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Privacy Notice

About Us

 

Pallas Capital Limited (collectively referred to as “Pallas”, “we”, “us” or “our”) is registered under the Data Protection Act 2018 (“Act”) with the Information Commissioner’s Office (registration reference ZB978853). In the course of our regular business activities we collect, store and use personal data and/or confidential data including information about borrowers, guarantors, brokers, intermediaries, sub-contractors, investors, clients, contacts, suppliers, employees and job applicants. Where the aforementioned are legal entities, we may collect, store and use information about their directors, shareholders and other beneficial owners.

Pallas acts as a specialist property lender operating in the niche short term market. Pallas has issued this Privacy Notice to describe how we handle personal information that we hold about customers (collectively referred to as “you”).

 

How to contact us

 

Pallas is the data controller of your personal information (as defined under European Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”) with the UK Information Commissioner’s Office (“ICO”).

If you have any questions about this Privacy Notice or how we process your personal data, please contact us by sending an email to welcome@pallascapital.co.uk  or by writing to us at:

Pallas Capital Limited
128 City Road
London, EC1V 2NX
United Kingdom

Reference in this Privacy Notice to the Pallas Website refers to www.pallascapital.co.uk

What data we collect

  • Your name, address, telephone numbers, email address(s), date of birth, place of birth, nationality, tax/residency status, passport, employment, banking and financial details including those of any business that you run;
  • people connected with you such as your spouse, any joint mortgage holders, or other financial associates;
  • demographic and lifestyle information;
  • information we receive when making a decision about you, your loan or your application for such a loan;
  • information we receive when making a decision about you, your application as an investor and when updating the information held on you as an investor;
  • information that you provide by completing forms that we provide to you or you give us;
  • details of the loan(s) you have and have had with us and all transactions;
  • details of investments you make and have made with us, and all transactions;
  • details of when you contact us and when we contact you (e.g. copies of any correspondence);
  • details of how you applied for your loan or investment arrangement, together with any other information (including where obtained from third parties) which we reasonably need to operate your loan or investment agreement, make decisions about you or fulfil our regulatory obligations;
  • your preferences;
  • your technology;
  • your profile;
  • your CV and references in the case of staff;
  • your criminal convictions and the results of any checks we are required by law or regulations to undertake.


Sensitive data

We may capture sensitive data about you with regards to your or a related persons health if you advise of an issue that we may need to take into account in dealing with your loan, investment or dealing with you as a member of staff. We will ask you for your consent to hold this information but may retain this information where it would be in your best interests for us to do so or in order to protect us from a claim.

 

How we collect your data

 

We collect data when you, or someone acting on your behalf, make contact with us.

By providing us with this data you (or the person acting with consent on your behalf) agree to the processing of your data in accordance with this Privacy Notice.

By phone

We may use call number identification to recognise who is calling us and to have a short term record of calls received. We may record some calls for training, monitoring and record keeping purposes. We will capture information that you give us for our records in order to deal with your enquiry and process it in accordance with our processing basis as set out below.

By email

If you send us an email that is not encrypted any personal data within it may be at risk. We will capture and process the information in the email for our legitimate interest and legal purposes as set out below.

By post

When we receive an enquiry or a paper application or supporting documentation it will contain personal information for applicant(s) and possibly other parties in connection with the property(ies) and investments.

By on-line web form

When you input and submit information on our enquiry form.

Providing information to us on other people including via brokers

 In providing information to us about other people you warrant that you have their permission to give us their data and that you have provided them with our Privacy Notice so that they are aware of the basis on which we will process their information. We store information provided to us in electronic format.

Parties we may collect information from

We may collect information from:

  • You, someone acting on your behalf or someone associated with you such as your spouse, any joint mortgage holders, or other financial associates
  • Your employer and past employers (if required)
  • People who introduce you to us
  • Your professional advisers

We may also collect information about you from other providers such as:

  • credit reference agencies
  • fraud prevention and search agencies
  • via Google Analytics and other web search tools
  • social media
  • other providers of public information services such as land registry and Companies House

We only do this when we are considering to offer you a loan or manage any loan offered, considering you as an investor to manage such investments, or considering you for a job.

