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Privacy Policy
This Privacy Policy sets out how we, Plutus Business Finance Limited, collect, store and use information
about you when you use or interact with our website, https://www.plutusfinance.co (our website) and
where we otherwise obtain or collect information about you. This Privacy Policy is effective from 01 March
2025.
This Privacy Policy, together with our data handling practices, are designed to comply with the General
Data Protection Regulation (Regulation (EU) 2016/769) (GDPR) as amended by the Data Protection Act
2018 and the Data Protection, Privacy And Electronic Communications (Amendments Etc)(EU Exit)
Regulations 2020.
Contents
● Summary
● Our details
● Information we collect when you visit our website
● Information we collect when you contact us
● Our use of profiling
● How we collect or obtain information about you from third parties
● Disclosure and additional uses of your information
● How long we retain your information
● How we secure your information
● Transfers of your information outside the European Economic Area
● Your rights in relation to your information
● Your right to object to the processing of your information for certain purposes
● Sensitive Personal Information
● Changes to our Privacy Policy
● Children’s Privacy
● California Do Not Track Disclosures
● Copyright, credit and logo
Summary
This section summarises how we obtain, store and use information about you. It is intended to provide a
very general overview only. It is not complete in and of itself and it must be read in conjunction with
the corresponding full sections of this Privacy Policy.
● Data controller: Plutus Business Finance Limited, (trading as Plutus)
● How we collect or obtain information about you:
o when you provide it to us (e.g. by contacting us),
o from your use of our website, using cookies and similar technologies,
o occasionally, from third parties.
● Information we collect: name, contact details, payment information e.g. your credit or debit card
details, IP address, information from cookies, information about your computer or device (e.g.
device and browser type), information about how you use our website (e.g. which pages you have
viewed, the time when you view them and what you clicked on, the geographical location from
which you accessed our website (based on your IP address), company name or business name
(if applicable), and VAT number (if applicable).
● How we use your information: for administrative and business purposes (particularly to contact
you, to improve our business and website, to fulfil our contractual obligations, to analyse your use
of our website, to store your preferences such as your preferred language, how many search
results you wish to have shown per page and whether or not you wish to have Google’s
SafeSearch filter turned on and in connection with our legal rights and obligations.
● Disclosure of your information to third parties: only to the extent necessary to run our
business, to our service providers, to fulfil any contracts we enter into with you, and where
required by law or to enforce our legal rights.
● Do we sell your information to third parties (other than in the course of a business sale or
purchase or similar event):No
● How long we retain your information: for no longer than necessary, taking into account any
legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we
have for using your information (e.g. your consent, performance of a contract with you or our
legitimate interests as a business), for recruitment purposes to retain candidate information for
future opportunities and certain additional factors described in the main section below entitled
How long we retain your information. For specific retention periods in relation to certain
information which we collect from you, please see the main section below entitled How long we
retain your information.
● How we secure your information: using appropriate technical and organisational measures
such as storing your information on secure servers, only granting access to your information
where necessary, by ensuring wherever possible that your information is shared with third parties
on a pseudonymised or anonymised basis and by imposing confidentiality obligations on third
parties with whom we share your personal information.
● Use of cookies and similar technologies: We use cookies and similar information-gathering
technologies such as Google Analytics on our website including essential, functional, and
analytical cookies. For more information, please visit our cookies policy here:
plutusfinance.co/cookies
● Transfers of your information outside the European Economic Area: In certain circumstances
we transfer your information outside of the European Economic Area to the United States of America.
Where we do so, we will ensure appropriate safeguards are in place, including the third parties we
use who transfer your information outside the European Economic Area have self-certified
themselves as compliant with the EU-U.S. Privacy Shield.
● Use of automated decision making and profiling: we use profiling through the use of web
analytics and cookies.
● Your rights in relation to your information
o to access your information and to receive information about its use
o to have your information corrected and/or completed
o to have your information deleted
o to restrict the use of your information
o to receive your information in a portable format
o to object to the use of your information
o to withdraw your consent to the use of your information
o to complain to a supervisory authority
● Sensitive personal information: we do not knowingly or intentionally collect what is commonly
referred to as ‘sensitive personal information’. Please do not submit sensitive personal
information about you to us. For more information, please see the main section below entitled
Sensitive Personal Information.
Our details
We are the data controller in respect of our website. You can contact us by writing to Avon House,
Avonmore Road, London, United Kingdom, W14 8TS or sending an email to declan@plutusfinance.co .
