Privacy Policy
Paddock Capital Limited understands how important your privacy is and we take its security seriously. Please read this policy carefully, along with our Client Terms of Business and Introducer Agreement, together with any other documents referenced within this policy.
Paddock Capital is a trading style of Paddock Capital Limited (company registration number: 15814053). Paddock Capital is a credit broker not a lender. The firm deals with a panel of lenders.
This Privacy Policy describes the policies of Paddock Capital on the collection, use, and disclosure of your information that you collect when you use our websites and/or our services (the “Service”). By accessing or using the Service, you are consenting to the collection, use and disclosure of your information in accordance with this Privacy Policy. If you do not consent to the same, please do not access or use the Service.
Definitions
Application means a proposal with the intention of sourcing a product or service for you. Applications, Apply, and Applying shall be interpreted accordingly
Credit Reference Agency (CRA) means a person which provides credit references on businesses and individuals. Credit Reference Agencies shall be interpreted accordingly
Credit Search means a search carried out with a Credit Reference Agency. Credit Searches shall be interpreted accordingly
Provider means any entity to which we may make an Application including (but not limited to) banks, peer-to-peer lenders, private investors, alternative finance providers, insurers and other intermediaries. Providers shall be interpreted accordingly
Data protection and regulatory notice
We shall comply with all applicable requirements of the General Data Protection Regulation ((EU) 2016/679) (the “GDPR”) and any other relevant regulatory requirements currently in effect and those that come into effect in the future. We are registered with the Information Commissioner’s Office (the “ICO”) as a “Data Controller” which has meaning given to it by the ICO and more information is detailed on the ICO website. Our ICO reference number is ZB724466.
You are providing your personal information to us to enable us to assist you in obtaining appropriate products and/or services in support of your requirements, along with providing information on your business and requirements. In processing this information, we may share this data with carefully selected third-parties who may either be a Provider or a packager / broker of such services whom the company believes can satisfy your requirement. We may also share data with other third-parties to assess your requirement and source appropriate solutions such as comparison platforms.
We take our responsibilities under GDPR seriously and we will at all times respect your privacy and legal rights. We will never sell or distribute any data you have provided to us to any unrelated or unconnected third-party except where necessary to source a product or service with a Provider or a packager / broker of such services, or to adhere to prevailing regulatory and compliance obligations. We may contact you on an ongoing basis to inform you about relevant products and services only if you have given us specific permission to do so and at any time you may opt out of receiving such contact and information from us.
Your information is collected and may be shared and processed with our Providers and third-party service partners to:
Where we share your information with Providers, or packagers / brokers of such services, they will be acting as a “Data Processor” or “Data Controller” in their own right and their own privacy policy will apply. We will share links to Providers’ privacy policies where feasible and on request. Due to the number of Providers that we work with, we do not hold copies of their privacy policies as there is a risk that the information we hold may become out of date where a Provider makes changes to their policies and we have not been made aware of these changes. A list of Providers and links to their privacy policies is available here.
In order to fully assess your circumstances in support of any Applications we make, we and relevant Providers may wish to search your records with selected Credit Reference Agencies (CRAs) by conducting Credit Searches. Credit Searches may be conducted on any partner, director, or beneficial stakeholder connected to the applicant entity and its wider group and relevant requirement/requirements. Credit Searches may add a record of the details of the search made to the relevant credit file when they are conducted. We and Providers may see Credit Searches conducted by other organisations. Similarly, other organisations that carry out such searches may see Credit Searches conducted by us and Providers we approach.
Providers may be required to check your details with Fraud Prevention Agencies as part of their assessment of an Application. If you provide us false or inaccurate information then this may be recorded at such agencies.
An association between you (or another individual a Credit Search is conducted on) and any named partner or spouse may be created at the Credit Reference Agency. This may link your financial records, each of which may be taken into account in all future Applications by either or both of you. If an association already exists then your application may be assessed with reference to these associated records. This situation will continue until one of you successfully files a disassociation with the relevant Credit Reference Agency.
We will generally collect your personal data directly from you, or via third-parties such as introducers or other intermediaries. We may also collect data from and/or combine your personal data with information from other source such as CRAs, fraud prevention agencies, marketing affiliates, agents working on our behalf and publicly available sources such as Companies House, your websites, and social media.
