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Privacy Policy

This privacy policy governs the collection, storage and use of personal information by us on our website www.ablrate.com. It provides you with details about how your personal information is treated, your rights to that data, and how we use that data. By accessing our website and using the Ablrate Platform, you agree to this privacy policy in its entirety. If you don’t agree with this privacy policy as a whole or partially, you must not use the Ablrate website or services. The following are the definitions of terms used in this privacy policy;

“Ablrate”, “we”, “us” and “our” means Aviation and Tech Capital Limited;

“Ablrate Group” means Ablrate and any parent company or Subsidiary of Ablrate from time to time (including but not limited to Ablrate Assets Limited)

“you” and “your” means a user of the website and the services provided via it;

“Loan Contract” means the agreement between Lending Members and a Borrower comprising our standard Loan Conditions and Loan Contract Terms (and forming an individual and seperate Loan between the Borrower and Lending Member).

“Subsidiary” means any subsidiary company within the meaning of section 1159 of the Companies Act 2006 or any subsidiary undertaking within the meaning of section 1162 of the Companies Act 2006

This privacy policy was last updated on the 5th September 2016.

Please check back regularly to keep informed of updates to this privacy policy.

1. Who we are.

Aviation and Tech Capital Limited is a company incorporated in England and Wales, whose registered number is 07940046 and whose registered office is c/o Montgomery Swann, Scotts Sufferance Wharf, 5 Mill Street, City of London, Greater London, SE1 2DE and whose principal place of business is at Badgemore House, Gravel Hill, Henley-on-Thames. Oxon, RG9 4NR. Ablrate are registered with the Information Commissioner (ZA033501) and Ablrate authorised and regulated by the Financial Conduct Authority (FRN:724444).

We respect your right to privacy and will only process personal information you provide to us in accordance with the Data Protection Act 1998, the Privacy and Electronic Communications (EC Directive) Regulations 2003 and other applicable privacy laws.

If you have any questions about how we collect, store and use personal information, or if you have any other privacy-related questions, please do contact us on the Ablrate website www.ablrate.com.

2. Lender specific information.

If you are applying to be a member of Ablrate as a lender then this section explains the type of personal information we collect about you and how we may store, use and disclose your information.

2.1 The personal information we collect about you

(a) When you access, browse this website, submit personal information or apply to be a Lending Member of Ablrate and while you continue to be a member of Ablrate we will collect information from you which will include;

(i) your name;
(ii) your current and previous postal addresses;
(iii) your phone, fax and e-mail details;
(iv) your bank or building society account details and details of debit cards used to make transfers on Ablrate;
(v) your date of birth;
(vi) your passwords and security question answers;
(vii) comments you make on blogs and discussion forums on the website;
(viii) correspondence with us by email and post;
(ix) answers to questions required by Tracesmart for identification purposes (although these answers and questions will be deleted by Ablrate); and
(x) data about your activities using Ablrate.
(b) If you give us false or inaccurate information and we suspect or identify fraud, we will record this.
(c) If false or inaccurate information is provided and fraud is identified, details may be passed to fraud prevention 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

We and other organisations may access and use from other countries the information recorded by any fraud prevention agencies we may use.

(d) We may also collect anonymised data in order to analyse statistics for usage of the site, however this data will not carry any single user identification.

2.2 How we may store, use and disclose your information.

(a) Ablrate, third party data processors, agents and sub-contractors acting on our behalf, may collect, store and use your personal information for the following purposes:

(i) to authenticate and verify your identity and detect crime including money laundering;

(ii) to manage your Ablrate Lending Member’s account with us and update the records we hold about you from time to time;

(iii) to identify any fraud being committed;

(iv) to carry out statistical and market research;

(v) to carry out required regulatory checks;

(vi) to develop and improve our services and products;

(vii) to make this website available to you and to identify the products and services which you may be interested in;

(viii) where you have given us your consent, to disclose your personal and business information to lenders on the platform or third parties where sharing that data is material to the offering of credit by lenders. You explicitly agree to our ability to share this information in these circumstances.

(b) Any or all of the processes above may be automated.

(c) We may disclose your personal information as follows:

(i) to other members of Ablrate if required to enforce any Loan Contract. If we provide you with information about other Ablrate members for this purpose then you must only use it to communicate with us about your Loan Contract;

(ii) to a third party if it acquires all (or substantially all) of our business and/or assets in connection with the acquisition; and

(iii) where we are required to do so by applicable law, by a governmental body, law enforcement agency or regulatory agency.

