- Who will hold your information?
- The information about you which we collect
2.1 The information about you which we will collect may include:
2.1.1. Personal details such as your name, date of birth, signature, marital status and nationality;
2.1.2 Contact details such as your address, email address, telephone numbers and fax numbers.
2.1.3 Details about a loan or credit application made by you or by a borrower with which you are connected (whether as a guarantor, director, partner, member, shareholder, beneficial owner or in some other capacity);
2.1.4 Information about your personal assets, liabilities, income, outgoings and related financial information such as bank account details relevant to lending decisions (whether made by us or by a lender or by a third party on behalf of a lender); and
2.1.5 Information to assist in the operation of our services including your IP address, operating system and browser type. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
2.2 We may also need to collect information about you to meet our legal obligations including under anti-money laundering regulations such as proof of identity, proof of address, recent bank statements, pay slips and financial accounts.
- Sources of the information we hold about you
3.1 We may receive information about you directly when you submit information to us in connection with a loan or credit application made by you or by a borrower with which you are connected for example when you complete a Personal Profile Questionnaire.
3.2 We may receive information about you directly when you submit information to us through our website for example by filling in forms on our website. We may also ask you for information when you report a problem with our website.
3.3 We may receive information about you when you submit information to us through an intermediary such as a broker or introducer in connection with a loan or credit application made by you or by a borrower with which you are connected.
3.5 If you contact us by email, telephone or in writing, we may keep a record of that communication and, if you submit personal data to us during that communication, for example your contact details and your interests in our services we will keep a record of that information.
3.6 If you meet us or one of our representatives at an event or visit one of our offices and provide personal data to us at that time, for example your contact details and your interests in our services we will keep a record of that information.
3.7 We may monitor or record communications with Zorin in which you take part and which are relevant to our business:
3.7.1 To ascertain or demonstrate the standards that are or ought to be achieved by our personnel for quality control and staff training purposes;
3.7.2 To ascertain our compliance with any regulatory or self-regulatory practices or procedures relevant to our business;
3.7.3 If so requested by order of the Court, regulatory body or law enforcement organisation or otherwise to prevent or detect a crime.
Any calls that are recorded will start with a message that the call will be recorded and the consent of the caller to that recording is deemed given by the caller choosing to continue with the call after hearing that message.
- How We Use Your Personal Data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we are considering whether or not to enter into a contract with you, including where we are evaluating the potential financing of a project with which you are connected, or where we are considering or negotiating the terms of that contract.
- Where we need to perform a contract we have entered into or are about to enter into with you, including a loan agreement or a guarantee agreement.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
- Purposes for which we hold and use your information
We may use your information for those purposes outlined below:
5.1. To record your details as a person interested in receiving services or information from us or from a lender for whom we act as facility agent;
5.2 To verify your identity and to respond to any query that you may raise with us;
5.3 To provide our services to you:
5.4 To verify the accuracy and completeness of the information you have provided by conducting independent checks and by conducting credit checks;
5.5 To determine your suitability to borrow from us or from a lender for whom we act as facility agent (or, if you are not the borrower, to determine your suitability to act as a guarantor for the borrower, or otherwise to determine the suitability of the borrower to borrow from us or from a lender for whom we act as facility agent):
5.6 To enter into and perform a contract with you including a loan agreement or a guarantee agreement;
5.7 To provide relevant information to you;
5.8 To manage our relationship with you and to administer and maintain our records;
5.9 To meet our legal obligations; and
5.10 To ensure that our service continues to be the most appropriate service for your needs and that content from our website is presented in the most effective manner for you and your computer.
5.11 We may use your data to provide you with information about those of our services which may be of interest to you and we may contact you about these by post or telephone. If you are an existing customer, we will only contact you by email or other electronic means with information about services similar to those which were the subject of a previous enquiry or contract with you. If you are a new customer we will contact you by email or other electronic means only if you have consented to this. If you no longer want us to use your data in this way, please use the ‘unsubscribe’ link on the email you have received or write to us at the address below.
5.12 Your information may be used by Zorin for the purpose of research and statistical analysis and internal customer service monitoring.
