27th Feb 2020

Privacy policy

Eris Group Ltd, trading as Native Finance (we) are committed to protecting and respecting your privacy.

  1. Scope of policy

    This policy (together with our Terms and Conditions) applies to (i) your use of our website, nativefinance.co.uk; and (ii) or any one of Native Finance’s subdomains (collectively, the "Native Finance Platform"), and any of the services accessible through the Native Finance Platform, ("the Services").

    This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

    For the purposes of applicable data protection laws (including the EU General Data Protection Regulation 2016/679 – "GDPR") ("Data Protection Laws"), Eris Group Ltd, trading as Native Finance is an independent controller. We are registered in England and Wales under company number 09479417. An individual Lender that we provide your data to may also be a data controller for the purpose of Data Protection Laws and at that stage use of your personal data will be governed by the privacy policy of the individual Lender.

  2. What personal data do we collect?

    • Company directors and shareholders

      We collect personal data relating to company directors and shareholders from publicly available registers. The information we collect includes:

      • Name
      • Date of birth (month and year)
      • Corporate appointments, shareholdings and relationships

      We collect information relating to company directors and shareholders in the following countries:

      • United Kingdom
      • Isle of Man
      • Jersey
    • Information we may collect from you

      We may collect and process the following data about you:

      • Information you give us (Submitted Information): you may give us information about you either through the Native Finance Platform (for example when you create an account, or submit a finance request), or your communications with us (for example, by email, live chat or on a phone call). This includes information you provide when you subscribe to any of our Services. The information you give us may include:
        • Name
        • Address (including postcode)
        • E-mail address
        • Phone number
        • Property details (including location, value and size of property)
        • Transaction details
        • Financial Information
        • Company structure and information
    • Information we collect about you and your device: Each time you use the Native Finance Platforms we may automatically collect the following information:

      • Technical information, including a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface) (Device Information);
      • Details of your use of the Native Finance Platform including, but not limited to, traffic data and location data, (Log Information).

    We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this policy for as long as it is combined. Other than Lenders and other third parties concerned with the provision of the Services (for example our payments partner), we do not disclose information about identifiable individuals to other third parties, but we may provide them with anonymous aggregate information about our users. We may make use of the personal data we have collected from you to enable us to comply with our third parties’ wishes by displaying their information to that target audience.

    Our lawful basis for collecting and processing is that we are required to process this personal data in order to fulfil our obligations under the Terms and Conditions in order to provide the Services.

  3. Why we collect your personal data

    Our legal ground for using personal data relating to directors and shareholders is that doing so is necessary for the purposes of legitimate interests pursued by Native Finance and our customers. Our legitimate interests include for the purpose of providing, developing and promoting the Platform. Our customers’ legitimate interests include conducting thorough and robust due diligence. This includes commercial due diligence and legal obligations to carryout due diligence.

    We consider that commercial and legal due diligence are crucial to a strong economy and safe society. Consequently, we consider that they provide a compelling ground for us to process personal data relating to directors and shareholders.

    We consider that, as all the personal data we collect for the Platform is publicly available, the interests and rights and freedoms of directors and shareholders do not override our legitimate interests and particularly do not override the compelling legitimate interests of our customers. Where we use criminal offence information or special category personal data relating to directors and shareholders we do so for the purposes of preventing and detecting crime.

    Your personal data is collected primarily so that you can effectively use the Native Finance Platforms and the associated Services and/or so that we can communicate with you in relation to such use.

    We may also collect and process your personal data because we have a legitimate interest in contacting you with marketing information relating to Native Finance and our products.

    We may also use your data for internal statistical analysis purposes, although we will anonymise this data.

  4. Disclosure of your information

    We may disclose some or all the Submitted Information and/or your contact details that we collect from you when you register or use the Native Finance Platforms to Lenders, to allow them to contact you directly in respect of the Services.

    We may disclose your Submitted Information to third parties:

    • In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.

    • If Eris Group Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its users will be one of the transferred assets.

    • If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.

    • In order to:

      • Enforce or apply our Terms and Conditions and any other agreements or to investigate potential breaches; or
      • Protect the rights, property or safety of Eris Group Ltd, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

    Our contractual arrangements and the requirements of Lenders are changing all the time, and the nature of our service is for your benefit, to allow you to make the most of the Native Finance Platforms. If you would like specific information about which category of disclosure particular Lender fall into, please contact us using the contact details below.

  5. Where we store your personal data

    The data that we collect from you is transferred to, and stored at, a destination within the European Economic Area (EEA). It is processed by staff operating inside the EEA. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

    Where we have given you (or where you have chosen) a password that enables you to access certain parts of the Native Finance Platforms, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

    Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Native Finance Platforms; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

  6. Your rights

    In accordance with applicable Data Protection Laws, you have the right to access your personal data, the right to rectification, a right to restrict our processing activities of your data and a right of erasure.

    You have the right to ask us not to process your personal data for any marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You will be required to provide your consent to the processing of your Submitted Information by checking certain boxes in the Native Finance Platforms. You can contact us at support@nativefinance.co.uk for further information.

    The Native Finance Platforms may, from time to time, contain links to and from the websites of the Lenders and other third parties. If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.

  7. Access to information

    The applicable Data Protection Laws give you the right to access information held about you. Your right of access can be exercised in accordance with such Data Protection Laws. You will not have to pay a fee to access your personal data (or exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

    You can exercise the right at any time by contacting us at support@nativefinance.co.uk.

  8. Changes to privacy policy

    Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail or when you next log-in to the Native Finance Platforms including where we are required to obtain either revised or additional consent from you with regards to the collection, transfer and processing of your personal data. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the Native Finance Platforms or the Services.

  9. Contact

    Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to support@nativefinance.co.uk.