(iv) to Ablrate Assets Limited for the purpose of setting up a secured loan or leasing finance product and/or enforcing a secured loan.

(v) to any member of the Ablrate Group of companies for the purposes of providing and administering the Ablrate platform and services.

(d) We will also provide transactional information to other members of Ablrate but this information will not include your bank payment details. Your account number may be used in the Loan Contract Terms. We are not responsible for misuse of this transactional information by Ablrate members but please let us know if you become aware of such misuse of this data.

(e) Details of the Borrowers account and how it is managed may be shared with credit reference agencies.

(f) We will not sell your data, rent your personal information unless you have specifically consented to the use of that data. If you do consent and later change your mind, contact us immediately and we will cease any such activity as soon as we are informed.

3. Borrower specific information

When you access, browse this website, submit personal information or apply to be a Borrower on Ablrate and while you continue to be a member of Ablrate we will collect information from you which will include;

3.1 The personal information we collect about you

(a) When you access, browse the website (including when you submit personal information to us through data entry fields on the website) or apply to be a member of Ablrate as a borrower, or use an agent to make a loan application on your behalf, and whilst you continue to be a member of Ablrate, we will collect information from you, which will include the following information:

(i)  your name and your business name;

(ii) your current and previous home postal addresses;

(iii) your business postal address;

(iv) your business phone, fax and e-mail details;

(v) your business bank or building society account details and details of debit cards used to make payments on Ablrate;

(vi) your date of birth;

(vii) your passwords and security question answers;

(viii) comments you make on blogs and discussion forums on the website;

(ix) correspondence with us by email and post;

(x) answers to questions required by Tracesmart for identification purposes (although these answers and questions will be deleted by Ablrate);

(xi) information provided in your application form; and

(xii) data about your activities using Ablrate.

(b) If you give us false or inaccurate information, either directly or through an agent, and we suspect or identify fraud, we will record this.

(c)If false or inaccurate information is provided and fraud is identified, details may be passed to fraud prevention 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

We and other organisations may access and use from other countries the information recorded by any fraud prevention agencies that we use.

(d) We may also collect anonymised data in order to analyse statistics for usage of the site, however this data will not carry any single user identification.

(e) We will check information about you held on our own records and also obtain information from credit reference agencies about you and your business partners’ personal credit behaviour and personal credit accounts if you are proprietors of a small business and are directors of that business, your business accounts, identity information on beneficial owners of the business, your personal financial partner’s personal accounts (if they are a director). If you are a director, we will seek confirmation that the residential address you provide is the same as that shown on the restricted register of directors’ usual address at Companies House.

(f) We may also search at fraud prevention agencies for information on your business, you, your personal financial partner (if they are a director), your business partners, beneficial owners and your addresses.

3.2 How we may store, use and disclose your information

(a) Ablrate or third party data processors, agents and sub-contractors acting on our behalf, may collect, store and use your personal information for the following purposes:

(i) to assess your application for credit, including by using scoring methods;

(ii) to check details on applications for credit and credit related and other facilities;

(iii) to verify your identity in order to prevent and detect crime and money laundering, including by using scoring methods;

(iv) to manage your Ablrate borrower account with us and update the records we hold about you from time to time;

(v) to identify fraud;

(vi) if you do not repay money you have borrowed, to trace your whereabouts and recover debts or enforce a Loan Contract;

(vii) to carry out statistical analysis and market research;

(viii) to carry out regulatory checks;

(ix) to develop and improve our services and products;

(x) to make this website available to you and to identify the products and services which you may be interested in;

(xi) where you have given us your consent, to contact you (including by SMS and e-mail) with products and services which we think may interest you; and

(xii) where you have given us your consent, to disclose your personal information to carefully chosen third parties so that they may contact you (including by SMS and e-mail) with products and services which they think may interest you.

(b) Any or all of the processes above may be automated.

(c) We may disclose your personal information as follows:

(i) to credit reference agencies who will record information about your application, your business, you and your business partners. For the avoidance of doubt we will not disclose any management account information you supply to us to credit reference agencies;

(ii) to credit reference and fraud prevention agencies, where it will be recorded by them, and supplied to other organisations to perform similar checks, trace your whereabouts and recover debts you owe;

(iii) we may provide information about your loans with Ablrate and how you manage them to credit reference agencies, where it will be recorded by them but we will not disclose information on your other loans outstanding that has been provided to us from credit reference agencies;

(iv) we may provide information about other loans outstanding with Ablrate Lending Members;

(v) to and via an organisation which provides a centralised matching service which it collects from mortgage and/or credit applications, for the purpose of preventing and detecting fraud;

(vi) to other members of Ablrate if required to enforce any Loan Contract. If we provide you with information about other Ablrate members for this purpose then you must only use it to communicate with us about your Loan Contract;

(vii) to a third party if it acquires all (or substantially all) of our business and/or assets in connection with the acquisition; and

(viii) where we are required to do so by applicable law, by a governmental body, law enforcement agency or regulatory agency.