Our legal name is Plutus Business Finance Limited. Our company registration number is 15204688.
‘Plutus’ is a registered trading name of Plutus Business Finance Limited.
If you have any questions about this Privacy Policy, please contact us.
Information we collect when you visit our website
We collect and use information from website visitors in accordance with this section and the section
entitled Disclosure and additional uses of your information.
E-Newsletter
When you sign up for our e-newsletter or opt to receive news or offers from us or related third parties over
the phone or online, we collect your name and email address.
Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: you give your consent to us sending you our e-newsletter by signing up to receive it using the
steps described above.
Transfer and storage of your information
We use a third party service to send out our e-newsletter and administer our mailing list, our third party
telephone service provider Elastic Inc. (trading as Close CRM) Their privacy policy is available here:
https://www.close.com/privacy.
Information you submit to subscribe for our e-newsletter may be stored outside the European Economic
Area on our third party mailing list provider’s servers. For further information about the safeguards used
when your information is transferred outside the European Economic Area, see the section of this privacy
policy below entitled Transfers of your information outside the European Economic Area.
Web server log information
We use a third party server to host our website called Wix.com Ltd (a copy of their privacy policy is
available at https://www.wix.com/about/privacy). However please note that we will soon be migrating our
web server host to Wordpress (a copy of their privacy policy is available at
https://wordpress.org/about/privacy/). Our website server automatically logs the IP address you use to
access our website as well as other information about your visit such as the pages accessed, your
browser version and operating system, the duration of your stay, visits by country and overall visits per
month. Please note that this data does not correlate so we would not be able to identify which browser a
particular IP address is using.
Our servers are distributed across the Wix.com server network in the United States of America, European
Union and third countries.
Use of website server log information for IT security purposes
We do not use the server logs for any type of analysis.
We do not make, nor do we allow our hosting provider to make, any attempt to identify you from the
information collected via server logs.
Cookies and similar technologies
Cookies are data files which are sent from a website to a browser to record information about users for
various purposes.
We use cookies and similar technologies on our website, including essential and analytical cookies. For
further information on how we use cookies, please see our cookies policy which is available here:
plutusfinance.co/cookies
You can reject some or all of the cookies we use on or via our website by changing your browser settings,
but doing so can impair your ability to use our website or some or all of its features. For further
information about cookies, including how to change your browser settings, please visit
www.allaboutcookies.org or see our cookies policy.
Contact form
When you contact us using our contact form, we collect your name, email address and mobile telephone
number. We also collect any other information you provide to us when you complete the contact form
such as your business name, business financial information and enquiry-related information you provide
to us. If you do not provide the mandatory information required by our contact form, you will not be able to
submit the contact form and we will not receive your enquiry.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation).
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of
correspondence.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter
into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with
goods or services or taking steps at your request prior to providing you with our goods and services (for
example, providing you with information about such goods and services), we will process your information
in order to do so).
Transfer and storage of your information
Messages you send us via our contact form may be stored outside the European Economic Area on our
third party hosting provider’s servers worldwide. Our third party hosting provider is Wix.com Their privacy
policy is available here: https://www.wix.com/about/privacy.
For further information about the safeguards used when your information is transferred outside the
European Economic Area, see the section of this privacy policy below entitled Transfers of your
information outside the European Economic Area.
Messages you send us via our contact form may be stored outside the European Economic Area on our
third party email provider’s servers worldwide. Our third party hosting provider is Google Mail. Their
privacy policy is available here: https://policies.google.com/privacy?hl=en
For further information about the safeguards used when your information is transferred outside the
European Economic Area, see the section of this privacy policy below entitled Transfers of your
information outside the European Economic Area.
Information we collect when you contact us
We collect and use information from individuals who contact us in accordance with this section and the
section entitled Disclosure and additional uses of your information.
Phone
When you contact us by phone, we collect your phone number and any information provided to us during
your conversation with us.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation)
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of
correspondence.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter
into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with
goods or services or taking steps at your request prior to providing you with our goods and services (for
example, providing you with information about such goods and services), we will process your information
in order to do so).
Transfer and storage of your information
Information about your call, such as your phone number and the date and time of your call, is processed
by our third party telephone service provider Elastic Inc. (trading as Close CRM) Their privacy policy is
available here: https://www.close.com/privacy.
