Privacy

Introduction

At Linked Finance, we take the security and integrity of your personal data very seriously. We understand that, by using our website and services, you are placing your trust in us and we value that. We know that this is your data and we will always do our very best to keep it secure, up-to-date and accessible to you. We will process your data fairly and transparently, taking every reasonable step we can to ensure that your privacy is protected.

Definitions

In this Privacy Policy, certain terms are used frequently and should be understood as follows:
  • “Linked Finance”, “we”, “us” or “our” means Linked P2P Limited, Linked Recoveries Limited and its employees in the Republic of Ireland.
  • “Processors”, “third-party services” or “providers” means certain outside agencies and service providers that Linked Finance uses in order to provide services to you. This includes, but is not limited to, cloud-based software providers, credit rating agencies, email services and web hosting services.
  • “Users”, “you” and “your” means:
    • Borrowers - Businesses or other commercial entities who have raised funding with Linked Finance and any relevant persons connected with such businesses, including employees, directors, partners, shareholders and beneficial owners.
    • Applicants - Businesses or other commercial entities who have applied for funding with Linked Finance and any relevant persons connected with such businesses, including employees, directors, partners, shareholders and beneficial owners.
    • Prospective Borrowers - Businesses or other commercial entities who may have an interest in raising funding with Linked Finance and any relevant persons connected with such businesses, including employees, directors, partners, shareholders and beneficial owners.
    • Lenders - individuals, businesses or other entities who have registered to lend with Linked Finance.
    • Visitors - individuals, businesses or other entities who visit LinkedFinance.com or other web properties controlled by Linked Finance.
    • Partners - individuals, businesses or other entities who work with Linked Finance and provide us with personal data relating to natural subjects in order for us to provide our services

Scope

Linked Finance operates a P2P lending platform that facilitates business loans. In order to successfully operate our platform, we are required to collect and process data including personal data belonging to our users. The aim of this privacy policy is to provide our users with a clear understanding of how, why and when we will process personal data and to outline our users’ rights in relation to this personal data.

Acceptance

By accessing and using our website, platform and services, you confirm that you have had proper opportunity to read this Privacy Policy, that you understand it and that you agree to be bound by its terms. If you do not, you must immediately stop using our website and platform, and any services provided by us.

What data we collect

The data we collect varies upon the nature of your relationship with Linked Finance but all forms of data collected by Linked Finance can be categorised as follows:
  • Identity Data including name, date of birth and personal contact details such as title.
  • Document Data for identity verification purposes including scanned copies of photo identification or utility bills.
  • Contact Data including addresses, telephone numbers, and personal email addresses.
  • Company Data including business name, address, job titles, and other company contact or categorisation data
  • Financial Data including bank account details, your debit or credit card information, your credit rating information (which we acquire from credit reference agencies) and other banking information.
  • Platform Data about your activity on the site including records of all access, lending, borrowing, payments, deposits and withdrawals.
  • Security Data used to secure your access to the site including securely-stored passwords, security questions and answers, failed log-in attempts and other information required in order to regulate access and safeguard your account.
  • Contract Data used to administer loan agreements between lenders and borrowers on the platform including details of parties to the contract and details of any guarantor.
  • Profile Data including information display names, comments and other publicly visible information you provide in relation to your use of the platform.
  • Marketing and Communications Data including your preferences in receiving marketing from us and your communication preferences.
  • Technical Data including IP addresses, cookies and other technical information relating to your use of our site.

When and how we collect your data

If you engage with us in any way, we may collect the following information about you through the methods of contact you choose to use at the point of engagement:
  • information you provide through our website and through our application and verification processes;
  • information you provide through communications with us, whether in writing (including by letter or email) or on the telephone (including by way of recorded calls);
  • information we obtain through your engagement with us on social media, including on blogs, forums and through Facebook and Twitter; and
  • information provided on your behalf by your representatives or agents who engage with us on your behalf in the ways described above.

For applicants, borrowers and prospective borrowers, we may obtain information from outside sources to help us carry out our business functions. This information, which often contains personal data, includes:
  • information and reports from credit reference agencies, fraud prevention agencies, insolvency practitioners, debt advisers and tracing agents;
  • commercial databases and marketing databases; and
  • public records and other publicly available information sources.

