Privacy Notice – Scope
We take your privacy seriously and are committed to maintaining the trust and confidence of our clients, visitors to our website and subscribers to our newsletter. Maintaining the security of your data is critical and we have implemented measures to ensure your privacy rights are respected and applied. We commit to process your data fairly, legally and to be transparent about how we do so.
This notice, which applies whether you use our services or use our website, explains our approach to data integrity and your individual rights.
It does not apply to pages hosted by our referral partners, independent consultants and associates.
By using our services, you consent to the collection, use and transfer of your information under the terms of this notice.
Put simply, we set out what we are going to do with your data in this Privacy Notice.
We ask you to read this Privacy Notice to ensure you are happy with the way that Transmit Startups will process your data.
We ask you to confirm that you agree with our Privacy Notice when you confirm your decision to enter into a loan application with us.
We provide the option to opt in to the different marketing options that you prefer.
The processing of personal data is governed by the General Data Protection Regulation 2016/679 (GDPR).
The notice may change from time to time so please check for updates.
If you need further details or are unsure in any way, please contact us at email@example.com.
Who are we?
Transmit Growth Loans are a trading name of Transmit Start Ups Ltd. (08702257) and are Commercial Finance Brokers based in the UK. Our registered office address is: Northern Design Centre, Baltic Business Quarter, Abbott’s Hill, Gateshead, NE8 3DF. We act as an broker for our customers. Transmit Start Ups Ltd. are Authorised and Regulated by the Financial Conduct Authority. FRN 727421.
What personal information do we collect and process?
Transmit Growth Loans will be what is known as the controller of the personal data you provide to us. We collect personal data about you which may also include any special types of information or location-based information.
We collect and process your data in the following circumstances:
- When you use our services;
- When you use our website;
- When you sign up for our mailing list;
- When you contact us.
Transmit Growth Loans may collect the following information about you:
- Your name, date of birth and gender;
- Your ethnicity, qualification levels and employment status;
- Your contact details: postal address, business addresses, telephone numbers (including business, personal & mobile numbers) and e-mail address;
- Your existing financial commitments;
- Your device’s IP address;
- Your online browsing activities on the Company website;
- Your communication and marketing preferences;
- Your interests, preferences, feedback and survey responses;
- Your location;
- Other publicly available personal data, including any which you have shared via a public platform (such as a LinkedIn profile, Twitter feed or public Facebook page).
This list is not exhaustive and, in specific instances, we may need to collect additional data for the purposes set out in this notice. Some of the above personal data is collected directly, for example when you engage with us. Other personal data is collected indirectly, for example your browsing activity. We may also collect personal data from third parties who have your consent to pass your details to us, or from publicly available sources.
Why do we collect and process your personal information?
We need to know your basic personal data to provide you with an accurate recommendation for your personal circumstances. We will not collect any personal data from you we do not need to provide and oversee this service to you.
We only collect and process the information needed to effectively provide our services to you, as well as for contact and communication purposes.
We will use your personal information as part of the reporting process we have agreed with our partner organisations.
We provide reports on our activity as per agreements with organisations for whom we deliver programmes.
How is your personal information used?
We use your personal data:
- To provide services to you;
- To effectively communicate with you;
- To respond to your enquiries;
- To make our website and other social media content available to you;
- To verify your identity;
- To assess your eligibility for the Start Up Loans programme, including assessing lending risks and obtaining a credit reference;
- For crime and fraud prevention, detection and related purposes (if mandated by law);
- To contact you (with your agreement) electronically about promotional offers and services which may interest you;
- For market research purposes and to better understand your needs;
- To enable us to manage service interactions with you;
- To ensure compliance with our contractual obligations, including auditing and reporting, we have in providing our service to you;
- Where we have a legal right or duty to use or disclose your information (for example in relation to an investigation by a public authority or in a legal dispute);
- Test new systems and check upgrades to existing systems to improve our service delivery;
- Help improve our products and services, for quality control, security, internal record keeping and other business needs.
Certain types of personal information, such as gender and ethnicity, are used only as part of our contractual reporting requirements, for the purposes of monitoring and promoting equal opportunities.
Automated Decision Making: Transmit Growth Loans will pass your data captured to our panel of lenders whom may use automated decision-making in respect of your application for finance. We will only collect the minimum amount of data needed and have a clear retention policy for the profiles we create.
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or any significant affects. You can request human intervention and challenge a decision made this way by contacting the relevant lender.