Information about your phone call will be stored by our third party telephone service provider outside the
European Economic Area. For further information about the safeguards used when your information is
transferred outside the European Economic Area, see the section of this privacy policy below entitled
Transfers of your information outside the European Economic Area.
When you send an email to the email address displayed on our website we collect your email address
and any other information you provide in that email (such as your name, telephone number and the
information contained in any signature block in your email).
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation).
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of
correspondence.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter
into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with
goods or services or taking steps at your request prior to providing you with our goods and services (for
example, providing you with information about such goods and services), we will process your information
in order to do so).
Transfer and storage of your information
We use a third party email provider to store emails you send us. Our third party email provider is Google
Mail.
Emails you send us will be stored in Google’s data servers globally.
Post
If you contact us by post, we will collect any information you provide to us in any postal communications
you send us.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation)
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of
correspondence.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter
into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with
goods or services or taking steps at your request prior to providing you with our goods and services (for
example, providing you with information about such goods and services), we will process your information
in order to do so).
Information collected or obtained from third parties
This section sets out how we obtain or collect information about you from third parties.
Information received from third parties
Generally, we do not receive information about you from third parties. It is possible that third parties with
whom we have had no prior contact may provide us with information about you.
Information that may be provided to us by third parties will generally be your name and contact details,
but will include any additional information about you which they provide to us.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter
into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where a third party has passed on information about
you to us (such as your name and email address) in order for us to provide services to you, we will
process your information in order to take steps at your request to enter into a contract with you and
perform a contract with you (as the case may be).
Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: where you have asked that a third party to share information about you with us and the purpose
of sharing that information is not related to the performance of a contract or services by us to you, we will
process your information on the basis of your consent, which you give by asking the third party in
question to pass on your information to us.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation).
Legitimate interests: where a third party has shared information about you with us and you have not
consented to the sharing of that information, we will have a legitimate interest in processing that
information in certain circumstances.
For example, we would have a legitimate interest in processing your information to perform our
obligations under a sub-contract with the third party, where the third party has the main contract with you.
Our legitimate interest is the performance of our obligations under our sub-contract.
Similarly, third parties may pass on information about you to us if you have infringed or potentially
infringed any of our legal rights. In this case, we will have a legitimate interest in processing that
information to investigate and pursue any such potential infringement.
Where we receive information about you in error
If we receive information about you from a third party in error and/or we do not have a legal basis for
processing that information, we will delete your information.
Information obtained by us from third parties
In certain circumstances (for example, to verify the information we hold about you or obtain missing
information we require to provide you with a service) we will obtain information about you from certain
publicly accessible sources, both EU and non-EU, such as the electoral register, Companies House,
online customer databases, business directories, media publications, social media, and websites
(including your own website if you have one), third party paid and open source AI, credit checking
agencies, insolvency registers, registers of judgments, and the Disclosure and Barring Service.
In certain circumstances will also obtain information about you from private sources, both EU and
non-EU, such as lenders, finance brokers and introducers.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter
into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where you have entered into a contract or requested
that we enter into a contract with you, in certain circumstances, we will obtain information about you from
public sources in order to enable us to understand your business and provide services to you or services
to a sufficient standard.
For example, we would obtain and/or verify your email address from your website or from a directory
where you ask us to send you information by email but we do not possess the information or we need to
confirm that we have recorded your email address correctly.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation).
Legitimate interests: in certain circumstances, we will have a legitimate interest in obtaining information
about you from public and private sources. For example, if you have infringed or we suspect that you
have infringed any of our legal rights, we will have a legitimate interest in obtaining and processing
information about you from such sources in order to investigate and pursue any suspected or potential
infringement.
Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: we may obtain information from third parties, such as credit checking agencies, where you
have consented to them sharing information with us by confirming the same by email or in writing.
Additional information that we request from you directly.
This section sets out how we obtain or collect information about you that we request in our customer
onboarding or staff applications processes.
Information received directly from you
When we onboard you as a new customer and process your service requests, we require identity
checking information and data relating to our ‘know your customer’ checks. This information may include
certified copies of passports or driving licences, previous addresses, proof of address such as bank
statements or utility bills, and any other information we directly request for these purposes.
