Privacy Policy

1. Introduction

We are committed to safeguarding the privacy of our website visitors and service users.

This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.

We use cookies on our website. By using our website, you consent to our use of cookies. We will notify you of this when you visit our website.

In this policy, “we“, “us” and “our” refer to Primary Finance Ltd and our data controller(s). For more information about us, see Section 13.

In this policy, “you”, “yours”, where relevant refer to you, anyone handling your investment account on your behalf (including but not limited to trustees, executors or attorneys under a Power of Attorney) and proposed contributors to your investment in Primary Finance HPP PLC (“PLC”) as stated in your Grow Your Savings or Home Financing application. Where you, or the contributors are a company, this reference may include any directors, partners, majority or controlling shareholders, receivers, liquidators, executors, loan providers or investors of or to that company.

Any reference to “law” or “laws” in this policy includes all local, national and directly applicable supra-national laws as amended, extended or re-enacted from time to time and shall include all subordinate laws made from time to time under them and all orders, notices, codes of practice and guidance made under them.

A reference to “data protection law(s)” is a reference to all applicable data protection and privacy legislation in force from time to time in the UK including the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and shall include all subordinate laws made from time to time under them and all orders, notices, codes of practice and guidance made under them.

Business accounts” and “Business numbers” refer to any official social media account or phone number used by Primary Finance Ltd as well as any personal social media accounts or phone numbers used by any of our officers in the course of business.

This Privacy Policy overrides and supersedes any previous versions provided to you.

2. How we use your personal data

In this section we have set out:

  • the general categories of personal data that we may process;
  • in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
  • the purposes for which we may process personal data; and
  • the legal bases of the processing as provided by the UK GDPR

We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and The legal basis for this processing is consent OR our legitimate interests, namely monitoring and improving our website and services.

We may process your account data (“account data“). The account data may include your name and email address. The source of the account data is information provided by you on our website or via direct communications with us. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

We may process your information included in your personal profile on our website (“profile data“). The profile data may include your name, address, telephone number, email address, gender, date of birth, relationship status, educational details and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

We may process your personal data that are provided in the course of the use of our services (“service data“). The service data may include your name; address; telephone number; email address; gender; date of birth; relationship status; Official ID including but not limited to any, numbers, dates, addresses stated therein and such ID documents may include but are not limited to: passport, driving license; Biometric Residence Permit; photo ID; a video recording of yourself to prove your identity; educational details; account transactions and communications and where relevant sensitive information such as: credit reference data, financial crime data, financial health details, nationality and legal proceedings; employment details; employer; job title or role; bank and other payment details; details of existing credit agreements and outgoings; and any other information that you supply to us that enables us to provide our services. The source of the service data is information provided by you on our website or via direct communications with The service data may be processed for the purposes of: operating our website; providing our services; ensuring the security of our website and services; maintaining back-ups of our databases; improving as well as analysing the quality and efficiency of our products and services; determining your eligibility for certain credit awards; monitoring statistics and making models based on such statistics to analyse and showcase the performance of our business to others (in this case your data will be anonymised) and complying with any laws or regulations to which Primary Finance Ltd is subject and communicating with you. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

We may process information that you post for publication on our website or through our services (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and services to you. The legal basis for this processing is consent.

We may process information contained in any correspondence between you and our staff (“customer care data”). This information may include but is not limited to: recordings of video and phone calls on any platform conducted using our business numbers/accounts on such platforms; messages received by our business accounts on any and all social media or electronic platforms; emails etc. The customer care data may be processed for the purposes of improving our customer care services, training our staff in regards to the same and handling disputes, legal or otherwise, based on such correspondence. The legal basis for this processing is consent OR our legitimate interests, namely the proper management of our business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

We may process information relating to our customer relationships, including customer contact information (“customer relationship data“). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is information provided to us by you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is consent OR our legitimate interests, namely the proper management of our customer relationships.

We may process information relating to transactions, including purchases of goods and services that you enter into with us and/or through our website (“transaction data“). The transaction data may include your contact details, your card details and the transaction details. The source of the transaction data is you and/or our payment services provider. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and/or our legitimate interests, namely the proper administration of our website and business.

We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

In addition to the specific purposes for which we may process your personal data set out in this Section, we may also process any of your personal data where such processing is necessary for compliance with any legal obligations to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Please do not supply any other person’s personal information to us unless we prompt you to do so and we strongly recommend that you notify the said person about this privacy policy before sharing their information with us.

See Appendix 1, 2 and 3 at the end of this page for more information about how we may use your data.