 

Who we share your data with 

 

We may share your information with other parties where we need to do so. We will only share information with them that is relevant to why we share it.

We share information where necessary with:

  • Our funders, professional advisers, contractors and third-party providers and partners.
    • funders may receive all personal information held including all information disclosed on your application such as your name, address, date of birth, financial information and credit and anti-fraud checks we carry out on you
    • professional advisors and contractors working for us may see any information that is held during the performance of their role – e.g. an auditor will be able to review all information held in our file where they are checking whether the loans we have advanced meets our policies and procedures and payments to and from investors. They would not, however, see all of your personal information when auditing our accounts
    • anyone wishing to acquire all or any part of our business will be able to access all information held as part of their due diligence in order to assess the quality of our business and any legal or regulatory risks they may inherit
    • third party providers will only have access to information relevant to the service provided. This covers any third party used to market to you who would only have access to your contact details and products you have used or expressed an interest in in order to determine what products and services we may wish to market to you (including via third party products and services) and to carry out that marketing. You can withdraw your consent to marketing at any time
  • other companies in the same group and associated companies
  • fraud prevention and credit agencies and tracing agencies if required (see checking with credit agencies below)
  • your intermediary about your application information or the performance of your loan – you may request us to cease disclosure at any time
  • any recruitment agency or search provider about your job application
  • any government body, law enforcement agency or regulatory body that we are required to


Credit Reference Agencies

When we carry out checks with Credit Reference Agencies (CRA) we supply information to them based on the details you provide. We provide information to you on this before we carry out the search. The credit agencies have their own basis on which they process your data and you can view their privacy notices here:

Callcredit: www.callcredit.co.uk/crain

Equifax: www.equifax.co.uk/crain.html

Experian: www.experian.co.uk/crain/index.html

CreditSafe Supporting GDPR | Creditsafe

We may also carry out checks with them in order to identify you and for fraud prevention purposes.

Please ask us if you require details of the CRAs or any other agencies we may pass your information to and who we receive information from about you.

Fraud Prevention Agencies

We may need to confirm your identity before we provide products or services to you or your business.

Once you have become our customer, we share your personal information as needed to help detect money-laundering and fraud risks. We may use Fraud Prevention Agencies (FPAs) to help us with this.

Both Pallas and FPAs can only use your personal information if we have a good reason to do so. It must be needed either for us to obey the law or regulations, or for a ‘legitimate interest’.

We use the information to:

  • Confirm identities.
  • Help prevent money laundering and fraud.
  • Fulfil any contracts you or your business has with us.

Pallas or an FPA may allow law enforcement agencies to access your personal information. This is to support their duty to detect, investigate, prevent and prosecute crime.

FPAs can keep personal data for different lengths of time. They can keep your data for up to six years if they find a risk of money-laundering or fraud.

Below are examples of the personal data that is used:

  • Name
  • Date of birth
  • Residential address
  • History of where you have lived
  • Contact details, such as email addresses and phone numbers
  • Financial data
  • Data relating to your or your business’ products or services
  • Employment details
  • Data that identifies computers or other devices you use to connect to the internet. This includes your Internet Protocol (IP) address

Pallas and FPAs may process your personal information in systems that look for fraud by studying patterns in the data. We may find that an account is being used in ways that fraudsters work. Or we may notice that an account is being used in a way that is unusual for you or your business. Either of these could indicate a possible risk of fraud or money-laundering.

If Pallas or an FPA decide there is a risk of fraud, we may stop activity on the accounts or block access to them. FPAs will also keep a record of the risk that you or your business may pose. This may result in other organisations refusing to provide you with products or services, or to employ you.

FPAs may send personal information to countries outside the European Economic Area (EEA). When they do, there will be a contract in place to make sure the recipient protects the data to the same standard as the EEA. This may include following international frameworks for making data sharing secure.

The fraud prevention agencies have their own basis on which they process your data and you can view their privacy notice here:

CIFAS Checkmyfile | Privacy & Cookies

National SIRA Privacy Policy

 

Lawful bases of processing data

 

The information we gather and use will vary according to why we are processing it. For example, we will use all the information we gather such as your name, address, date of birth, financial information, and employment details in order to help us determine whether or not to offer you a loan  whereas we would only use your name, contact details, what products you have taken with us or have enquired about and preferences to determine what marketing we may send to you.