We also collect additional information from you directly if you make a job application to us through our
website. In this case, the information we collect may include identity and address confirmation
documentation as above, as well as information from referees and previous employers.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter
into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where you send us your information in order to allow us
to provide you with the services you have requested, we will process your information in order to take
steps at your request to enter into a contract with you and perform a contract with you (as the case may
be).
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation).
Legitimate interests: where you provide us directly with your information and you have not consented to
the sharing of that information, we will have a legitimate interest in processing that information in order to
administer and operate our business, to provide services to customers and to hire and employ staff.
Our use of automated decision-making and profiling
We use automated decision making and profiling on our website. We do not consider that this has any
legal effect on you or similarly significantly affects you.
You have the right to object to our use of automated decision making and profiling described in this
section. You can do that by opting-out of cookies and similar technologies in accordance with the method
described in the relevant section below. If you do not want us to process your actual IP address (usually
the IP address assigned to you by your Internet Service Provider) when you visit our website, you can use
a Virtual Private Network (VPN) or a free service such as Tor.
You can find out more about our use of cookies and similar technologies (including the legal basis on
which we use them) and how to opt out from them in our cookies policy, which is available here:
plutusfinance.co/cookies
Automated decision making
Automated decision making is decision making by technological means (i.e. by a machine) without human
involvement.
Use of automated decision making for display advertising via Google Adwords, Facebook and LinkedIn
We automate the display advertisements containing our products and services on other websites you
visit, based on the fact that you have visited our website using cookies. For further information on the
cookies we use, please see our cookies policy which is available here: plutusfinance.co/cookies
Logic involved: automatically displaying advertisements to individuals who have visited our website
results in increased efficiencies and costs savings for us than manually displaying advertisements or
displaying advertisements by different means.
Significance and envisaged consequences: cookies will be used to recognise the fact that you have
visited our website in order to display advertisements to you (unless you have blocked such cookies) and
will collect information about your online behaviour.
How to object: you can block these cookies by using the cookies control management tool on your site.
or for Google DoubleClick, by opting out of seeing personalised ads by following the instructions here:
https://support.google.com/ads/answer/2662922?hl=en-GB]. For further information, please see our
cookies policy: plutusfinance.co/cookies
Our use of profiling
We use profiling on our website.
You have the right to object to our use of profiling described in this section. You can do that by opting-out
of cookies and similar technologies in accordance with the method described in the relevant section
below. If you do not want us to process your actual IP address (usually the IP address assigned to you by
your Internet Service Provider) when you visit our website, you can use a Virtual Private Network (VPN)
or a free service such as Tor.
You can find out more about our use of cookies and similar technologies (including the legal basis on
which we use them) and how to opt out from them in our cookies policy, which is available here:
plutusfinance.co/cookies
Profiling
Profiling is any form of automated processing of your information to evaluate personal aspects about you,
in particular to analyse or predict things like your performance at work, economic situation, health,
personal preferences, interests, reliability, behaviour, location or movements.
Use of profiling for web analytics
Our web analytics services, Wix (soon to be replaced by Wordpress) and Google Analytics, collects
information such as your location (based on your IP address) and your behaviour (based on cookies)
when you access our website (such as the pages you visit and what you click on). We will only process
information from cookies if you have consented to us setting cookies on your computer in accordance
with our cookies policy (plutusfinance.co/cookies). Information collected about you, once collected, is
anonymised and stored on an aggregate basis.
Logic involved: by automatically analysing and categorising information such as the location (based on
IP address) as well as the behaviour and devices of visitors to our website (using cookies), we are able to
gain a better understanding of what our website visitors want (in terms of the content of our website and
our products), how to improve our website and how to advertise and market our services to them.
Significance and envisaged consequences: cookies will be used to track and store information about
your behaviour and device on our website (unless you have opted out from receiving such cookies by
switching off the relevant cookie type settings using our online cookie control tool on our website) and
your location will be analysed based on your IP address.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation).
Legitimate interest: understanding how our website users access and interact with our site in order to
better understand our customers and to improve our products and services for those users.
Disclosure and additional uses of your information
This section sets out the circumstances in which we will disclose information about you to third parties
and any additional purposes for which we use your information.
Disclosure of your information to service providers
We endeavour to share your information with third parties only to the minimum extent necessary to
enable us to efficiently and effectively run our business.