3. Providing your personal data to others

We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

We may disclose your personal data to credit reference and fraud prevention agencies such as TransUnion, HooYu and Equifax for purposes including but not limited to:

  • conducting background identity checks
  • conducting credit checks and detecting
  • helping to investigate and prevent fraud
  • anti-money laundering
  • any other types of financial crime

More information about the companies’ activities are available in these Credit Reference Agency/Privacy Notices listed below:

We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

In addition to the disclosures of personal data set out in this Section, we may disclose your personal data where such disclosure is necessary for compliance with legal or regulatory obligations to which we are subject, or in order to protect your vital interests or the vital interests of another natural person or persons. This includes sharing data to any regulators or government agencies conducting inquiries into our business or any law enforcement agencies seeking to use our information to detect or prevent any crime. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4. How we store your data safely

Secure document transfer and digital form submission may be handled by our outsource provider MyDocSafe and are subject to the MyDocSafe’s data processing agreement as well as the associated terms of service and acceptable use policy.

We may also elect to use other secure platforms such as Microsoft Outlook’s One Drive, Google (Sheets, Docs, Drive etc.), Amazon Web Services (AWS) and other such platforms to host your data. You can find more information about Microsoft, AWS and Google’s Privacy and Security Policies using these links here:

Whenever we decide to use another platform to host your data, we will mention such changes in an updated version of this policy at the earliest reasonable opportunity.

5. International transfers of your personal data

In this section, we provide information about the circumstances in which your personal data may be transferred to countries outside the UK and the European Economic Area (EEA).

We may transfer your data to entities situated in the USA or other countries currently not covered by an adequacy decision for any of the purposes listed in this policy. Transfers to these countries will be protected by appropriate safeguards, mainly through the use of Standard Contractual Clauses adopted or approved by the ICO, copies of which can be obtained from here.

You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the We cannot prevent the use (or misuse) of such personal data by others.

6. Retaining and deleting personal data

This section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

We will retain your personal data for a minimum period of 2 years following the date on which we receive it, and for a maximum period of 100 years following the same date.

Notwithstanding the other provisions of this section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

7. Amendments

We may update this policy from time to time by publishing a new version on our website.

You should check this page occasionally to ensure you are happy with any changes to this policy.

We may notify you of significant changes to this policy by email or any other contact method we have from you.

8. Your rights

In this Section, we have summarised the rights that you have under data protection Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

In light of the above, contents of this section should therefore not be construed as legal advice. You should seek external independent legal advice before making any decisions based on the information in this policy.

Your principal rights under data protection law are:

  • the right to access;
  • the right to rectification;
  • the right to erasure;
  • the right to restrict processing;
  • the right to object to processing;
  • the right to data portability;
  • the right to complain to a supervisory authority; and
  • the right to withdraw consent

You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable You can access your personal data by requesting it from us in writing.

You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

In some circumstances you have the right to the erasure of your personal data without undue Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; for reasons of important public interest; or to comply with any laws or regulations to which we are subject.

You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this

You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

To the extent that the legal basis for our processing of your personal data is:

  • consent; or
  • that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with the ICO.

To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

You may exercise any of your rights in relation to your personal data by written notice to us.

9. About cookies

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

10. Cookies that we use

We use cookies for the following purposes:

  • authentication – we may use cookies to identify you when you visit our website and as you navigate our website;
  • status – we may use cookies to help us to determine if you are logged into our website;
  • personalisation – we may use cookies to store information about your preferences and to personalise the website for you;
  • security – we may use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;
  • advertising – we may use cookies to help us to display advertisements that will be relevant to you;
  • analysis – we may use cookies to help us to analyse the use and performance of our website and services; and
  • cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.

11. Cookies used by our service providers

Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

We may use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://policies.google.com/privacy.

Personal data you enter into our website when subscribing to our mailing list is handled by our mailing list services provider, Sendinblue. You can find out more about how Sendinblue processes your data in line with our requests here.

12. Managing cookies

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

Blocking all cookies will have a negative impact upon the usability of many websites.

If you block cookies, you will not be able to use all the features on our website.

For a more detailed description of what our cookies are and what they do with your data, kindly refer to the cookies policy that can be found on our website.

13. Our details 

This website is owned and operated by Primary Finance Ltd.

We are registered in England and Wales under registration number 10347817, and our registered office is at Kemp House, 124, City Road, London, England, EC1V 2NX.

Our principal place of business is at Mirror Works Workspace, Office 3.07, 12 Marshgate Lane, London, E15 2NH.

You can contact us:

  • by post, to the postal address given for our principle place of business above;
  • using our website contact form;
  • by telephone, on any contact number published on our website from time to time; or
  • by email, using any email address published on our website from time to time.

