Privacy and Cookies (Newable Business Finance)
This policy sets out how Newable uses and protects an individual’s personal data, including data from our website.
Newable is the Data Controller for personal data about clients, event attendees, newsletter subscribers or when sending marketing material which you expect to receive or have consented to receive.
Newable collects different types of personal data about our clients to:
• provide the services for which you have consented or contracted to receive
• market Newable’s products and services
• process recruitment records
Newable will also collect anonymized website statistics using cookies, so that Newable can improve our website.
2. Your Rights
As an individual whose personal data is processed by Newable, you have the following rights:
• the right to be informed (which is the purpose of this Privacy Notice)
• the right to access the data Newable holds about you
• the right to object to direct marketing (by contacting Newable at the address below, or via email)
• the right to object to processing carried out on the basis of legitimate interests (to undertake the service that you would expect or in line with a contract)
• the right to erasure (in some circumstances, however, not if Newable has a legal obligation to retain it)
• the right to have your data restricted or blocked from processing
The GDPR includes a right for individuals to have inaccurate personal data rectified, or completed if it is incomplete.
An individual can make a request for rectification verbally or in writing to the Data Protection Officer (DPO), Gavin Holland. Newable has one calendar month to respond to a request. Newable will confirm to you that inaccurate personal data has been rectified or completed if it is inaccurate.
To exercise any of these rights, write or email your request to the DPO. You will be required to provide sufficient information for Newable to satisfactorily identify you.
3. Contacting You
Newable will only contact you if you’ve asked to be contacted, or if your contact details are featured in a third-party email list, which you’ve consented to be added to. You have the ability to opt-out of being contacted by Newable, at any point.
You will receive telephone or emails from Newable, if you have contacted us using an online contact form.
Newable also engages in business to business marketing activity.
4. Storing Your Data
Newable will store your data securely
Newable will continue to invest in high-quality security and to do our utmost to protect user data and privacy, using the latest security technology.
Newable contractors will only ever process your data on our behalf.
Newable will ensure that the contractors we use in connection with the running of the website and services (for example, hosting providers), are subject to strict contractual obligations.
They are only able to process data on our behalf and in accordance with our principles and instructions, and not for any other purposes.
5. Checking Your and Your Business Partner’s Records
When you apply to Newable and its subsidiaries to establish a business relationship, Newable and its subsidiaries will check the following records concerning you and your business partners:
- Newable’s and its subsidiaries’ own records
- Newable’s business partner’s records
- Records at fraud prevention agencies (FPAs)
· In order to process your application we will supply your personal information to credit reference agencies (CRAs) and they will give us information about you, such as about your financial history. We do this to assess creditworthiness and product suitability, check your identity, manage your account, trace and recover debts and prevent criminal activity.
· We will also continue to exchange information about you with CRAs on an ongoing basis, including about your settled accounts and any debts not fully repaid on time. CRAs will share your information with other organisations. Your data will also be linked to the data of your spouse, any joint applicants or other financial associates.
· Personal and business records at Credit Reference Agencies (CRAs). When CRAs receive a search from Newable this will place a search footprint on your business credit file that may be seen by other lenders. CRAs will supply to Newable both public (including the electoral register) and shared credit and fraud prevention information.
The identities of the CRAs, and the ways in which they use and share personal information, are explained in more detail at www.equifax.co.uk/crain and www.experian.co.uk/crain [
Newable and its subsidiaries may also undertake periodic searches at CRAs and FPAs in order to manage your account.
The personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance, or employment. Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights, can be found by clicking here
6. Use of Your Information
Newable may also use your information to:
· Communicate with the Secretary of State for Business, Energy and industrial Strategy (the Guarantor) and any of its agents and auditors (including the British Business Bank plc (BBB), any affiliate of the BBB and any of their advisers, agents or contractors) (Guarantor Related Parties) (GRP)
Your information may also be used by the Guarantor and any GRP:
· For analytical and administrative purposes (including to keep a record of the types of borrowers and/or applicants applying for an Enterprise Finance Guarantee (EFG) Scheme facility)
· To contact Newable in connection with the EFG Scheme
- To make enquiries concerning an EFG application
· To take up references about you and your business
· To give information about you and your business to above third parties, or to any official involved in running or monitoring the EFG Scheme
- To evaluate the effectiveness of the EFG Scheme
Above records will be retained by the relevant recipient for a minimum of 10 years after the initial drawdown date of such a scheme facility.
7. Changes to this Policy
Newable will publish any changes to this policy
Newable will collect anonymized website statistics using cookies.
A cookie is a small file of letters and numbers which websites may send to a computer to make a user’s experience of a website better.
• collect anonymized data about the number of visitors to pages, so we can improve the website and ensure that content is easy to find and engaging.
• to remember your preferences, for text sizes, for example. Again, this information is processed anonymously.
For information on controlling cookies visit http://www.aboutcookies.org
9. Anonymized Statistics
Newable collects anonymous website usage data
The data we collect may include a user’s device and browser type, operating system, the pages or features of our website a user browsed or spent time on, the links on our website a user clicked, and other statistics.
Newable uses this information to analyse the performance of our website in order to improve and enhance our website, by expanding its features and functionality to meet our users’ needs.
Newable will only share anonymized data
Newable will only share anonymized aggregate statistics about our users with our advertisers.
Newable will follow strict procedures to store client data securely
10. Security Procedures
The GDPR means that Newable will follow strict security procedures when storing and disclosing information which you have given us, to prevent unauthorised access.
Newable will not sell, trade or rent your personal information.
Newable may provide aggregate statistics about our customers, sales, traffic patterns and related site information to reputable third-party vendors, but these statistics will never include personally identifying information.
Any data processors with access to your data when providing services on our behalf are subject to contractual restrictions to ensure that your data is protected, and not used independently by such third party.
Newable reserves the right to access and disclose individually identifiable information to comply with applicable laws and lawful government requests, to operate our systems properly and to protect both ourselves and our users.
11. Legal Information under the GDPR
For the purposes of the GDPR, Gavin Holland is Newable’s Data Protection Officer who can be contacted at Newable Limited 140 Aldersgate Street Barbican London EC1A 4HY, UK. Alternatively email firstname.lastname@example.org.
Any queries regarding Newable’s use of data and data policies should be addressed to the DPO. The company registration number is 1653116.
12. Your Right to Complain
You have the right to complain to the Information Commissioner’s Office at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, if you think that there is a problem with the way that Newable handles your data.