We use a number of third parties to provide us with services which are necessary to run our business or
to assist us with running our business and who process your information for us on our behalf. These
include the following:
● Telephone provider: Elastic Inc. (trading as Close CRM)
● Email provider: Google Mail
● CRM provider: Elastic Inc. (trading as Close CRM)
● Web developer: Wix.com / Wordpress
● Hosting provider: Wix.com / Wordpress
● VPN Provider: Nordpass / Nord VPN
● Lead Generation provider: LinkedHelper
● Professional database provider: Pitchbook
● Email archiving provider: Google Mail
● Open source AI software providers: ChatGPT
● Virtual data room provider: Slack
● Accounting software provider: Xero
● Document signing software: Doc2
●Mailshot management software provider: Woodpecker
●Other software providers: Lenders
Our third party service providers are located in the UK and the United States.
Your information will be shared with these service providers where necessary to provide you with the
service you have requested, whether that is accessing our website or ordering goods and services from
us.
We do not display the identities of all of our service providers publicly by name for security and
competitive reasons. If you would like further information about the identities of our service providers,
however, please contact us directly by email and we will provide you with such information where you
have a legitimate reason for requesting it (where we have shared your information with such service
providers, for example).
Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation).
Legitimate interest relied on: where we share your information with these third parties in a context other
than where it is necessary to perform a contract (or take steps at your request to do so), we will share
your information with such third parties in order to allow us to run and manage our business efficiently.
Legal basis for processing: necessary to perform a contract and/or to take steps at your request prior to
entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: we may need to share information with our service
providers to enable us to perform our obligations under that contract or to take the steps you have
requested before we enter into a contract with you.
Disclosure of your information to other third parties
We disclose your information to other third parties in specific circumstances, as set out below.
Providing information to third parties such as Google Inc. Google collects information through our
use of Google Analytics on our website. Google uses this information, including IP addresses and
information from cookies, for a number of purposes, such as improving its Google Analytics service.
Information is shared with Google on an aggregated and anonymised basis. To find out more about what
information Google collects, how it uses this information and how to control the information sent to
Google, please see the following page: https://www.google.com/policies/privacy/partners/.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation).
Legitimate interest(s): meeting our contractual obligations to Google under our Google Analytics Terms
of Service (https://www.google.com/analytics/terms/us.html)
You can opt out of Google Analytics by installing the browser plugin here:
https://tools.google.com/dlpage/gaoptout
Transfer and storage of your information
Information collected by Google Analytics is stored outside the European Economic Area on Google’s
servers in the United States of America.
For further information about the safeguards used when your information is transferred outside the
European Economic Area, see the section of this privacy policy below entitled Transfers of your
information outside the European Economic Area.
Sharing your information with third parties, which are either related to or associated with the
running of our business, where it is necessary for us to do so. These third parties include our
accountants, advisors, insurers, business travel and banking services. Further information on each
of these third parties is set out below.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation).
Legitimate interest: running and managing our business efficiently.
Accountants
We share information with our accountants for tax purposes. For example, we share invoices we issue
and receive with our accountants for the purpose of completing tax returns and our end of year accounts.
Advisors
Occasionally, we obtain advice from advisors, such as accountants, financial advisors, lawyers We will
share your information with these third parties only where it is necessary to enable these third parties to
be able to provide us with the relevant advice.
Insurers
We will share your information with our insurers where it is necessary to do so, for example in relation to a
claim or potential claim we receive or make or under our general disclosure obligations under our
insurance contract with them.
Affiliates, introducers and business partners
We will share your information with our affiliates, introducers and business partners who pass on referrals
to us or to whom we share customer information so that they can quote for services you have requested.
Independent contractors.
We will share your information with our independent contractors in order to enable them to facilitate the
administration of our business activities and processes.
FX Brokers
We will share your information with our FX brokers in order to facilitate currency exchange transactions in
connection with our standard business services.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation).
Legitimate interest: running and managing our business effectively.
Legal basis for processing: necessary to perform a contract or to take steps at your request prior to
entering into a contract] (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: we need to share your information with other companies
in order to be able to meet our contractual obligations to you or to take steps at your request prior to
entering a contract, for example because of the services or information you have requested.
We do not display the identity of the other third parties we may share information with by name for
security and competitive reasons. If you would like further information about the identities of such third
parties, however, please contact us directly by email and we will provide you with such information where
you have a legitimate reason for requesting it (where we have shared your information with such third
parties, for example).
Where appropriate, we require third party processors to sign a written data processing agreement with us
to control how they handle the information we share with them.