We collect and process your data when:
The nature of information provided may depend on the nature of the requirements you seek our assistance with and may include but is not limited to details as follows:
Who you are:
Your employment status and sources of income:
Your financial commitments and position:
We will not collect or retain any personal data from you we do not need for our purposes. The legal grounds that are relevant to us in justifying our processing of your personal data are as follows:
For your legitimate interests or the legitimate interests of a third-party unless there is a good reason to protect your personal data which overrides this legitimate interest.
We are required under regulation to keep your basic personal data, such as name, address, and contact details for a minimum of 6 years, after which time it will be erased. The information used for marketing purposes will be kept with us until you notify us that you no longer wish to receive marketing communication from us.
Your data is securely stored on our customer relationship management systems and client file directories. With the exception of signed documentation pertaining to a contract or agreement, we do not typically retain physical copies of your data.
Should you wish to be provided with the details of the data and information we hold on you please email alexander.austin@paddockcapital.co.uk detailing your request and the information you wish to be provided with. You have the legal right to be provided with these details and to receive a copy of all data that we hold about you. At your request Paddock Capital will amend/correct/destroy all data that we hold about you and remove all records from our systems, except where the right to erasure conflicts with our legal obligation to keep hold of your data to comply with financial or other regulations, or other relevant circumstance as outlined by the ICO’s guidance.
Some Providers and Credit Reference Agencies to whom your data may be provided may require you to apply in writing directly in respect of any request for information or erasure and a fee may be payable for the provision or erasure of such information.
As part of providing our services to you, we may share data with Providers and relevant third-parties by interfacing with third-party systems or via an application programming interface (API). To enable us to manage your data effectively, you agree to grant us an irrevocable, royalty-free, sub-licensable, transferable, perpetual license to use, copy, reformat, translate, excerpt (in whole or in part) and distribute these data for any purpose on or in connection with our services, systems and websites, and to prepare derivative works of, or incorporate into other works.
If you wish to raise a complaint on how we have handled your personal data, you can do so by following the steps in the section referencing “Complaints” in our Client Terms of Business, or our Introducer Agreement, and marking your complaint for the attention of the Data Protection Officer.
Changes to this privacy policy
We reserve the right to amend or modify this privacy policy from time to time without any prior notice to you and an updated copy of this privacy policy will be posted on this website. The revised Privacy Policy will be effective 90 days from when the revised Privacy Policy is posted on this website and your continued access of the Service after such time will constitute your acceptance of the revised Privacy Policy. We therefore recommend that you periodically review this page.
These terms and conditions (the “Terms of Business”), along with our Privacy Policy, govern the use of our websites and the services provided by Paddock Capital Limited to any business and/or individual.
Definitions
Application means a proposal with the intention of sourcing a product or service for you. Applications, Apply, and Applying shall be interpreted accordingly
Broker Agreement means a contract issued to and signed by the entity or entities for whom we are sourcing a Credit-Backed Offer
Broker Fee means an arrangement fee paid to Paddock Capital for facilitating and arranging a facility with a Provider
Completion means the successful provision of a product or service from a Provider to you
Credit-Backed Offer means the outline terms of a credit-sanctioned agreement from a Provider or syndicate of multiple Providers for a product or service which, subject to conditions being satisfied, will lead to Completion on the terms outlined
Credit Reference Agency (CRA) means a person which provides credit references on businesses and individuals. Credit Reference Agencies shall be interpreted accordingly
Credit Search means a search carried out with a Credit Reference Agency. Credit Searches shall be interpreted accordingly
Provider means any entity to which we may make an Application including (but not limited to) banks, peer-to-peer lenders, private investors, alternative finance providers, insurers and other intermediaries. Providers shall be interpreted accordingly
Paddock Capital is a trading style of Paddock Capital Limited (company registration number: 15814053). We will be acting as a credit broker on your behalf. We are not a lender. Currently we deal with an unrestricted panel of lenders.
We provide a non-advised service which means you will not receive financial advice, nor a formal recommendation from us. You will need to make your own choice about how to proceed with any of the solutions sourced and presented.
Limitations of our services
Paddock Capital cannot guarantee that we will be successful in sourcing a solution for your requirements, nor are we obliged to assist or provide our services to you.
We source solutions based on the information provided to us by you and third-parties. Where your specific needs have not been detailed fully and/or accurately, it is your responsibility to ensure that any solutions we present are appropriate for your requirements.
There may be Providers who could provide you a solution that we do not have a relationship with or access to. This means that there may be some solutions in the market better suited to your requirement than those we can source.
Some of the information we source may be derived from third-parties whom we have no control over and information may contain inaccuracies or errors.