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
- Data Retention Periods
6.1 We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
6.2 To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
6.3. Zorin will store your personal information electronically until either a) the loan application is terminated (i.e. it does not proceed to drawdown) or b) all amounts owing to us (and any co-lending partner) under the terms of our loan agreement have been repaid and no dispute remains outstanding. This information will be deleted from our records after that time or after such longer period as we may be required to retain that information for legal or regulatory reasons (including under any then-applicable Money Laundering Regulations).
6.4 In some circumstances you can ask us to delete your data: see ‘Your Rights’ below for further information.
6.5 In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
- Sharing Information
We will share your personal information with third parties where required by law, where it is necessary to administer our relationship with you or where we have another legitimate interest in doing so.
7.1 We may share your personal data with the parties set out below for the purposes described above (‘Purposes for which we hold and use your information’):
7.1.1 Zorin may disclose information to its group companies in connection with the provision of our services to you;
7.1.3 Zorin may share your personal information with its solicitors who may use this information to determine your suitability to borrow from us or from a lender for whom we act as facility agent (or, if you are not the borrower, to determine your suitability to act as a guarantor for the borrower, or otherwise to determine the suitability of the borrower to borrow from us or from a lender for whom we act as facility agent).
7.1.5 We may disclose information to a Court, regulatory body or law enforcement agency;
7.1.6 We may share personal data with third party companies and organisations contracted by us to help supply, maintain or facilitate our website including IT support teams;
7.2 If any of these third parties will be located outside of the European Economic Area (‘EEA’) in a country which has not been determined by the European Commission to provide a similar or adequate level of protection for personal data to that provided by the EEA, then in order to provide that adequate protection for your personal data we will ensure that the relevant third party is contractually and legally obliged to provide a similar or adequate level of protection for personal data to that provided by the EEA, either by using the specific form of contract approved by the European Commission or (in the case of a data transfer to the US) by the third party having self-certified its compliance with the EU-U.S. Privacy Shield Framework as set out by the U.S. Department of Commerce so that it adheres to the Privacy Shield Principles regarding the collection, use, and retention of personal information transferred to it from the EEA.
- Keeping information up to date and secure
8.1 If any of the information that you have provided to Zorin changes, for example if you change your email address or other contact details, please let us know the correct details by sending an email to firstname.lastname@example.org or writing to us at the address below.
8.2 Zorin is committed to protecting the security of your personal information. We use a variety of security technologies and procedures to help protect your personal information from unauthorised access, use or disclosure. For example, we store the personal information you provide on computer systems with limited access and which are located in controlled facilities. If we transmit highly confidential information such as a credit card number over the Internet, we protect it through the use of encryption, such as the Secure Socket Layer (SSL) protocol.
8.3 As stated above, we have in place a level of security appropriate to the nature of the data and the harm that might result from a breach of security. However, all publicly accessible websites are susceptible to malicious practices, and we accept no liability if security is breached.
- Your rights
9.1 You have certain rights under data protection legislation in relation to the information that we hold about you. These rights include the rights set out below:
9.1.1 You are entitled to request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
9.1.2 You are entitled to request that Zorin stops using information about you for the purpose of direct marketing i.e. the communication to you by whatever means of any advertising or marketing material;
9.1.3 You are entitled to require us to ensure that no decision taken by or on behalf of Zorin which significantly affects you is based solely on the automated processing of your information, for the purpose of evaluating such matters as, for example, your creditworthiness, reliability or conduct.
9.1.4 You are entitled to require a correction of errors in the personal information held about you. We may need to verify the accuracy of the new data you provide to us, and if we disagree that information is inaccurate you are entitled to apply to ask the court for an order that such erroneous information be rectified, blocked, destroyed or erased. This enables you to have any incomplete or inaccurate data we hold about you corrected, though.
9.1.5 You are entitled to request the erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
9.1.6 You are entitled to object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
9.1.7 You are entitled to request a restriction of the processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
9.1.8 You are entitled to request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
9.2 You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
9.3 We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
9.4 We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
- 16 & under
We do not wish to collect any personal information from persons 16 or under. If you are under 16, please do not use our services and do not supply any information to us.
- Contact Details for Zorin