Sharing your information with a prospective or actual purchaser or seller in the context of a
business or asset sale or acquisition by us, a merger or similar business combination event,
whether actual or potential.
Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation).
Legitimate interest(s): sharing your information with a prospective purchaser, seller or similar person in
order to allow such a transaction to take place.
Disclosure and use of your information for legal reasons
Indicating possible criminal acts or threats to public security to a competent authority
If we suspect that criminal or potential criminal conduct has occurred, we will in certain circumstances
need to contact an appropriate authority, such as the police. This could be the case, for instance, if we
suspect that a fraud or a cyber crime has been committed or if we receive threats or malicious
communications towards us or third parties.
We will generally only need to process your information for this purpose if you were involved or affected
by such an incident in some way.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation).
Legitimate interests: preventing crime or suspected criminal activity (such as fraud).
In connection with the enforcement or potential enforcement our legal rights:
We will use your information in connection with the enforcement or potential enforcement of our legal rights,
including, for example, sharing information with debt collection agencies if you do not pay amounts owed
to us when you are contractually obliged to do so.
Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual
(such as legal rights that we have under copyright law or tort law).
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation).
Legitimate interest: enforcing our legal rights and taking steps to enforce our legal rights.
In connection with a legal or potential legal dispute or proceedings:
We may need to use your information if we are involved in a dispute with you or a third party for example,
either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation).
Legitimate interest(s): resolving disputes and potential disputes.
For ongoing compliance with laws, regulations and other legal requirements:
We will use and process your information in order to comply with legal obligations to which we are
subject. For example, we may need to disclose your information pursuant to a court order or subpoena if
we receive one or to the National Crime Agency in connection with suspected or potential money
laundering matters.
Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data
Protection Regulation).
Legal obligation(s): legal obligations to disclose information which are part of the laws of England and
Wales or if they have been integrated into the United Kingdom’s legal framework (for example in the form
of an international agreement which the United Kingdom has signed).
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection
Regulation).
Legitimate interest: where the legal obligations are part of the laws of another country and have not
been integrated into the United Kingdom’s legal framework, we have a legitimate interest in complying
with these obligations.
How long we retain your information
This section sets out how long we retain your information. We have set out specific retention periods
where possible. Where that has not been possible, we have set out the criteria we use to determine the
retention period.
Retention periods
Server log information: we retain information on our server logs for a short period of time in the case of
error logs; access logs are retained for a reasonable period and then deleted.
Order information: when you sign a business finance contract with one of our lenders, we retain that
information for six years following the end of the financial year in which your finance agreement is
concluded, in accordance with our legal obligation to keep records for tax purposes.
Correspondence and enquiries: when you make an enquiry or correspond with us for any reason, by
email we will retain your information for as long as it takes to respond to and resolve your enquiry, and for
a maximum of six further months, after which point we will delete your information.
Careers enquiries: for recruitment purposes, applicant’s personal details are saved for six months if they
are not employed by us. We may in certain circumstances choose to save personal details of potential
applicants for longer than six months if the applicant expresses a wish to be considered in the future.
This would be if a candidate was interesting to us but we had no space at the current time to hire. All
potential candidates have the opportunity to opt out of their details being held for any length of time.
Criteria for determining retention periods
In any other circumstances, we will retain your information for no longer than necessary, taking into
account the following:
● the purpose(s) and use of your information both now and in the future (such as whether it is
necessary to continue to store that information in order to continue to perform our obligations
under a contract with you or to contact you in the future);
● whether we have any legal obligation to continue to process your information (such as any
record-keeping obligations imposed by relevant law or regulation);
● whether we have any legal basis to continue to process your information (such as your consent);
● how valuable your information is (both now and in the future);
● any relevant agreed industry practices on how long information should be retained;
● the levels of risk, cost and liability involved with us continuing to hold the information;
● how hard it is to ensure that the information can be kept up to date and accurate; and
● any relevant surrounding circumstances (such as the nature and status of our relationship with
you).
How we secure your information
We take appropriate technical and organisational measures to secure your information and to protect it
against unauthorised or unlawful use and accidental loss or destruction, including:
● using secure servers to store your information
● using encrypted servers and end-to-end encrypted transfers of your data
● only sharing and providing access to your information to the minimum extent necessary, subject
to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
and
● verifying the identity of any individual who requests access to information prior to granting them
access to information;
- Transmission of information to us by email
- Transmission of information over the internet is not entirely secure, and if you submit any information to
us over the internet (whether by email, via our website or any other means), you do so entirely at your
own risk.