(x) to Ablrate Assets Limited for the purpose of setting up a secured loan or asset finance product and/or enforcing a secured loan.

(xi) to any member of the Ablrate Group for the purposes of providing and administering the Ablrate platform and services.

(d) We will also provide transactional information to other members of Ablrate but this information will not include your postal address or payment details. The name of your business will be used in the Loan Contract Terms. We are not responsible for misuse of this transactional information by Ablrate members but you should let us know about any misuse of such information.

(e) We will not provide the following information to other Ablrate members:

(i) addresses and personal details of directors;

(ii) ownership of different shareholders;

(iii) employee details;

(iv) contact numbers or email addresses of the business; and

(v) any other data used in the verification of the directors.

(f) When applying for a loan you may choose to supply your personal information or other information about shareholders, directors or member’s financial position in order to secure a lower interest rate or to ensure you loan is funded. Please be aware this information is available to all registered members of Ablrate and other members may use this information. If you would like this personal information removing, please contact us.

(g) We will not disclose, sell or rent your personal information to any third party unless you have consented to this. If you do consent but later change your mind, you may contact us and we will cease any such activity.

3.3 What Credit Reference and Fraud Prevention Agencies Do?

(a) When credit reference agencies receive a search from us they will:

(i) place a credit search request on your file, which may be seen by others when you apply for credit elsewhere.

(ii) if your directors are also checked a search enquiry will appear on the credit files of you directors or any others who have been submitted as being involved in your business and who we may wish to have searched;

(iii) link together the previous and subsequent names advised by you, of anyone that is a party to the account;

(iv) place an enquiry or identification search on the record of any shareholder who is a beneficial owner and who we have checked;

(v) create a record of the name and address of your business and its proprietors if there is not one already.

(b) Credit reference agencies supply the following information to us:

(i) information about your business or company, such as previous applications for credit and the conduct of the accounts and also similar personal credit information in your name and of your business partners;

(ii) public information such as County Court Judgments (CCJs) and bankruptcies;

(iii) electoral register information on you and your business partners;

(iv) fraud prevention information; and

(v) confirmation or otherwise of the residential address information supplied by the directors match those on public record and that these addresses match those held by other credit reference agencies.

(c) Credit reference agencies will keep records of outstanding debt on file for six years after they are closed, whether settled by you or defaulted.

(d) Your information will not be used by credit reference agencies to create a blacklist or to make a decision.

(e) The information which we and other organisations may provide to the credit reference agencies and fraud prevention agencies about you, your business partners and details about your business may be supplied by credit reference agencies and fraud prevention agencies to other organisations and used by them to:

(i) prevent crime, fraud and money laundering by, for example checking details provided on applications for credit and credit related or other facilities;

(ii) check the operation of credit and credit-related accounts;

(iii) verify your identity if you or your business partner(s) applies for other facilities;

(iv) make decisions on credit and credit related services about you and/or your business partner, or your business;

(v) manage your personal, your business partner’s and/or business credit or credit related account(s);

(vi) trace your whereabouts and recover debts that you owe;

(vii) conduct other checks to prevent or detect fraud; and

(f) undertake statistical analysis and system testing.

Organisations may access and use from other countries the information recorded by fraud prevention agencies.

3.4 How we may store, use and disclose information provided to us about third parties

We may use information you or your agent provide to us about directors/business partners and shareholders of your business to verify their identity. We may also disclose information about your business partners and shareholders to credit reference agencies so you must be sure that you have their agreement to do this. Information on shareholders who are beneficial owners will be used and supplied to others only for the purpose of the performance of identity checks and with their specific consent.

4. Agent specific information

If you are applying to be a member of Ablrate as an agent for borrowers then this section explains the type of personal information we collect about you and how we may store, use and disclose your information.

