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At GapCap Limited we recognise and respect the privacy of all clients and visitors to our website. We collect, use and are responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation (GDPR) which applies across the European Union, including the United Kingdom and under any local legislation which implements or supplements the GDPR including in the UK, the Data Protection Act 2018. As a ‘controller’ & ‘processor’ of that personal information and for the purposes of those laws we will not keep or use your data for anything other than the reason(s) for which is was originally collected.

Where we refer to “GapCap”, “we” or “us” in this document we are referring to GapCap Limited and references to “you” means the person to whom this Privacy Policy is given.

How we source your personal information

The information we hold about you will be either from information you have supplied to us directly or which is published by you about you, i.e.by credit reference and fraud prevention agencies and professionals such as, bankers, brokers, valuers and agents with whom you may have had a business relationship.

In obtaining or storing information about you we may:

1. store and process information about you including on our computers and in any other way;
2. search your records at a credit reference or fraud prevention agency of our choice. Details of our searches may be kept by such agency and may be seen by other organisations that make searches with the agency;
3. monitor and/or record telephone conversations with you for training and/or security purposes;
4. seek and record any further information that we may require from any source, including banks, for any of the purposes set out below;
5. transfer such of the information that we may have to our financiers; to associates or persons acting on our behalf; to guarantors or indemnifiers and to businesses providing similar services to those of GapCap

This Privacy Policy provides up to date information about how we use your personal information and updates any previous information we have given you about our use of your personal information. We will update this Privacy Policy if we make any significant changes affecting how we use your personal information and we will contact you to let you know about the changes.

GapCap Limited Privacy Policy

What personal information do we use?

We use a variety of personal information depending on the products and services we provide to you (or to any connected company 1* or to your supplier 2*). For most products and services which we provide to you (or to any connected company) we need your name, address, date of birth, contact details (including email address and phone numbers), any other information to allow us to check your identity (including a copy of your identification documents (such as a passport or driving licence) and information about your credit history.

We may also need additional personal information such as financial information which may include your income, expenditure, assets and liabilities, credit history and credit scoring, details of bankruptcy or any county court judgements.

What we do with your information

We will use, analyse and assess your information for the following purposes:

1.considering any applications made by you, and helping us to make credit related decisions about you and/or your business;
2.financial risk assessment, preventing money laundering, fraud or other wrongdoing;
3.exchanging information with credit reference agencies for the prevention of fraud or any wrongdoing;
4.administering any funding facility, we have made/may make available to you;
5.making payments to you and/or your business;
6.recovering monies owed to us;
7.training, product and statistical analysis;
8.development of new products
9.protecting our interests (including the provision of the information to third parties retained by us for them to conduct their services for us).

We take appropriate security measures to ensure that your personal information is kept secure, is not lost or unlawfully accessed. Your data is only made available to those who have a genuine business need to do and is only processed by personnel authorised for this purpose.

We will notify you and any appropriate regulators of any data security breaches where we are legally required to do so.

1 A company is connected with another company if either the same person has control of both companies or that person and a person connected with him together have control of both companies or if a group of two or more persons has control of each company and the group consists of the same person if one member is replaced with another with whom he is connected.

2 A supplier is a person, company or organisation that sells or supplies goods or services to you their customer.

Visits to our website

GapCap Limited Privacy Policy

We collect certain information or data about you when you visit our website.

Cookies

Cookies are very small files that downloads to your computer or device when you visit a website. They are used to remember when your computer or device accesses our website. Some cookies form an essential part of ensuring our website works correctly. We also use cookies to collect information about browsing, this includes the pages viewed and time spent on parts of the site. We do not use cookies to collect or record information on your name or other personal details.

Google Analytics

When you visit www.gapcap.co.uk we use a third-party service, Google Analytics, to collect standard internet log information and details of visitors’ behaviour patterns. We do this to find out information such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and we do not allow Google to make, any attempt to find out the identities of those visiting our website.

Your privacy rights under GDPR

Under GDPR you have a number of important rights which you can exercise free of charge.

1.The right to be informed
2.The right of access
3.The right to rectification
4.The right to erasure
5.The right to restrict processing
6.The right to data portability
7.The right to object
8.Rights in relation to automated decision making and profiling

For further information in relation to these rights, including the circumstances in which they apply, go to the Information Commissioners Office (ICO) on individual’s rights under GDPR https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation- gdpr/individual-rights/

If you have any questions about how we use your personal information and to whom we may give information about you, by contacting our data controllers, Alex Fenton. You have a legal right to these details and can also obtain a copy of the information we may hold about them by writing to Alex Fenton at the address shown at the bottom of this Notice.

Our Address: GapCap Ltd, 8th Floor Mindspace, 9 Appold Street, London, EC2A 2AP