The lawful basis for processing your personal information
For processing of data to be lawful under GDPR Transmit Growth Loans use;
Consent: the individual has given clear consent for you to process their personal data for a specific purpose.
Contract: the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract.
Legitimate interests: the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.
Who we share your personal information with
As a credit broker, we work with a select panel of lenders. Our brokers will identify the best products/services for your business from our panel. With your consent, we will pass your information onto the lender(s) we have identified. They will process your data in order to assess your suitability for their products. Each lender will have their own privacy notice available.
Where your personal information is stored
All the personal data we use is controlled by Transmit Growth Loans in the UK, however, for the purposes of IT hosting and maintenance, this information is located on servers within the European Union and GDPR compliant US based companies. No 3rd parties have access to your personal data unless the law allows them to do so. We have a Data Protection regime in place to oversee the effective and secure processing of your personal data.
Your data is stored electronically on our cloud encrypted server which is hosted through Dropbox for Business. Their servers are based in the USA.
Your information is stored on dedicated hardware used by Transmit Growth Loans and all data is held and backed up within the UK or EU, or is covered by the EU-US Privacy Shield Framework.
Where you communicate with us by email, we may store copies of the emails. Our email service is provided through Google G Suite.
We use a cloud-based Customer Relationship Management (CRM) system, Capsule, and a cloud-based task management system, Monday, that allow us to manage and record our work with clients in an efficient manner.
Your personal information will also be uploaded and stored on the systems our panel of funders use in order to process your application.
How we keep your personal information secure
We are committed to keeping your personal data safe and secure.
Our security measures include:
- Encryption of data
- Back up of data
- Password management
- Implementing risk management and data impact assessment analysis
- Regular cybersecurity assessments of all service providers who may handle your personal data
- Security controls which protect our IT infrastructure from external attack and unauthorised access
- Internal policies setting out our data security approach and training for staff
Only authorised and trained personnel can access your personal information if required to do so as part of their legitimate job role.
How long we keep your personal information
We will not retain your data for longer than necessary for the purposes set out in this notice.
We are required by law to keep some information for a minimum period of time e.g. financial information for tax purposes.
Different retention periods apply for different types of data, however the longest we will normally hold any personal data is 7 (seven) years. Where there is no legal requirement we will retain personal information for only as long as necessary to deliver our services and respond to any subsequent communications.
You are able to update, amend or request deletion of your personal information at any time.
When do we collect your information?
Our website has forms built using Gravity Forms. When you use our contact forms the information submitted is sent to firstname.lastname@example.org so that we can correspond with you. Your personal data will be stored in the website’s database and will be automatically deleted from here after five years. Your data is encrypted with the Gravity Forms Encrypted Fields plugin before it is saved to the database.
When you subscribe to our newsletter we collect your email address and name so that we can correspond with you. Your personal data will be stored in MailChimp, the application we use to send our newsletters. You can request to be removed anytime by clicking ‘unsubscribe’ in any newsletter/mailout or by contacting us.
We may also collect additional information from you as we communicate with you in order to deliver your services. For example, we may collect documentation from you via email etc.
Online data management (analytics and security)
When someone visits our website, we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns.
We collect information about your computer and about your visits to and use of this website (including your IP address, geographical location, browser type, referral source, length of visit, entry and exit points and the number of page views).
We do this to find out things 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 do not permit Google to make, any attempt to find out the identities of those visiting our website.
If we do ever want to collect personally identifiable information through our website, we will be upfront about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
Website security and backups
Our website has HTTPS encryption via a Let’s Encrypt SSL certificate to ensure any data passed between your browser and the web server (where this website is hosted) is encrypted. When you are on a secure page, a lock icon will appear on the bottom of web browsers such as Microsoft Internet Explorer.
This website and its database are automatically backed up every day using a third-party service ManageWP. Backups are stored for 90 days in the EU Region.
Links to Other Web Sites
This Privacy Notice does not cover the links within our site linking to other websites. Those sites are not governed by this Privacy Notice, and if you have questions about how a site uses your information, you’ll need to check that site’s privacy information.
The cookies stored on your browser, computer or other device when you access our websites are designed by Transmit Growth Loans, or on behalf of us, and are necessary to improve your use of our site.
A cookie often includes a randomly generated number which is stored on your device. Many cookies are automatically deleted after you finish using the website.
