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 applying for a Start Up Loan 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 Start-Ups 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 firstname.lastname@example.org.
Who are we?
Transmit Start-Ups Ltd is a Limited Company registered in England. (referred to as “Transmit”, “we”, “our” or “us” in this notice).
Our registered number is 08702257.
Our registered office is at The International Business Centre, Mulgrave Terrace, Gateshead, NE8 1AN
Transmit Start-Ups is a national delivery partner of the Start Up Loans Company, a Government-backed initiative which is part of the British Business Bank. We provide Start Up Loans to individuals across the UK for the purpose of starting and growing their business.
In addition to the loan fund, we also provide free business planning support and post-loan mentoring for up to 12 months for all loan recipients.
What personal information do we collect and process?
We collect and process your data in the following circumstances:
- When you apply to Transmit Start-Ups for a Start Up Loan
- When you use our website
- When you sign up for our mailing list
- When you complete the contact form on our website
Transmit Start-Ups 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, 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
- Your correspondence and communications with us
- 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 only collect and process the information needed to effectively provide our services to you when applying for a Start Up Loan, 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.
The lawful basis for processing your personal information
We may collect, hold and process your personal data on the basis of legitimate interest where it is necessary in order for us to fulfil our needs as a business and to be able to provide you with our services, including, but not limited to:
- To send you information about your loan
- To provide details of the benefits available as part of the loan agreement
- Protecting customers, employees and other individuals and maintaining their safety, health and welfare
- Promoting, marketing and advertising our products and services
- Understanding our customers’ behaviour, activities, preferences, and needs
- Improving existing products and services and developing new products and services
- Complying with our legal and regulatory obligations
- Preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies
- Handling customer contacts, queries, complaints or disputes
- Protecting Transmit Start-Ups Ltd., its employees and customers, by taking appropriate legal action against third parties who have committed criminal acts or are in breach of legal obligations to us and our staff
- Effectively handling any legal claims or regulatory enforcement actions taken against us
- Fulfilling our duties and obligations to our customers, staff, colleagues, shareholders and other stakeholders.
We collect, hold and process your personal data on the basis that you give us consent when you accept this Privacy Notice.
We will seek your consent to hold and process your data when you sign up to our mailing list or we need to ask for any sensitive data as part of the application process. If you chose not to sign up to our mailing list we will still communicate with you when necessary as part of our contractual obligations.
You remain in control of the personal data you share with Transmit. You can change your preferences at any time, by choosing whether you want to give consent to your data being processed for specific types of communication and / or communication channels.
We may use your personal information to contact you if we reasonably believe that the processing of your personal data will prevent or reduce any potential harm to you. This type of notification is in your vital interest.
We may use and process your personal data to comply with our legal obligations such as HMRC requirements, if it is genuinely needed for law enforcement, to identify you as an individual if you contact us, or to verify the accuracy of your data.
Who we share your personal information with
Our service providers and suppliers
In order to make certain services available to you, we may need to share your personal data with some of our service partners. These include HMRC, cloud storage and IT providers.
Transmit only allows its service providers to handle your personal data when we have confirmed that they apply appropriate data protection and security controls. We also impose contractual obligations on service providers relating to data protection and security, which mean they can only use your data to provide services to Transmit and to you, and for no other purposes.
Our partners in the Start Up Loans programme
When making an application for a Start Up Loan we will share your personal information with our partners who deliver the Start Up Loans programme.
The Start Up Loans Company
The Start Up Loans Company (SULC) are part of the British Business Bank and manage the Start Up Loans programme nationally. SULC are able to access all of the personal information you provide to Transmit and your application is also covered by their Privacy Notice.
The Enterprise Fund t/a GC Business Finance
The Enterprise Fund t/a GC Business Finance are our finance partner in delivering the Start Up Loans programme. When you are approved for a loan your personal details are passed to them to enable a loan agreement to be drawn up and for the loan to be paid to you. GC Business Finance will also use your personal details to contact you about loan repayments. Their agreement and Privacy Notice will set out the terms.
Associate Business Advisors
If we engage an associate business advisor to work with you on your application, we will need to share your personal information as part of that process. All of our Associate Business Advisors operate within the terms set out in this Privacy Notice.
Credit reference and fraud prevention agencies
When you apply for a loan, any of the services we provide, or that we provide on behalf of SULC we and SULC will check our own records for information about you and may also carry out a search through credit reference agencies on you.
Credit reference agencies collect and maintain information about consumers’ and businesses’ credit behaviour. This includes Electoral Register, fraud prevention, and credit information (including details of previous applications and the conduct of your bank accounts) and public information such as County Court Judgements, decrees, and bankruptcies. Credit reference agencies may form a link between any previous or subsequent names that you use in the records they hold about you.
