors who are based or have operations overseas. We will ensure that appropriate safeguards are provided in order to confirm that the data transfers are subject to an adequate level of protection. These safeguards will comply with the applicable privacy laws.
Your rights over your personal data
You may, at any time:
- request access to certain personal data records we hold about you (a subject access request) (including receiving this as an electronic copy);
- update and correct any out-of-date or inaccurate personal data we hold about you;
- erase your personal data;
- lodge a complaint with the local data protection authority.
Please refer to the Contacting Us section below for further details on how to exercise these rights.
As is true of most websites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.
We may combine this automatically collected log information with other information we collect about you. We do this to improve marketing, analytics, or site functionality.
Data security and integrity
The security of your Personal Data is important to us. We take appropriate technical and organizational measures to safeguard the Personal Data submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our website, you can contact us at firstname.lastname@example.org.
Boost Capital will retain Customer Personal Data following closure of the Customer’s account(s) or following a transaction for a period of time, which will be calculated depending on the type of Personal Data, and the purposes for which it is held by Boost Capital. Boost Capital will only retain Customer Personal Data to enable Boost Capital:
- Maintain business records for analysis and/or audit purposes.
- Comply with record retention requirements under the law. (for example, as required under legislation concerning the prevention, detection and investigation of money laundering and terrorist financing).
- Defend or bring any existing or potential legal claims.
- Deal with any future complaints regarding the services Boost Capital has delivered.
The retention period is often linked to the amount of time available to bring a legal claim, which in many cases is six or seven years following closure of the Customer(‘s) accounts or following a transaction. Boost Capital will retain Customer Personal Data after this time if it is required to do so to comply with the law, if there are outstanding claims or complaints that will reasonably require Customer personal data to be retained, or for regulatory or technical reasons. Where Boost Capital retains this data it will continue to make sure that Related Parties’ privacy is protected.
You have the right at any time to ask us to stop processing your personal data for marketing purposes by contacting us at email@example.com.
Corporate recipients of any marketing communications may tell Boost Capital at any time if they wish to change their contact preferences for this purpose.
Merge, sell, assignment, transfer
Boost Capital may sell or buy any business or assets, in which case we will disclose your Personal Data to the prospective seller or buyer of such business or assets. If Boost Capital is sold or merges with another entity, or sells or otherwise assigns or transfers some or all of its assets, including the business of this website to a third party, the Personal Data that we have obtained from you via our sites will be one of the transferred assets. You will be notified via email and/or prominent notice on our website of any change in ownership or uses of your Personal Data, as well as any choices you may have regarding your Personal Data.
Changes to this Privacy Notice
Subject access requests should be submitted via the online Subject Access Request form www.onetrust.com. For any other type of request, please contact your Customer Relationship team in the first instance.
Boost Capital LTD
91-99 New London Road
Phone: +44 (0)01245 353 326
Boost Capital is committed to working with individuals to obtain a fair resolution of any complaint or concern about privacy. If, however, individuals believe that Boost Capital has not been able to assist with their complaint or concern, they have the right to make a complaint to a data protection authority. Details of the national data protection authorities within the EU are available on the European Commission website. UK residents can
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) here. (https://feedback-form.truste.com/watchdog/request)
Effective: May 25, 2018