This website does not store any information that would, on its own, allow us to identify individual users of this service without their permission. Any cookies that may be used on this website are used either solely on a per session basis or to maintain user preferences. Cookies are not shared with any third parties.
The main purposes for which cookies are used are:
- For technical purposes essential to effective operation of our websites, particularly in relation to site navigation.
- To enable us to collect information about your browsing patterns, including to monitor the success of conveying our information to you.
Types of cookies that may be used during your visit to the website are listed below:
|Cookie Name||Expiration Time||What It Does|
|_ga||2 years||Used to distinguish unique users by assigning a randomly generated number as a client identifier.|
|_gid||24 hours||Used to distinguish users.|
|_gat||1 minute||Used to throttle request rate.|
|privacy_embeds||30 Days||Used to manage third party content.|
How do I disable cookies?
Most browsers allow you to reject all cookies, whilst some browsers allow you to reject just third-party cookies. For example, in Chrome, you can block or allow all cookies by default. On your computer, open Chrome. At the top right, click ‘More Settings’, then under 'Privacy and security', click Cookies and other site data and select an option.
How you can do this will depend on the browser you use. Further details on how to disable cookies for the most popular browsers are set out below. Please be aware that blocking all cookies will, however, have a negative impact upon the usability of many websites, including ours.
Microsoft Internet Explorer
1. From the Tools menu, select Internet Options.
2. Click on the Privacy tab.
3. Select the appropriate settings.
1. Choose Settings> Advanced
2. Under “Privacy and security,” click “Content settings”.
3. Click “Cookies”
1. Choose Preferences > Privacy
2. Click on “Remove all Website Data”
1. Choose the menu “tools” then “Options”
2. Click on the icon “privacy”
3. Find the menu “cookie” and select the relevant options
Opera 6.0 and further
1. Choose the menu Files”> “Preferences”
At the Transmit Growth Loans we respect your online privacy. Please check the third-party embeds you would like to load by default.
To deliver a full range of services to you, it may be necessary for us to share your data outside of the European Economic Area. This will typically occur when service providers are located outside the EEA or if you are based outside the EEA. These transfers are subject to special rules under GDPR.
If this happens, we will ensure that the transfer will be compliant with data protection law and all personal data will be secure. Our standard practice will be to use ‘standard data protection clauses’ which have been approved by the European Commission for such transfers. Those clauses can be accessed on the European Commission website.
How you can help protect your personal information
If you are using a computing device in a public location, we recommend that you always log out and close the website browser when you complete an online session.
In addition, we recommend that you take the following security measures to enhance your online safety:
- Keep your account passwords private. Remember, anybody who knows your password may be able to access your account.
- When creating a password, use at least 10 characters. A combination of letters, symbols and numbers is best. Try not to use easy to guess words, your name, email address, or other personal data that can be easily obtained. We also recommend that you frequently change your passwords.
- Avoid using the same password for multiple online accounts.
Your rights in respect of the personal information we hold
If you wish to correct, complain, object or otherwise control the data we hold please contact us and we will respond accordingly.
Please contact us if you have any questions about how your personal information is being used or if you are unhappy about our service or anything we do. We will do our best to resolve the issue.
An overview of your different rights
You have the right to request:
- Access to the personal information we hold about you, free of charge.
- The correction of your personal information when incorrect, out of date or incomplete.
- For example, when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the personal information has come to an end.
- That we stop using your personal information for direct marketing (either through specific channels, or all channels).
- That we stop any consent-based processing of your personal information after you withdraw that consent.
Your right to withdraw consent
Whenever you have given us your consent to use your personal information, you have the right to change your mind at any time and withdraw that consent.
Where we rely on our legitimate interest
In cases where we are processing your personal information on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal information.
You have the right to stop the use of your personal information for direct marketing activity through all channels, or selected channels. We must always comply with your request.
How you can access the personal information we hold
You can access a copy of the personal information we hold by submitting a Subject Access Request to us using the contact details below.
We will respond to as soon as possible, and in any event, within one month of verifying the request.
To protect the confidentiality of your personal information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
Getting in touch with Transmit Growth Loans
We can be contacted at:
Transmit Growth Loans,
Northern Design Centre,
Baltic Business Quarter,
Phone on: 0333 355 4886
The Supervisory Authority in the UK
The Supervisory Authority in the UK is the Information Commissioners Office (ICO).
Transmit Start-Ups Ltd can be found on the Data Protection Register. The registration number is ZA047144.