We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities
or any other form of loss or damage suffered by you as a result of your decision to transmit information to
us by such means.
Transfers of your information outside the European
Economic Area
Your information will be transferred and stored outside the European Economic Area (EEA) in the
circumstances set out below. We will also transfer your information outside the EEA or to an international
organisation in order to comply with legal obligations to which we are subject (compliance with a court
order, for example). Where we are required to do so, we will ensure appropriate safeguards and
protections are in place.
Google Analytics
Information collected by Google Analytics (your IP address and actions you take in relation to our
website) is transferred outside the EEA and stored on Google’s servers. You can access Google’s privacy
policy here: https://www.google.com/policies/privacy/
Country of storage: United States of America. This country is not subject to an adequacy decision by the
European Commission.
Safeguard(s) used: Google has self-certified its compliance with the EU-U.S. Privacy Shield which is
available here: https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield is an approved
certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted
under Article 46(2)(f) of the General Data Protection Regulation. You can access the European
Commission decision on the adequacy of the EU-U.S. Privacy Shield here:
http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.html
Your rights in relation to your information
Subject to certain limitations on certain rights, you have the following rights in relation to your information,
which you can exercise by writing to Avon House, Avonmore Road, London, United Kingdom, W14 8TS
or sending an email to declan@plutusfinance.co:
● to request access to your information and information related to our use and processing of
your information;
● to request the correction or deletion of your information;
● to request that we restrict our use of your information;
● to receive information which you have provided to us in a structured, commonly used and
machine-readable format (e.g. a CSV file) and the right to have that information transferred to
another data controller (including a third party data controller);
● to object to the processing of your information for certain purposes (for further information,
see the section below entitled Your right to object to the processing of your information for certain
purposes); and
● to withdraw your consent to our use of your information at any time where we rely on your
consent to use or process that information. Please note that if you withdraw your consent, this will
not affect the lawfulness of our use and processing of your information on the basis of your
consent before the point in time when you withdraw your consent.
In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge
a complaint with a supervisory authority, in particular in the Member State of your habitual residence,
place of work or of an alleged infringement of the General Data Protection Regulation.
For the purposes of the UK, the supervisory authority is the Information Commissioner’s Office (ICO), the
contact details of which are available here: https://ico.org.uk/global/contact-us/
Further information on your rights in relation to your personal data as an individual.
The above rights are provided in summary form only and certain limitations apply to many of these rights.
For further information about your rights in relation to your information, including any limitations which
apply, please visit the following pages on the ICO’s website:
rights/; and
● https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/
You can also find out further information about your rights, as well as information on any limitations which
apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the
General Data Protection Regulation, which is available here:
http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf
Verifying your identity where you request access to your information.
Where you request access to your information, we are required by law to use all reasonable measures to
verify your identity before doing so.
These measures are designed to protect your information and to reduce the risk of identity fraud, identity
theft or general unauthorised access to your information.
How we verify your identity
Where we possess appropriate information about you on file, we will attempt to verify your identity using
that information.
If it is not possible to identify you from such information, or if we have insufficient information about you,
we may require original or certified copies of certain documentation in order to be able to verify your
identity before we are able to provide you with access to your information.
We will be able to confirm the precise information we require to verify your identity in your specific
circumstances if and when you make such a request.
Your right to object to the processing of your information for certain purposes
You have the following rights in relation to your information, which you may exercise in the same way as
you may exercise by writing to Avon House, Avonmore Road, London, United Kingdom, W14 8TS or
sending an email to declan@plutusfinance.co.
● to object to us using or processing your information where we use or process it in order to carry
out a task in the public interest or for our legitimate interests, including ‘profiling’ (i.e.
analysing or predicting your behaviour based on your information) based on any of these
purposes; and
● to object to us using or processing your information for direct marketing purposes (including
any profiling we engage in that is related to such direct marketing).
For more information on how to object to our use of information collected from cookies and similar
technologies, please see the section entitled How to accept or reject cookies in our cookies policy, which
is available here: plutusfinance.co/cookies
Sensitive Personal Information
‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin,
political opinions, religious or philosophical beliefs, or trade union membership, genetic information,
biometric information for the purpose of uniquely identifying an individual, information concerning health
or information concerning a natural person’s sex life or sexual orientation.