We will hold and process your data for the performance of a contract and our legitimate interests to:

  • Determine whether or not to offer a loan
  • Manage any loan advanced through to redemption
  • Manage any relationship with intermediaries including a record of introductions, payments made and other relevant information appropriate to managing the relationship
  • Manage the relationship with investors or anyone applying to become an investor and to maintain appropriate records relevant to that relationship
  • To manage business relationships with our professional advisers, contractors and third-party providers
  • To consider any application for a job, including CVs, and whether to progress it
  • Share information where necessary with funders, our professional advisers, contractors and third-party providers and anyone who may wish to acquire all or any part of our business
  • Share information with other companies in the same group and associated companies
  • Carry out checks with fraud prevention and credit agencies and tracing agencies if required (see Section 5)
  • Share information with your intermediary about your application or the performance of your loan – you may request us to cease disclosure at any time
  • Share information with any recruitment agency or search provider about your job application
  • Manage staff performance and employment obligations
  • Undertake analysis, produce models, statistics, reports and forecasts
  • Investigate and respond to complaints, disputes and where necessary to bring or defend legal claims

We will hold and process your data for legal purposes to:

  • Meet our legal obligations, e.g. when you exercise your rights under data protection law and make requests
  • Help identify you and meet our anti-money laundering obligations
  • Meet our legal and regulatory requirements and related disclosures to any government body, regulatory authority, law enforcement agency as required
  • For activities relating to the prevention, detection and investigation of criminal activity
  • For establishment and defence of legal rights

We will hold and process your data by consent for marketing purposes to keep you informed of:

  • Our products and services and those of any related group or company
  • Information contained in any newsletter we may issue
  • Products and services of any selected third-parties where you have agreed to this

We may use a third-party provider to issue marketing information to you but will not share your information with any other third-party for marketing purposes.

We may also gather information on our marketing to understand and measure the effectiveness of it.

We may also process your data by consent to:

  • Disclose information to the introducing intermediary about your loan application and the performance of your account
  • Disclose any personal data we hold about you to a third-party at your request
  • To hold personal sensitive data about you such as any health condition that may be disclosed to us that could impact how we manage our dealings with you.

 

How long we retain your data 

 

We will retain information for our legitimate interests and legal purposes as follows:

  • Loans advanced – up to 6 years after the loan has redeemed but may be longer where legal action has been taken or is pending
  • Enquiries and applications for loans not advanced – up to 18 months from the date the enquiry or application is marked not proceeded with – may be longer where a fraudulent application is made. We will retain any anti-money laundering information gathered for a period of up to 6 years
  • Investors – up to 6 years after all investing has ceased – may be longer where legal action has been taken or is pending
  • Investing enquiries – up to 18 months from the date the enquiry or application is marked not proceeded with – may be longer where a suspicion of criminal activity is made. We will retain any anti-money laundering information gathered for a period of up to 6 years
  • Intermediaries – up to 6 years from the end of our relationship
  • Professional advisers, contractors and third-party advisers – up to 6 years from the end of our relationship
  • Staff records – up to 6 years from the time of termination of employment or final actions, e.g. tribunals, unless there are ongoing legal actions or other issues such as criminal activity

Where you have consented to marketing, we will retain your contact information for marketing purposes until such time as consent is withdrawn.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “How to contact us” section.

 

Where we store your data and transers of data outside the EEA

 

All information is generally retained in the UK or within the European Economic Area (EEA). We also transfer all data to Pallas Group Pty. Limited (ABN 61 618 981892) in Australia, Pallas Group Limited (NZCN 8373196) in New Zealand and their related bodies corporate and affiliates (also in Australia and New Zealand). Our Australian entities are regulated by the Office of the Australian Information Commissioner (OAIC) and are compliant with Australian Privacy Principles (APPs) as set out in the Privacy Act 1988 (Cth). Our New Zealand entity is regulated by the Office of the New Zealand Privacy Commissioner.