Information on our websites may change without notice and information provided as part of our services may not be timely or correct, meaning it is for your general information and use only.
You use our websites and systems at your own risk and you should use software to detect and disinfect viruses or malware in any information you use and download.
The availability of third-party websites, links, services or information via our documentation, emails, or websites does not constitute any recommendation, advice, endorsement or publication by us and we are not responsible for any such websites, links, services or information provided by any third-party.
We reserve the right to change any aspect of our services and websites at any time without notice or to suspend access to our services or websites, or end them.
To the extent permitted by applicable law, each party shall only be liable to the other party for any loss or damage which results as a directly foreseeable consequence of its breach of these Terms of Business or negligence (except in the case of fraud or wilful misconduct).
Nothing in these Terms of Business shall seek to exclude or limit liability for death or personal injury or any other liability that cannot be lawfully excluded or limited.
Our intellectual property
Unless otherwise stated in writing, we do not grant you, nor any of your related businesses, any intellectual property rights in relation to our documentation, services, websites, or processes, including but not limited to our copyright, trademarks, domain names, designs, patents and databases.
We do not grant you, nor any of your related businesses, any rights to use or reference any content or material on our websites and services include graphics, copy, source code, algorithms, databases, proprietary technology, and configurations, expect where explicitly stated in writing. Any usage except a direct link to our website home pages requires prior written consent.
You will not acquire any rights (whether proprietary or otherwise) to any information provided via our systems or websites.
You are not permitted to use our systems and websites to collect information on other non-related parties for any reason, whether by saving information made available to you unintentionally, or using our systems and websites intentionally in any way to access data you should not reasonably expect to have access to.
You may not use any scripts or automation to collect information or interact with our systems or websites except where you are given prior written permission.
You are prohibited from impersonating any person or entity or creating false identities in order to use or access our systems and websites. You are not permitted to register the information for any person or entity for whom you do not have authorisation and consent to do so.
You are not permitted to copy, reuse, or distribute any material on or obtained via our systems and websites.
Broker fee
In consideration of the services carried out by us in relation to this appointment, you may be asked to pay to us a Broker Fee. Any Broker Fee will be in addition to any fees charged by a Provider to you as part of the provision of a product or service.
If a Broker Fee is applicable, it shall be set out within our Broker Agreement and shall be payable upon acceptance of a formal offer from a Provider. Any variation or reduction to your requirement/requirements following the signing of a Broker Agreement shall not reduce the Broker Fee set out in a signed Broker Agreement, however any increase in your requirement/requirements may lead to the Broker Fee increasing and a new Broker Agreement being issued.
We shall accept payment of fees as they fall due by debit card or direct bank transfer.
Commission
In addition to any Broker Fee payable by you, a Provider may pay us commission on a transaction. Any such commission will typically take the form of a fixed fee or a percentage of the facility amount you draw down, however commission structures vary between Providers.
The commission structure adopted may impact the amount that you pay in respect of any product or service including (but not limited to) interest rates and fees. It may be that we know, in advance of making an Application, what commission structure a Provider shall apply. In some circumstances, there will be scope for us to set the amount of commission we receive, which may impact the amount that you pay in respect of any product or service including (but not limited to) interest rates and fees.
Where Paddock Capital is charging you a Broker Fee, any commissions due to be earned will be detailed explicitly in the Broker Agreement.
Where a product or service is defined as a Regulated Product with meaning given to it in the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001 (SI 2001/544), the existence and nature of commission arrangements where the commission varies depending on the Provider, product, or other permissible factors will always be disclosed. This disclosure will also cover how the arrangements could impact the products we propose to you. Such disclosures will be made in a formal document (the “Suitability Document“) issued to you along with our Broker Agreement where applicable and this Suitability Document will detail the calculation of commission or commission amount.
You will indemnify Paddock Capital Limited in respect of any commission we are required to repay to a Provider as a result of you or your business being in breach of the terms of the agreement with that Provider following a Completion.
Complaints
If you wish to register a complaint you can do so by emailing alexander.austin@paddockcapital.co.uk and providing the relevant details. Please include as much information as possible and tell us what you want to happen. A copy of our complaints procedure will be outlined to you in our response. If we cannot resolve your complaint, you may be entitled to refer it to the Financial Ombudsman Service via their website: https://www.financial-ombudsman.org.uk or by calling 0800 023 4567.