If you wish to register on the platform, for lending or borrowing, you may need to provide us with the following information, which we may also collect from third parties:
  • your personal details (including name, date of birth, current and previous postal addresses);
  • your contact information (including phone, e-mail and social media details);
  • (for borrowers, those representing borrowers and relevant institutional lenders) your business name and contact information;financial information (including bank or building society account details and details of debit cards used to make transfers on Linked Finance);
  • information you provide in our registration or application processes (including, if you are a borrower, Agent or relevant investor, certain personal data, identity verification, contact details and financial information about directors, partners, members, shareholders, beneficial owners and guarantors);
  • information you provide in your dealings with us and through your interaction with the platform;
  • if you are a borrower or a director, partner, member, shareholder, beneficial owner or guarantor of a borrower:
    • information about your business or company, such as previous credit applications and the conduct of your accounts, and similar personal credit information;
    • credit reference checks
    • fraud prevention information;
    • passwords and security question answers.

In addition to the personal and financial information you submit or we collect as described above, we may also collect information about your computer (including, where available, your IP address, operating system and browser type), your interaction with the platform and our website, and email performance data.

We may use this information for several reasons, including for marketing, for platform administration and for service improvement. Our Cookies Policy describes these processes in more detail.

We may also collect and retain:
  • copies of our correspondence with you as well as other data we collect relating to your activities on the platform and your arrangements with Linked Finance;
  • details about visitors to our website for the purposes of aggregating statistics or reporting purposes and to calculate referral fees; and
  • comments made on blogs and discussion forums in connection with the platform.

We may, particularly in relation to borrowers, lenders or guarantors, be given sensitive personal data (such as medical information or criminal records). Where relevant, we will hold and process this data to allow us to make decisions about you and your accounts with us or with which you are connected. This may involve us sharing your sensitive personal data with your Agents. We will process sensitive personal data only in accordance with the requirements of applicable privacy law.

If you provide information about other people (for example, if you represent a borrower and you provide information about directors, partners, members, shareholders or beneficial owners other than yourself) then you confirm:
  • you have provided a copy of this Privacy Policy to those persons and you have ensured that they are aware of and understand the contents of this Privacy Policy; and
  • by providing information about other people, that you have all relevant permissions and authority (i) to make all those disclosures, (ii) to act on their behalf and (iii) in relation to partners, members, shareholders or beneficial owners of borrowers, to allow us to make credit checks at credit reference agencies in respect of those persons.

Using your information

We collect, store and use your personal data:
  • to inform you of platform developments and activity and of changes to our products and services;
  • to develop and improve our services, products and business, including analysing and improving our credit risk models and our customer service offering;
  • to transfer money;
  • to carry out mandatory or other regulatory checks;
  • to comply with our legal and regulatory obligations;
  • to carry out statistical analysis and market research and testing;
  • to contact you (including by SMS and e-mail) with products and services which Linked Finance think may interest
  • you (at all times taking into consideration your rights at law including your right to opt-out from receiving marketing from us);
  • to open accounts with us and to manage and maintain those accounts;
  • to verify your identity and the other information you have provided to us, including your bank
  • account information and (if relevant) the identity of your business associates;
  • to update the records we hold about you from time to time;
  • to provide and administer the platform and our related services; and
  • for the prevention and detection of fraud or other illegal or criminal activity.
  • if you are a borrower (or a director, partner, member, shareholder, beneficial owner or guarantor of a borrower):
    • to ascertain your borrowing needs;
    • to assess your creditworthiness and to make credit-related decisions; and
    • if you miss any repayment of your loan, to trace your whereabouts and recover debts or enforce a loan contract and to verify any payment plan you have proposed or income and expenditure form you have submitted;

Disclosing your information

We may disclose your personal data to other registered members of our platform, including:
  • to operate the platform and seek to match lenders and borrowers;
  • in the loan contract and personal guarantee, when lenders and borrowers are matched;
  • to provide transactional and performance information;
  • to provide updates (including if and when there are late repayments or if and when a risk-banding has been
  • downgraded); and
  • if required to enforce (or make preparations to enforce) any loan contract.

If you, as a registered member of our platform, receive information about another registered member, then you must only use that information to communicate with Linked Finance about your loan contract with that member. You acknowledge that Linked Finance is not responsible for misuse of transactional or other information by Linked Finance members but you must inform Linked Finance promptly if you are the victim of any misuse of that information.