You can find out more information about the Privacy Act 1988 (Cth) and the APPs from the Office of the Australian Information Commissioner (at www.oaic.gov.au or contactable by email at enquiries@oaic.gov.au) or about the Privacy Act 2020 and the IPPs from the Office of the New Zealand Privacy Commissioner (at www.privacy.org.nz or contactable by email at enquiries@privacy.org.nz).

You can find out more about data protection on the Information Commissioners website: https://ico.org.uk/

 

Your rights

 

Right to access

You have the right as an individual to request details on the information we hold about you. To exercise your right please contact us and ask for a Data Subject Access Request form.

Right to correct

You have the right to ask us to correct personal information you think is  inaccurate or incomplete.

Right to erase

You have the right to ask us to delete your personal information. This does not mean we will have to automatically delete all information held on you as we may still need to keep appropriate information to meet our legal obligations and for our legitimate interests.

Right to restriction of processing

You have the right to ask us to limit how we can use your personal information.

Right to object to processing

You have the right to object to the processing of your personal data.

Right to withdraw consent

When we use consent as our lawful basis you have the right to withdraw your consent at any time for future processing of your data.

Right to request to be forgotten

You have the right to request us to delete your personal data. We are obliged to comply with this request unless we have an overriding legal obligation or our legitimate interests (including performance of the contract) override your rights.

Right to data portability

You have the right to ask that we transfer the personal information you gave us to another organisation, or to you in a set machine readable format.

Changes to your data

Pallas is required to take reasonable steps to ensure that the data we hold about you is accurate and current. Please keep us informed of any changes to the personal information that you have provided to us.

Exercising your rights

If you contact us to exercise any of these rights we may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. There are certain laws which may allow or require us to refuse to provide you with access to some or all the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions. In all cases we will respond to you without delay and at the latest within one month of receipt of the request.

If we do not action your right to exercise your request

If we fail to action your request without delay and by the latest one month from the date of your request we must have told you why we have refused your request – e.g. our legitimate interests override your rights. If you have not had a response or do not agree with our assessment then you have the right to complain – see right to complain below.

Right to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details in Section 2 of this Privacy Notice.

You also have the right to make a complaint to the Information Commissioners Office (ICO). You can make a complaint to them via their website https://ico.org.uk/make-a-complaint/ or by calling them on 0303 123 1113.

The ICO’s address is:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

 

Wesbite and cookies

 

Third party links and sites

If you follow any links to third party external websites from our Website, the Privacy Notice will not apply to those websites which may have their own policies relating to privacy and data collection and website usage. If you choose to access any linked website or to provide any personal information on such websites you should review their policies and terms of use to learn more about how they may use your personal information. We are not responsible, and will not be liable, for the operations or policies of any third-party external website.

Website Host Click Stream Data

When you visit and browse our Website, we may collect personal information for statistical, reporting and maintenance purposes. Generally, the personal information collected by the hosts will not be used to identify you.

The information may include:

  • the number of users visiting our Website and the number of pages viewed;
  • the date, time and duration of a visit;
  • the IP address of your computer; or
  • the path taken through our Website.

The hosts may use this information to administer and/or improve the performance of our Website, including to assist with the diagnosis of and to provide support for any issues with our Website.

Cookies

We may collect personal information about you automatically using cookies or similar technologies. Cookies are small text files that are transferred to a user’s computer hard drive by a website for the purpose of storing information about a user’s identity, browser type or website visiting patterns. If we do use cookies, to allow us to personalise your browsing and experience on our Website and your access to these sites, a cookie is downloaded onto your computer’s hard drive when you first log on to our Website. You can adjust your internet browser to disable cookies, however we may not be able to provide you with all the service or functionality you require on our Website if you choose to do so.

Advertising

If we decide to use Google and/or other third-party service providers to serve ads on our behalf across the Internet and sometimes on our Website, then they may collect anonymous information about your visits to our Website (not including your name, address, email address or telephone number). They may also use information about your visits to the Website and other websites to target advertisements for goods and services in order to provide more relevant advertisements about goods and services of interest to you.

 

Changes to this Privacy Notice

 

Pallas reserves the right to change this Privacy Notice as we may deem necessary or as may be required by law. You should check our Website for changes from time to time.

Any changes will be immediately posted on our Website and you are deemed to have accepted the terms of the Privacy Notice on your first use of the Website following the alterations.

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