Privacy Policy

FND11 Ltd, trading as Funding11, is the data controller for personal data it holds.

This policy applies to personal data Funding11 processes about individuals connected with a business seeking or holding commercial finance, including directors, shareholders, guarantors, authorised representatives and beneficial owners, and to visitors to the Funding11 website.

Information about a company itself is not personal data and the rights in section 10 do not extend to it.

Assessing and arranging commercial finance. Performance of a contract, or steps taken prior to entering into one, and legitimate interests in assessing, arranging and administering commercial finance.

Submitting applications to lending institutions. Performance of a contract, or steps taken prior to entering into one, and legitimate interests.

Identity verification, fraud prevention, sanctions and anti-money laundering screening. Legitimate interests in preventing fraud and financial crime, and legal obligation where applicable.

Periodic reassessment of eligibility for alternative funding, including following a decline. Legitimate interests in administering an ongoing commercial relationship. This can be objected to at any time.

Communicating about commercial finance products and funding opportunities. Legitimate interests in communicating with existing and prospective business clients. This can be objected to at any time.

Recording calls and retaining communications. Legitimate interests in compliance, quality assurance, fraud prevention and dispute resolution.

Responding to complaints, enquiries and data rights requests. Legitimate interests, and legal obligation where applicable.

Meeting legal, regulatory, accounting and reporting obligations. Legal obligation.

Establishing, exercising or defending legal claims. Legitimate interests, and legal obligation where applicable.

Where processing relies on legitimate interests, Funding11 has assessed that those interests are not overridden by the interests or fundamental rights of the individuals concerned. Details of that assessment are available on request.

Lending institutions, for the purpose of assessing and arranging finance. A lending institution receiving personal data acts as a separate and independent data controller, applying its own retention periods, search policies and privacy notices. Funding11 is not responsible for that processing.

Credit reference and business information agencies, and fraud prevention agencies, where a lending institution or Funding11 carries out a check. A record of a search may be retained by the agency concerned.

Service providers and technology partners engaged to deliver Funding11's services, including customer relationship management systems, document storage, communication platforms, analytics, electronic signature and compliance tools. Where such a provider processes personal data on Funding11's behalf it does so under a written agreement and only on Funding11's instruction.

Professional advisers, including solicitors, accountants and insurers, where relevant.

Law enforcement agencies, regulators, courts, tax authorities and other competent authorities where Funding11 is required to disclose by law or where disclosure is otherwise permitted. Such disclosure does not require consent, and Funding11 may be unable to notify that a disclosure has been made where notification would prejudice an investigation or is prohibited.

A successor in title or acquirer, where Funding11's business or assets are transferred.

Funding11 does not sell personal data.

Personal data is held in encrypted, access-controlled storage located in the United Kingdom, in a jurisdiction the United Kingdom recognises as providing an adequate level of protection, or elsewhere under safeguards recognised under UK data protection law.

Client identity documents, bank statements and other client financial documentation are not provided to personnel outside the United Kingdom.

Funding11 uses administrative and research support located overseas. That access is restricted to administrative and research functions, is carried out under the Information Commissioner's Office International Data Transfer Agreement, and is subject to written confidentiality obligations.

The systems, platforms and providers used may change, and data may be migrated between them. Where that happens, the safeguards applied and the purposes of processing do not change.

Funding11 uses secure technology platforms to assist with document review, financial analysis, fraud detection, eligibility assessment and application preparation.

These tools assist with analysis. Funding11 does not take decisions producing legal or similarly significant effects based solely on automated processing. All commercial decisions and communications remain subject to human review.

Lending institutions operate their own automated decisioning systems. Those are the institution's own processes, carried out under its own policy and privacy notice.

Six years following the end of the commercial relationship. Longer only where a longer period is required by law, or where the information is relevant to an actual or reasonably anticipated dispute, claim, regulatory enquiry or investigation, in which case it is retained until that matter is concluded.

Funding11 determines which records it retains within those periods. It is not required to retain any particular record, note, message, call recording or working document, and records may be consolidated, archived or not carried across when systems change.

Where a business provides personal data relating to a director, shareholder, guarantor or other connected individual, it confirms that it is authorised to do so and that the individual has been informed that their information will be provided to Funding11 and to lending institutions.

Funding11 makes this policy available to those individuals on request and provides it directly where required to do so.

The Funding11 website uses analytics to understand how it is used. Where a tool on the website is described as anonymous, no name, contact detail or personal identifier is collected through it, and no individual visitor is identifiable from its records.

Cookie information is set out in the cookie notice on the website.

Individuals have the right to request a copy of the personal data Funding11 holds about them, to have inaccurate personal data corrected, to request erasure of personal data, to request restriction of processing, to object to processing carried out on the basis of legitimate interests including direct marketing, and to request data portability where applicable.

These rights apply to personal data and are subject to the exemptions and limitations in UK data protection law. They do not extend to information about a business itself.

No charge applies. Funding11 responds within one calendar month of receipt, and may extend that period by up to two further months where a request is complex or where several requests have been made, notifying the individual within the first month where it does so.

Where there is genuine doubt as to a requester's identity, or where clarification is needed as to the scope of a request, the period runs from the date the necessary information is received.

Requests should be sent to compliance@funding11.com, although a request made by any other means is also valid.

A complaint about the handling of personal data may be made to Funding11 using the contact details below, and to the Information Commissioner's Office, the UK supervisory authority for data protection, at ico.org.uk.

This policy is reviewed periodically. The version in force at the time personal data is processed is the version that applies to that processing. A copy of any earlier version is available on request.