14. How to complain

If you have any concerns about our use of your personal information, you can make a complaint to our Data Protection Officer:

You are also entitled to complain to the ICO if you believe we have processed your data unlawfully. The ICO’s contact details can be found below:

The ICO’s address:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk

APPENDIX 1:

EXAMPLES OF HOW WE MAY USE YOUR DATA: INVESTOR ONBOARDING AND MANAGEMENT.

 

  1. As part of our investor onboarding and management procedure, we may process your data in order to comply with the following regulations:
    1. Proceeds of Crime Act 2002;
    2. Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017;
    3. Terrorism Act 2000;
    4. Sanctions and Anti-Money Laundering Act 2018.
  1. We will update our policy at the earliest reasonable opportunity if Primary Finance Ltd at any point in the future becomes subject to any additional laws and regulations that may affect how we process your data. For the avoidance of doubt, when you agree to subscribe to our services, you also further consent to the processing of your data in order to comply with newly introduced as well as current laws and regulations in force regardless of whether or not such laws are mentioned in this policy.
  2. These are examples of some of the ways that your data may be processed during our investment onboarding and management procedure:
    1. Checking for Source of Funds by:
      1. Analysing funds coming into and out of your bank account;
      2. Assessing general affordability based on monthly income;
      3. Performing general due diligence in the case where investments into PLC are done by way of a loan to you from a third party;
      4. Analysing a video sent by you to us to confirm your identity;
      5. Examining documents relating to any sale of assets you declare to us when such a sale contributes significantly to your investment in PLC;
      6. Processing any other documents, correspondence or information we receive from you in response to any queries we ask you regarding proof of source of funds.
  1. Collecting and processing such data may also result in decisions being made by Primary Finance Ltd in regards to your application e.g choosing to make queries about your source of funds, delaying your application in order to analyse documents you send us in relation to such queries, rejecting your application where Primary Finance Ltd feels that there is a high risk of money laundering or fraud taking place, accept your application etc.
  2. Note that this list is not exhaustive and is amenable to change in the future.

APPENDIX 2:

EXAMPLES OF HOW WE USE YOUR DATA: CUSTOMER CARE, TRAINING AND DISPUTE MANAGEMENT.

 

  1. As previously mentioned, correspondence with you through various mediums may be stored by Primary Finance Ltd for future use during internal training programs. Such trainings may include:
    1. Analysing recorded phone/video calls with you;
    2. Looking through message/email threads and other correspondences with you to identify ways in which we can improve our customer care service.
  2. We may also create statistics or models based on correspondence we enter into with you to analyse the efficiency and quality of our products and services.
    1. Such statistics may also be shared internally and externally (including for marketing our products and services) where they may aid us in pursuing our legitimate interests as stated in this policy. In the case where these statistics are to be shared externally, your data will be anonymised.
  3. This data may also be used in the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
  4. Additionally, this data may be used where necessary to process any customer care complaints and any other disputes that may arise from such data in relation to our officers.
  5. Note that this list is not exhaustive and is amenable to change in the future.

APPENDIX 3:

EXAMPLES OF HOW WE MAY USE YOUR DATA: DATA AND BUSINESS ANALYTICS.

 

  1. In order to further improve how Primary Finance Ltd operates from a business and operational perspective, our tech team may use your data in order to create models, analyse statistics, generate reports and to learn more about how Primary Finance Ltd operates.
  2. Examples of such data might include:
    1. How much you have invested in PLC;
    2. How long you have been a customer with Primary Finance Ltd;
    3. How many successful referrals you have made;
    4. What are the most common questions asked by you and other customers through email;
    5. How many calls we have had with you;
    6. How many emails/texts we have exchanged with you;
  3. Note that this list is not exhaustive and is amenable to change in the future.
  4. This data, after anonymisation, may also be presented to our shareholders, directors, prospective investors and other external parties where necessary to pursue our legitimate interest as stated in this Privacy Policy.
You can request a copy of our full privacy policy using the contact form on this website.
All content on this site is protected under the UK and international copyright laws. No part of this site may be copied, reproduced, distributed, redistributed, modified displayed or performed without prior written consent by Primary Finance Ltd. This site is provided as an informational and contact resource by Primary Finance Ltd. The site is provided on an "as is" basis. Primary Finance Ltd makes no express or implied warranties of any kind relating to the provision of information or service on or by this site. Primary Finance Ltd will not be liable for any damages of any kind arising from the use or misuse of this site or any of the information contained within it. We reserve the right to make changes to this site, disclaimers, and terms and conditions at any time.
Registered Office Primary Finance Ltd, 124 City Road, London EC1V 2NX