How we use information from credit reference agencies
The information that we and/or SULC and other organisations provide to credit reference agencies about you, your financial associates and your business (if you have one) may be provided to other organisations and used by them and us to:
- help make decisions, for example when:
a. checking details on applications for loans or other credit and credit-related or other facilities;
b. managing loan, credit and credit-related accounts or facilities;
c. recovering debt;
d. checking details on proposals and claims for all types of insurance;
e. checking details of job applicants and employees;
- detect and prevent crime, fraud and money laundering;
- check your credit history;
- verify your identity if you, or someone financially linked with you, applies for loan or services;
- trace your whereabouts; and
- undertake research, statistical analysis and systems testing.
If we and/or SULC need to make a credit decision when you apply for a loan or to review the amount of credit we provide under an existing agreement, your records will be searched, along with those of anyone who is financially associated with you such as your spouse or partner. The credit reference agency will keep a record of this search and place a “footprint” on your credit file, whether or not your application proceeds.
We and/or SULC may give details of your loan account and how you conduct it to credit reference agencies, including if you borrow and do not repay in full and on time. If you fall behind with your payments and a full payment or satisfactory proposals are not received within 28 days of a formal demand being issued, then a default notice may be recorded with the credit reference agencies. Any records shared with credit reference agencies will remain on file for 6 years after your loan account is closed, whether it has been settled by you or as a result of a default. Other organisations may see these searches and updates if you apply for credit in the future, and these may affect your ability to borrow from other lenders.
You have a right to apply to the credit reference agencies for a copy of your file.
We and SULC carry out most of our credit searches using Experian, but details of how you have run your loan account may be disclosed to all the credit reference agencies. The information they hold may not be the same and there is a small fee that you may need to pay to each agency that you apply to. Their addresses are:
- CallCredit, Consumer Services Team, PO Box 491, Leeds LS3 1WZ or call 0870 060 1414 or log on to www.callcredit.co.uk.
- Equifax plc, Credit File Advice Centre, PO Box 1140, Bradford BD1 5US or log on to www.myequifax.co.uk.
- Experian Consumer Help Service, PO Box 9000, Nottingham NG80 7WP or call 0844 481 8000 or log on to www.experian.co.uk.
We and SULC have processes and systems that protect our customers and ourselves against fraud and other crime. Customer information can be used to prevent crime and trace those responsible. We will share your personal information from your application with fraud prevention agencies. If false or inaccurate information is provided and fraud is identified, details of this fraud will be passed to these agencies. Law enforcement agencies may access and use this information. We and other organisations may also access and use this information to prevent fraud and money laundering, for example when:
- checking details on applications for credit and credit related or other facilities;
- managing credit and credit related accounts or facilities;
- recovering debt;
- checking details on proposals and claims for all types of insurance; and
- checking details of job applicants and employees.
We and other organisations may access and use from other countries the information recorded by fraud prevention agencies.
Further information to explain credit can be obtained on the ICO website.
When you receive a loan from us we will offer you the services and support of one of our experienced business mentors. A separate agreement will be issued containing the details of this relationship. Your mentor will only have been provided with your personal information when you have both agreed to enter into the relationship and wish to be contacted
Other third parties
Aside from our service providers, we will not disclose your personal information to any third party unless we are legally obliged to do so, or you provide your consent for us to do so (for example to access third party resources). We will never sell or rent our customer data to other organisations for marketing purposes.
Examples of where we may be legally obliged to share your personal information include:
- Credit reference agencies;
- Governmental bodies, regulators, law enforcement agencies, courts/tribunals and insurers where we are required to do so;
- To comply with our legal obligations;
- To exercise our legal rights (for example in court cases);
- For the prevention, detection, investigation of crime or prosecution of offenders; and
- For the protection of our employees and customers.
Where your personal information is stored
Your information is stored on dedicated hardware used by Transmit Start-Ups and all data is held and backed up within the UK or EU, or is covered by the EU-US Privacy Shield Framework.
We use Dropbox for Business for the storage of electronic files.
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 partners The Start Up Loans Company and The Enterprise Fund t/a GC Business Finance require us to use when processing your loan 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 cyber security 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.
The following retention periods apply to applicants:
- For successful loan applicants, we keep personal data for a maximum period of six years after you have fulfilled all loan payment obligations.
- For unsuccessful loan applicants, we keep personal data for a maximum of six years after you have fulfilled all loan payment obligations.
You are able to update, amend or request deletion of your personal information at any time (see below).
Automated decision making, including profiling
We may retain some data for reporting and statistical purposes however this will only occur after removing all personal information that would allow an individual to be identified. This is called anonymisation.
Transmit do not engage in any profiling activity.
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 email@example.com or 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.
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.
You can view, update, download or delete your personal data stored on our website at any time from this page. Please note, this only shows data currently stored on this website and not in any of our other systems.
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 Start-Ups, 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||Expiration Time||What It Does|
|_gid||2 years||Used to distinguish users.|
|_gat||1 minute||Used to throttle request rate.|
How do I disable cookies?
Most browsers allow you to reject all cookies, whilst some browsers allow you to reject just third-party cookies.
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”
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 Start-Ups
We can be contacted at:
Transmit Start-Ups Ltd.
International Business Centre
Phone on: 0191 490 9328
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.