Privacy Policy

We're committed to privacy protection

This Privacy Policy was last updated on 18th September 2020

Zorin Finance Limited and its group of companies (the ‘Zorin Group’) is committed to privacy protection. Our privacy policy is set out below and tells you how we use and protect the personal data that you provide to us or that we collect about you, in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act 2018 and any other applicable laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (Data Protection Legislation). This includes when you use our web site, when we provide services to you, when you make a loan or credit application to us, and when you ask us for information. It also tells you about your privacy rights and how the law protects you; but nothing in this privacy policy limits your statutory rights in relation to your personal data.

It is important that you read this privacy policy together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

  1. Who will hold your information?

The Zorin Group is made up of different legal entities. This privacy policy is issued on behalf of the Zorin Group, so when we mention “Zorin”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company (or companies) in the Zorin Group responsible for processing your data. We will let you know which entity (or entitles) in the Zorin Group will be the controller for your data when you enter into a transaction with us.  Zorin Finance Limited, a company registered in England under number 07514913 whose registered office is at 1 Knightsbridge Green, London, England, SW1X 7NE, is the owner and data controller of this web site.

  1. The information about you which we collect

2.1 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

2.1.1. Identity Data such as your first name, last name, title, gender, date of birth, signature, marital status, nationality and identity document information including passport details;

2.1.2 Contact Data such as your address, email address, telephone numbers and fax number;

2.1.3 Transaction Data such as details about payments to and from you and other details of services you have ordered from us 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 Financial Data such as payment card details, credit score, credit history and information about your personal assets, liabilities, income, outgoings and related financial information such as pay slips and 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);

2.1.5 Technical Data such as your IP address, operating system and platform, browser type and version, time zone setting and location, and other technology on the devices you use to access this website;

2.1.6 Employment and Business Data such as occupation, employee identification number, professional history and experience, curriculum vitae (CV), shareholdings and other business interests and trust information;

2.1.7 Usage Data includes information about how you use our website and services; and

2.1.8 Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.2.2 We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you (or that we are facilitating on your behalf), and you fail to provide that data when requested, we (or the relevant contractual party) may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

  1. Sources of the information we hold about you

3.1 We use different methods to collect data from and about you including through:

3.1.1 Direct Interactions. You may give us your Identity, Contact, Financial and Employment and Business Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide 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;
  • apply for our services;
  • submit information to us through our website for example by filling in forms on our website;
  • give us feedback or contact us by any means including by email, telephone or in writing;
  • meet us or one of our representatives at an event or visit one of our offices; or
  • request marketing to be sent to you.

3.1.2 Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy (http://www.zorinfinance.com/home/cookies/) for further details.

3.1.3 Third parties or publicly available sources. We may receive information about you from various third parties as set out below:

  • Contact, Financial, Transaction and Employment and Business Data from intermediaries 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;
  • Contact, Financial and Transaction Data from our lending partners;
  • Identity, Contact, Financial and Transaction Data from credit reference agencies and fraud prevention agencies;
  • Identity, Contact, Financial and Employment and Business Data from any person with whom you are submitting a joint application for loan or credit facilities; and
  • Identity, Contact, Financial Data and Employment and Business Data from third parties you are connected with, including your guarantor.

3.2 We may monitor or record communications with Zorin in which you take part and which are relevant to our business:

3.2.1 to ascertain or demonstrate the standards that are or ought to be achieved by our personnel for quality control and staff training purposes;

3.2.2 to ascertain our compliance with any regulatory or self-regulatory practices or procedures relevant to our business; or

3.2.3 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.

  1. 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 or where we are facilitating (on your behalf) the provision of loan or funding (or similar arrangements) from our lending partners.
  • 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.

  1. Purposes for which we hold and use your information

We have set out in the table in Schedule 1, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table in Schedule 1.

Marketing

We may use your data to provide you with information about those of our services which we think 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.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time. 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.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see (http://www.zorinfinance.com/home/cookies/ ).

Change of purpose

We will only use your personal data 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 data 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.

  1. Data Retention Periods

6.1 We will only retain your personal data for as long as reasonably 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 data for the periods stated in our retention policy (a copy of which you can request from us by contacting us).  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.

