Swoop Finance Limited Privacy Notice Who we are Swoop Finance Limited (company number: 11163382 ) which is an independent Commercial Finance Broker registered at The Stable Yard Vicarage Road, Stony Stratford, Milton Keynes, Buckinghamshire, England, MK11 1BN . We act as a broker for our customers. What is the purpose of this document? Swoop Finance Limited is the controller and responsible for your personal data (collectively referred to as ” Swoop Finance Limited”, “we”, “us” or “our” in this privacy notice). This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in th 2 We may also collect, store and use the following “Special Categories” of more sensitive personal information: – Information about your health, including medical conditions, particularly where you are classified as a vulnerable individual as a result of your medical condition. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your location data to calculate the percentage of customers accessing our services in a given geographical location. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice. 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 and you fail to provide that data when requested, we 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 service you have with us but we will notify you if this is the case at the time. How is your personal data collected? We use different methods to collect data from and about you including through: – Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you : – apply for our services either directly or via our web page; – request marketing to be sent to you. – Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below : – Contact, Financial and Transaction Data from providers of Business information such as Credit Safe, Experian or Companies House, based inside or outside the EU; – Introducers and other businesses where we have a trading relationship. 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: (a) Consent: the individual has given clear consent for you to process their personal data for a specific purpose. (b) 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. (c) Legal obligation: the processing is necessary for you to comply with the law (not including contractual obligations). 3 (d) Public task: the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law. (e) 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. (This cannot apply if you are a public authority processing data to perform your official tasks.) The situations in which we will process your personal information are listed below. Please see Schedule 1 to this privacy notice in which we have set out, in a table format, 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 at 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 below. We will process your personal information for the following reasons: – to find the best source of finance based on your circumstances; – to undertake credit checks for the purposes of finding the most suitable finance product; – to confirm your affordability for the financial requirement we are seeking finance for; – to comply with our anti-money laundering and know your client requirements; and – to meet our regulatory responsibilities. Automated Decision Making Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances: – where we have notified you of the decision and given you 21 days to request a reconsideration; – where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights; or – in limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights. If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights Many of our funders use auto scoring technology to underwrite deals. You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you. Why might we share your information with third parties? 4 We will share your personal information with third parties where required by law, where it is necessary to administer the contractual relationship with you or where we have another legitimate interest in doing so. “Third parties” includes third-party service providers (including contractors and designated agents) and other entities within our group. The following third-party service providers process personal information about you for the following purposes: – the most suitable funders on our panel (a full list of which is available by contacting – our IT hosting and maintenance, this information is located on servers within the European Union. – CPA Audit Limited to meet our regulatory obligations to our Principal Firm. – Credit reference agencies for the purposes of ascertaining your financial status. – Regulatory bodies such as The Financial Conduct Authority for the purposes of meeting our regulatory obligations. – Other members of our group where needed to process your application. – Fraud prevention agencies where we are required to do so. – Third party product providers where you have given us your prior consent to do so. We have a Data Protection regime in place to oversee the effective and secure processing of your personal data. More information on this framework can be found on our website. How long we keep your information We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of your personal information are available in our retention policy which is available from 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. In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer an employee, worker or contractor of the company we will retain and securely destroy your personal information in accordance with applicable laws and regulations. International transfers We do not transfer your personal data outside the European Economic Area (EEA). 5 What are your rights? Under certain circumstances, by law you have the right to: – Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it; – Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected; – Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below); – Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes; – Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it; – Request the transfer of your personal information to another party. – Withdraw consent: In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it. If you wish to raise a complaint on how we have handled your personal data, you can contact our Data Protection Officer who will investigate the matter. If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the Information Commissioner’s Office (ICO). Our Data Protection Officer is Andrea Reynolds and you can contact her at 6 Acceptance I confirm I have read and accept the terms of this Privacy Notice. Signed……………………………………………. Print Name……………………………………… Dated…………………… Additional Marketing – from us From time to time we would like to contact you with detail of other products and services we provide. If you consent to us contacting you for this purpose please tick to say how you would like us to contact you. ☐ Post ☐ Email ☐ Phone ☐ Text ☐ Automated Call SCHEDULE 1 – PROCESSING ACTIVITIES AND LAWFUL BASIS FOR PROCESSING Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest To find the best source of finance based on your circumstances (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications – Contractual – Legitimate Interest: to promote financial products we believe may be of interest to you. To undertake credit checks for the purposes of finding the most suitable finance product. (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications – Contractual To confirm your affordability for the financial requirement you have proposed to us. (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications – Contractual 7 To comply with our anti-money laundering and know your client requirements. (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications – Legal Obligation to meet our regulatory responsibilities. (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications – Legal Obligation.

Customer Analytics FAQ

We use Hotjar to understand our users’ needs better and to optimize our service and user experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback.

What information is tracked and stored about me with Hotjar user behaviour tracking tool when I use the website?

All data is anonymously collected unless you give explicit consent to collect personal information. All the collected data will be stored electronically in Ireland, Europe on the Amazon Web Services infrastructure, eu-est1 datacenter. The database containing visitor and usage data is only accessible from the application servers, and no outside sources are allowed to connect to the database. Hotjar engineers who require access to perform their job efficiently will be given this type of access. Site visitors are assigned a user identifier, UUID, so that Hotjar can keep track of returning visitors without ever relying on any personal information, such as the IP-address. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on a particular user. 

How can I view the information that is recorded and stored about me with the user behaviour tracking tool Hotjar?

If you wish to view your personal information, please send a request to our user data management team and we will send a request to Hotjar requesting your information. Please note that this process can take up to few days.

How can I request deletion of the information that is stored about me?

According to GDPR, all users have the right to have their stored information deleted in entirety. Customers shall send an email request to asking to delete all the information that Hotjar has stored about them. An assigned Swoop representative will immediately send a request to Hotjar. Please note that the process can take up to 24 hours, and the information will then be erased within the next 30-day cycle of the database erasures. Finally, the user will receive a confirmation report, saying that all the data has been deleted.

For further details, please see Hotjar’s privacy policy by clicking on this link.You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies on other websites by following this opt-out link.