4.1 The personal information we collect about you

(a)    When you access, browse the website (including when you submit personal information to us through data entry fields on the website) or apply to be a member of Ablrate as an agent, and whilst you continue to be a member of Ablrate, we will collect information from you, which will include the following information:

(i) your name and your business name;
(ii) your current and previous home postal addresses;
(iii) your business postal address;
(iv) your business phone, fax and e-mail details;
(v) your business bank or building society account details;
(vi) your date of birth;
(vii) your passwords and security question answers;
(viii) comments you make on blogs and discussion forums on the website;
(ix) correspondence with us by email and post;
(x) answers to questions required by Experian for identification purposes (although these answers and questions will be deleted by Ablrate);
(xi) information provided in your application form; and
(xii) data about your activities using Ablrate.
(b) If you give us false or inaccurate information and we suspect or identify fraud, we will record this.
(c) If false or inaccurate information is provided and fraud is identified, details will be passed to fraud prevention 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

We and other organisations may access and use from other countries the information recorded by fraud prevention agencies.

(d) We may also collect anonymised details about visitors to the website for the purposes of aggregate statistics or reporting purposes and to calculate referral fees. However, no single individual will be identifiable from the anonymised details we collect or disclose for these purposes.

(e) We will check information about you held on our own records and also obtain information from credit reference agencies about you and your business partners’ personal credit behaviour and personal credit accounts if you are proprietors of a small business and are directors of that business, your business accounts, identity information on beneficial owners of the business, your personal financial partner’s personal accounts (if they are a director). If you are a director, we will seek confirmation that the residential address you provide is the same as that shown on the restricted register of directors’ usual address at Companies House.

(f) We will also search at fraud prevention agencies for information on your business, you, your personal financial partner (if they are a director), your business partners, beneficial owners and your addresses.

4.2 How we may store, use and disclose your information

(a) We (or third party data processors, agents and sub-contractors acting on our behalf) may collect, store and use your personal information for the following purposes:

(i) to assess your creditworthiness;
(ii) to verify your identity in order to prevent and detect crime and money laundering, including by using scoring methods;
(iii) to manage your Ablrate agent account with us and update the records we hold about you from time to time;
(iv) to identify fraud;
(v) to carry out statistical analysis and market research;
(vi) to carry out regulatory checks;
(vii) to develop and improve our services and products;
(viii) to make this website available to you and to identify the products and services which you may be interested in;
(ix) where you have given us your consent, to contact you (including by SMS and e-mail) with products and services which we think may interest you; and
(x) where you have given us your consent, to disclose your personal information to carefully chosen third parties so that they may contact you (including by SMS and e-mail) with products and services which they think may interest you.
(b) Any or all of the processes above may be automated.
(c) We may disclose your personal information as follows:
(i) to credit reference agencies who will record information about your business, you and your business partners;
(ii) to credit reference and fraud prevention agencies, where it will be recorded by them, and supplied to other organisations to perform similar checks;
(iii) to and via an organisation which provides a centralised matching service which it collects from mortgage and/or credit applications, for the purpose of preventing and detecting fraud;
(iv) to other members of Ablrate if required to enforce any Loan Contract that you may have facilitated to put in place for a borrower;
(v) to any member of the Ablrate Group for the purposes of providing and administering the Ablrate platform and services.
(vi) to a third party if it acquires all (or substantially all) of our business and/or assets in connection with the acquisition; and
(vii) where we are required to do so by applicable law, by a governmental body or by a law enforcement agency.
(d)  We will not disclose, sell or rent your personal information to any third party unless you have consented to this. If you do consent but later change your mind, you may contact us and we will cease any such activity.

4.3     What Credit Reference and Fraud Prevention Agencies Do?

(a) When credit reference agencies receive a search from us they will:

(i) place a credit search request on your file, which may be seen by others when you apply for credit elsewhere.

(ii) if your directors are also checked a search enquiry will appear on the credit files of you directors or any others who have been submitted as being involved in your business and who we may wish to have searched;

(iii) link together the previous and subsequent names advised by you, of anyone that is a party to the account;

(iv) place an enquiry or identification search on the record of any shareholder who is a beneficial owner and who we have checked;

(v) create a record of the name and address of your business and its proprietors if there is not one already.

(b) Credit reference agencies supply the following information to us:

(i) information about your business or company, such as previous applications for credit and the conduct of the accounts and also similar personal credit information in your name and of your business partners;

(ii) public information such as County Court Judgments (CCJs) and bankruptcies;

(iii) electoral register information on you and your business partners;

(iv) fraud prevention information; and

(v) confirmation or otherwise of the residential address information supplied by the directors match those on public record and that these addresses match those held by other credit reference agencies.

(c) Credit reference agencies will keep records of outstanding debt on file for six years after they are closed, whether settled by you or defaulted.