We may disclose your personal data to:
  • to companies in our group and our affiliates;
  • to our suppliers, sub-contractors and third party data processors (including card payment and direct debit payment processors, marketing and data analytics service providers, collection agents, tracing agents, insolvency practitioners, professional advisers and persons who provide us with the following services from time to time: identification and fraud check; marketing; technology; platform support; and back-up and business continuity);
  • with any third party you have asked us to share your personal data with, including social media sites if you have asked us to connect with your social media account;
  • to credit reference and fraud prevention agencies;
  • if we are unable to provide you with credit and if you consent, to third parties who may be in a position to arrange credit for you;
  • to a third party if it acquires all or part of our business or assets in connection with the acquisition, or to a successor in interest in the unlikely event of our insolvency, winding up or liquidation;
  • If we are required to do so by applicable law and regulation, governmental, tax or regulatory body or law enforcement agency;
  • if you are represented by an Agent, to your Agent; and
  • to any other person with your prior consent to do so.

Third parties who process your personal data on our behalf are only permitted to process your personal data in accordance with our instructions and we will take steps to ensure that the transfer and any on-going processing by those third parties is carried out securely and in accordance with applicable privacy laws.

Save as expressly provided above, or otherwise without your consent, Linked Finance will not share your personal data with any third party.

Overseas Transfers

We use various cloud-based software products and online tools to conduct our business. We will endeavour to ensure that all such services provide standards of privacy and data protection concurrent with our own.

As part of our use of these services, your data may be transferred to other countries, including those outside the European Economic Area, either for storage purposes or if we engage suppliers, sub-contractors or third party data processors who are based or have operations overseas. We will always take steps to ensure that your information is protected and that those transfers comply with applicable privacy laws.

Credit Reference Agencies

From time to time we may undertake credit reference checks against borrowers (and against directors, partners, members, shareholders and beneficial owners of borrowers and lenders), guarantors and agents:
  • as part of the application process;
  • for general credit management and know-your-customer (KYC) checks during the term of a loan; and
  • if there are late repayments or default.

For How Long Will We Use Your Information

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Platform Data) for six years after they cease being customers for tax purposes. In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. 

We will retain and securely destroy your personal information in accordance with applicable laws and regulations.

Your Rights

Under certain circumstances, by law you have the right to:
  • Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact us in writing (see contact details below).

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Withdrawal of Consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our us in writing (see contact details below). Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Security and other Third Parties

Linked Finance takes appropriate technical and organisational measures to safeguard the personal data that you provide to us, but we accept no liability if communications are intercepted by third parties or incorrectly delivered or not delivered.

If we transfer your information to third parties, we will take steps to ensure that the transfer and any on-going processing by those third parties is carried out securely and in accordance with applicable privacy laws.

The website and platform contain links to other websites operated by third parties. This Privacy Policy applies only to the personal data that Linked Finance collects and we are not responsible for personal data that third parties may collect, store and use through other websites.

You also have a responsibility to ensure that your information is kept secure. If you are a member of our platform, you must:
  • keep your login details secret;
  • log out of your account when not using it;
  • maintain good internet security (for example, be careful when using public WiFi or shared access internet connections); and
  • tell us immediately if you think your account has been compromised.

Amendments

This policy may be amended from time to time in order to comply with relevant laws and regulations or to meet our changing business needs. You are advised to review this page regularly to ensure you have the latest information in relation to how we process your data. By continuing to use our website, platform or services you agree to be bound by all such updates and amendments.

Contact Us

You can contact us at help@linkedfinance.com or by calling us on +353 (0)1 906 0300. Alternatively you can write to us at 43-45 Middle Abbey Street, Dublin 1, D01 X8R2 during regular business hours.

About Linked Finance

Linked Finance is a trading name of Linked P2P Limited. Registered with the Companies Registration Office in Ireland. Company number 491763. Linked Finance is also a trading name of Linked Finance P2P Limited. Registered with Companies House in the UK. Company number 09654940. In the UK, Linked Finance P2P Limited is authorised and regulated by the Financial Conduct Authority under firm registration number 714019. Linked Finance is not covered by the Deposit Guarantee Scheme or the Investor Compensation Scheme in Ireland or the Financial Services Compensation Scheme in the UK.