  1. Sharing Information

We will share your personal data 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 in paragraph 5 above (‘Purposes for which we hold and use your information’) and as set out in the table in Schedule 1:

7.1.1 Zorin may disclose your personal data to its group companies;

7.1.2 Zorin may share your personal data with lenders for whom it acts as facility agent or loan servicer. Any such lender will act as data controller and will process your personal data for its own purposes in accordance with its own privacy policy which will be provided to you by the relevant lender at that time;

7.1.3 we may disclose your personal data to third parties who will or may provide services to you or to us related to our own services to you (‘Third Party Service Providers’) including any solicitors, valuers and surveyors, credit reference agencies, anti-money laundering service providers, payment processing and cash management service providers and company director service providers. All our Third Party Service Providers are required to take appropriate security measures to protect your personal information. We do not allow our Third Party Service Providers to use your personal data for their own purposes. We only permit them to process your personal data for our specified purposes and in accordance with our instructions, which are all as described in this privacy policy;

7.1.4 we may disclose your personal data to a Court, regulatory body or law enforcement agency; and

7.1.5 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 We may share your personal data with other third parties (including our advisors and any prospective purchasers and their advisors) in the context of a possible sale, merger, restructuring or financing of or investment in our company or any of our businesses  or the sale, participation in, transfer of or creation of security over any of the loans in which we have an interest). In this event we will take appropriate measures to ensure that the security of your personal data continues to be ensured in accordance with this Privacy Policy and applicable data protection legislation. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

7.3  Some of our third parties with whom we share your personal data are based outside the UK and European Economic Area (‘EEA’) so their processing of your personal data will involve a transfer outside the UK and EEA. Wherever we transfer your personal data outside the UK and EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will transfer your personal data to countries that have been determined by the European Commission and/or the appropriate UK body to provide a similar or adequate level of protection for personal data to that provided by the EEA; or
  • Where we use certain service providers, in order to provide that adequate protection for your personal data, we may use specific contracts approved by the European Commission and/or the appropriate UK body which 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.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK and EEA.

  1. Keeping information up to date and secure

8.1 It is important that the personal data we hold about you is accurate and current. If any of the personal data that you have provided to Zorin changes during your relationship with us, for example if you change your email address or other contact details, please let us know the correct details by sending an email to privacy@zorinfinance.com or writing to us at the address below.

8.2 Zorin is committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorised access, use or disclosure. For example, we store the personal data 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 cannot guarantee that our security will not be breached.

  1. Your rights

9.1 Under certain circumstances, 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. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 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.

9.1.9 You are entitled to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

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.

  1. Children

This website is not intended for children and we do not knowingly collect data relating to children.

  1. Changes to this Privacy Policy

We keep our privacy policy under regular review. If we change our privacy policy we will post the changes on this page and we may place notices on other pages of the website, so that you may be aware of the information we collect and how we use it at all times.

  1. Contact Details for Zorin

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you would like to contact us with any queries or comments regarding our privacy policy, or to exercise any of your rights set out above, please send an email to: privacy@zorinfinance.com or write to: Zorin Finance, 1 Knightsbridge Green, London SW1X 7QA.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

SCHEDULE 1

PURPOSES FOR WHICH WE HOLD AND USE YOUR INFORMATION

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer (with Zorin or with one of our lending partners) (a) Identity

(b) Contact

Performance of a contract with you
To process and deliver your order / application / account including:

(a) Verify your identity;

(b) Manage payments, fees and charges

(c) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Employment and Business

(f) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to manage payments made to and from you and to recover debts due to us)

(c) Necessary to comply with a legal obligation

To verify the accuracy and completeness of the information you have provided by conducting independent checks and by conducting credit checks (a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Employment and Business

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

(c) Necessary to comply with a legal obligation

To determine your suitability to borrow from us or from a lender for whom we act as 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 agent) (a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Employment and Business

(a) Performance of a contract with you

(b) Necessary for our legitimate interests and those of the third party lender (to enable you to purchase services from us or the lender for whom we act as agent)

Disclosure to our lending partners for whom we act as agent for the purpose of providing you with a loan (a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Employment and Business

(a) Performance of a contract with you

(b) Necessary for the legitimate interests of the third party lender (to enable you to purchase services from the lender for whom we act as agent)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

 

(a) Identity

(b) Contact

(c) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity

(b) Contact

(c) Technical

(d) Usage

 

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity

(b) Contact

(c) Usage

(d) Marketing and Communications

(e) Technical

 

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, services, marketing, customer relationships and experiences (a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about services that may be of interest to you (a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Marketing and Communications

 

Necessary for our legitimate interests (to develop our products/services and grow our business)

 

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