(d) Your information will not be used by credit reference agencies to create a blacklist or to make a decision.

(e) The information which we and other organisations may provide to the credit reference agencies and fraud prevention agencies about you, your business partners and details about your business may be supplied by credit reference agencies and fraud prevention agencies to other organisations and used by them to:

(i) prevent crime, fraud and money laundering by, for example checking details provided on applications for credit and credit related or other facilities;

(ii) check the operation of credit and credit-related accounts;

(iii) verify your identity if you or your business partner(s) applies for other facilities;

(iv) make decisions on credit and credit related services about you and/or your business partner, or your business;

(v) manage your personal, your business partner’s and/or business credit or credit related account(s);

(vi) trace your whereabouts and recover debts that you owe;

(vii) conduct other checks to prevent or detect fraud; and

(f) undertake statistical analysis and system testing.

Organisations may access and use from other countries the information recorded by fraud prevention agencies.

4.4    How we may store, use and disclose information provided to us about third parties

We may use information you provide to us about directors/business partners and shareholders of your business to verify their identity. We may also disclose information about your business partners and shareholders to credit reference agencies so you must be sure that you have their agreement to do this. Information on shareholders who are beneficial owners will be used and supplied to others only for the purpose of the performance of identity checks and with their specific consent.

For details of how we may store, use and disclose information which you provide in relation to borrowers on whose behalf you make loan applications, please refer to section 3 above. You must provide a copy of this privacy policy to any potential borrowers whom you represent. You must ensure that they are made aware of the content of section 3 above and that they give their consent to their information being used in accordance with this privacy policy before you provide any information about the borrower to us.

5. Cookies

This website uses cookies to collect information about you. If you use this website, then you accept that we can use the cookies set out below.

5.1. What are cookies?

Cookies are small data files which are placed on your computer by this website and which collect certain personal information about you.

5.2. Why do we use cookies?

Cookies enable us to tailor our service offering (including the website) and to provide you with a better service.

5.3. What cookies do we use?

We use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website. They do not gather information about you that could be used for marketing purposes or remembering where you’ve been on the Internet.

Analytical/performance cookies. They allow us to collect information about how you use our website, such as, how you move around our website and if you experience any errors. These cookies do not collect any information that could identify you; all of the information collected is anonymous and is only used to help us improve the way our website works, understand what interests our users and measure how effective our advertising is.

Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences and improve your visit.

Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. They are linked to services provided by third parties, such as “Like” and “Share” buttons. The third party provides these services in return for recognising that you have visited our website.

Generally, cookies which are strictly necessary for the operation of the website will expire when you leave the website. Other cookies may be more permanent or not expire unless you actively delete them.

5.4. How to reject cookies?

If you want to reject any of the cookies that we use, then you will need to change your website browser settings.

6. Security

Whilst we take appropriate technical and organisational measures to safeguard the personal information that you provide to us, we accept no liability if communications are intercepted by third parties or incorrectly delivered or not delivered.

7. Your rights

7.1 You have the following rights:

(a) the right to ask us to provide you with copies of personal information that we hold about you at any time, subject to a fee specified by law (currently £10);

(b) the right to ask us to update and correct any out-of-date or incorrect personal information that we hold about you free of charge; and

(c) the right to opt out of any marketing communications that we (or any third party to whom we have disclosed your personal information with your consent) may send you.

7.2 If you wish to exercise any of the above rights, please contact us using the details specified above.

7.3 You can contact the credit reference agencies currently operating in the UK; the information they hold may not be the same, so it is worth contacting them all. They will charge you a small statutory fee.

(a) CallCredit, Consumer Services Team, PO Box 491, Leeds, LS3 1WZ or call 0870 0601414

(b) Equifax PLC, Credit File Advice Centre, PO Box 3001, Bradford, BD1 5US or call 0870 010 0583 or log on to www.myequifax.co.uk

(c) Experian, Consumer Help Service, PO Box 8000, Nottingham NG80 7WF or call 0844 4818000 or log on to www.experian.co.uk.

8. Third party sites

This website contains links to other websites operated by third parties. Please note that this privacy policy applies only to the personal information that we collect through this website and we cannot be responsible for personal information that third parties may collect, store and use through other websites. You should always read the privacy policy of each website you visit carefully.

The third party systems in the delivery of services via Ablrate, such as email delivery, customer service applications and general email systems that we currently use are:

(i) Google Apps (Privacy Policy)

(ii) Sendgrid (Privacy Policy)