We do not knowingly or intentionally collect sensitive personal information from individuals, and you must
not submit sensitive personal information to us.
If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be
considered to have explicitly consented to us processing that sensitive personal information under Article
9(2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal
information for the purposes of deleting it.
Changes to our Privacy Policy
We update and amend our Privacy Policy from time to time.
Minor changes to our Privacy Policy
Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new
effective date stated at the beginning of it. Our processing of your information will be governed by the
practices set out in that new version of the Privacy Policy from its effective date onwards.
Major changes to our Privacy Policy or the purposes for which we process your information
Where we make major changes to our Privacy Policy or intend to use your information for a new purpose
or a different purpose than the purposes for which we originally collected it, we will notify you by email
(where possible) or by posting a notice on our website.
We will provide you with the information about the change in question and the purpose and any other
relevant information before we use your information for that new purpose.
Wherever required, we will obtain your prior consent before using your information for a purpose that is
different from the purposes for which we originally collected it.
Children’s Privacy
Because we care about the safety and privacy of children online, we comply with the Children’s Online
Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of
children using the internet. We do not knowingly contact or collect information from persons under the age
of 18. The website is not intended to solicit information of any kind from persons under the age of 18.
It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or
deception of a third party. If we are notified of this, as soon as we verify the information, we will, where
required by law to do so, immediately obtain the appropriate parental consent to use that information or, if
we are unable to obtain such parental consent, we will delete the information from our servers. If you
would like to notify us of our receipt of information about persons under the age of 18, please do so by
sending an email to declan@plutusfinance.co
California Do Not Track Disclosures
“Do Not Track” is a privacy preference that users can set in their web browsers. When a user turns on a
Do Not Track signal in their browser, the browser sends a message to websites requesting that they do
not track the user. For information about Do Not Track, please visit www.allaboutdnt.org
At this time, we do not respond to Do Not Track browser settings or signals.
Copyright, credit and logo
This Privacy Policy is based on a General Data Protection Regulation (Regulation (EU) 2016/769)
(GDPR) compliant template provided by GDPR Privacy Policy, as amended by the Data Protection Act
2018 and the Data Protection, Privacy And Electronic Communications (Amendments Etc)(EU Exit)
Regulations 2020. For further information, please visit https://gdprprivacypolicy.org
The copyright in this Privacy Policy is either owned by, or licensed to, us and is protected by copyright
laws around the world and copyright protection software. All intellectual property rights in this document
are reserved.
Where we display the GDPR Privacy Policy logo on our website, this is used to indicate that we have
adopted a privacy policy template provided by GDPR Privacy Policy as the basis for this Privacy Policy.
Appendix 1
Safeguards for overseas transfers
● an adequacy decision by the European Commission. This is permitted under Article 45(1) of the
General Data Protection Regulation. The adequacy decision relied on by us is [insert reference to
adequacy decision e.g. Commission Decision 2004/411/EC in respect of the Isle of Man] and is
available here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm
● data protection policies adhered to by the data controller and other companies and entities within
our corporate group from time to time, which comply with applicable laws, known as “binding
corporate rules” or “BCRs” under Article 47 of the General Data Protection Regulation. This is
permitted under Article 46(2)(b) of the General Data Protection Regulation.
● standard data protection clauses adopted by the European Commission in accordance with its
committee examination procedure under Article 93(2) of the General Data Protection Regulation.
This is permitted under Article 46(2)(c) of the General Data Protection Regulation. These clauses
are available here: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protectio
n/standard-contractual-clauses-scc_en.
● standard data protection clauses adopted by the Information Commissioner’s Office and
approved by the European Commission pursuant to the committee examination procedure under
Article 93(2) of the General Data Protection Regulation. This is permitted under Article 46(2)(d) of
the General Data Protection Regulation. These clauses are available here
https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/international-transfers/interna
tional-data-transfer-agreement-and-guidance/.
● an approved code of conduct under Article 42 of the General Data Protection Regulation. This is
permitted under Article 46(2)(f) of the General Data Protection Regulation.
● EU-U.S. Privacy Shield, an approved certification mechanism under Article 42 of the General
Data Protection Regulation. This is permitted under Article 46(2)(f) of the General Data Protection
Regulation. You can access the EU-U.S. Privacy Shield: https://www.privacyshield.gov/welcome
and the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here:
http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.html
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