Your transaction may be covered by the Financial Services Compensation Scheme (the “FSCS“). The FSCS is the UK’s statutory deposit insurance and investors compensation scheme for customers of authorised financial services firms. The FSCS exists to protect customers of financial services firms that have failed. If the company you have been dealing with has failed and is unable to pay claims against it, the FSCS may be used to pay compensation. You can find out more about the FSCS at https://www.fscs.org.uk/.
General terms
We reserve the right to vary these terms and conditions at any time, including assigning these terms.
We may send any notices to you by email to the email addresses you initially provided to us, or any others since provided to us. You agree that we may send you notices via email or via alerts within our systems and websites.
If any provision of these Terms of Business is found to be invalid or unenforceable, the remaining provisions shall remain enforceable. Failure to exercise or enforce rights or provisions shall not constitute a waiver.
Nothing in these Terms of Business shall seek to exclude or limit liability for death or personal injury or any other liability that cannot be lawfully excluded or limited.
Your use of our services, systems and websites is subject to English law, and we both agree to submit to the jurisdiction of the English courts to settle any dispute that might arise.
Your usage, acknowledgement and consent
By agreeing to our Terms of Business and/or continuing to engage with Paddock Capital Limited following the provision of the Terms of Business, you provide consent for Paddock Capital and associated related/group companies to share your details with Providers and relevant third-parties who will process your information, in turn allowing Paddock Capital to offer suitable products and services that Providers may provide.
As part of sharing this information, you understand that Paddock Capital and associated related/group companies, in addition to Providers and relevant third-parties receiving this information, may conduct identify verification checks and Credit Searches on you and individuals associated with you, along with any partner, director, or beneficial stakeholder connected to the applicant entity and its wider group and relevant requirements.
You have the right to withdraw consent and object an any time to the processing of your personal data and this means that we cannot process your data without your consent. Please be aware that if you withdraw consent, we may not be able to proceed any further with any relevant Applications, and depending on the stage reached in our proposals, we may not be able to remove all of your data due to our responsibilities laid out by legal and regulatory bodies.
You agree to act with the utmost good faith in the provision of information to Paddock Capital and you warrant that all information and documentation provided throughout the course of this engagement is full and correct to the best of your knowledge. You agree not to withhold any material information that could influence the decision for Paddock Capital to proceed with this engagement, nor withhold any information or documentation that may influence the willingness of a Provider to provide a product or service. You agree to notify us promptly of any changes in the information you have provided to us.
You agree to keep any login credentials including usernames, passwords, security codes and memorable answers secure. When your credentials are used to access our systems and websites, we will assume this is you. Any instructions or information provided through our systems being accessed by your credentials will be presumed to have been provided by you and you are responsible for any activity on our systems and websites arising from any failure to keep your login credentials secure. We may refuse or disable your access at our sole discretion without notice or explanation, where it is lawful to do so.
You confirm that the information you provide for any person or entity is done with that person’s or entity’s prior authorisation.
You agree to take all reasonable steps and use all reasonable endeavours to comply with and satisfy any condition imposed by a Provider.
You are in agreement to pay any Broker Fee where applicable as stated in a Broker Agreement.
You understand that Paddock Capital may receive commission from Providers without prejudice to any Broker Fee you pay for our services and you have no objections to Paddock Capital receiving such remuneration.
You are aware that Paddock Capital may not receive commission or commission may be repaid if you do not honour the terms of your obligations under an agreement with a Provider, if a condition set out in a formal offer cannot be satisfied, if a Provider withdraws an Agreement in Principle or seeks to make a material variation to the terms of a formal offer such that you are no longer able to proceed to Completion, or in any case Completion does not occur and the product or service or any part of it is not advanced or provided by a Provider. You agree to indemnify Paddock Capital Ltd in respect of any commission that needs to be repaid.
You are aware that Paddock Capital is required to disclose the nature of commission upon request.
You understand that if your details have been provided to us by an affiliate or introducer then we may pay them a fee/commission.
You are aware that where the product or service is defined as a Regulated Product with meaning given to it in the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001 (SI 2001/544), the existence and nature of commission arrangements where the commission varies depending on the Provider, product, or other permissible factors will always be disclosed. This disclosure will also cover how the arrangements could impact the products we propose to you. Such disclosures will be made in a Suitability Document issued to you along with our Broker Agreement where applicable and this Suitability Document will detail the calculation of commission or commission amount.
Before agreeing to our terms and/or continuing to engage with Paddock Capital, you confirm that you have read this notice in full and have received any independent advice as you consider necessary.
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