Fintern Holdings LTD Privacy Notice

31/08/2022

Fintern Holdings LTD respects your privacy and is committed to protecting your personal data. This privacy policy will inform you on how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy notice relates to investors, clients and other individuals in their relations with Fintern Holdings Ltd.

Individuals who have applied for, or taken out, a loan or other product provided by Fintern Ltd should read the Privacy Notice provided at https://www.getabound.com/privacy.  Fintern Ltd operates under the brand names “Abound” and “Fintern”.

Individuals who have provided personal information to Fintern Technologies Ltd should read the Privacy Notice provided at Privacy policy (render.credit).  Fintern Technologies Ltd operates under the brand name “Render”.

General
This Privacy Policy aims to give you information on how Fintern Holdings LTD collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to receive newsletters, book a demo or contact us.

This website is not intended for children and we do not knowingly collect data relating to children.

Additional information regarding the privacy of personal data‚ and the use of cookies is available in our Privacy Policy. You acknowledge and agree to be bound by the terms of our Privacy Policy.

If you have any questions or comments about this Privacy Policy, please contact our Chief Compliance Officer Alan Cathcart:

Fintern
3rd Floor,
86-90 Paul Street,
London, EC2A 4NE

Privacy Policy

Purpose of this Privacy Policy

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Changes to the Privacy Policy and your duty to inform us for changes

We may change this policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection. Any changes will be made available through our website and will be deemed to be accepted by you upon your first visit following the publication of any update. You are reminded to check the relevant page of our website for updates. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third Party Links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows (this may vary according to your relationship with us):

Identity Data includes first name, maiden name, last name, username or similar identifier, NI number, employment information, date of birth.

Contact Data includes postal address, email address and telephone numbers.

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

Profile Data includes your username and password, purchases or orders made by you.

Usage Data includes information about how you use our website, products and services.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. Please note that you will always have the opportunity to opt-out.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature or page. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy. We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How is Your Personal Data Collected?

We use different methods to collect data from and about you including through: direct interactions.
You may give us your Identity and Contact by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
Apply for our products or services
Subscribe to our service or publications
Request marketing to be sent to you
Give us feedback or contact us.

Automated technologies or interactions

As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see below for further details.

Third parties or publicly available sources

We may also receive and/or collect personal information about you from various third parties and public sources such as business directories, public registers and other commercially or publicly available sources.

Technical data

We use different methods to collect data from and about you including through: direct interactions.
You may give us your Identity and Contact by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
Apply for our products or services
Subscribe to our service or publications
Request marketing to be sent to you
Give us feedback or contact us.

How is Your Personal Data Collected?

Technical data may be collected by analytics providers (such as Google, based outside the UK)

How we use your personal data

We will use your personal data to provide you with our services and information, for administration and customer services, for marketing, research, and advertising and to improve the design and layout of our website. We may keep your information for a reasonable period for these purposes. We may need to share your information with our service providers and agents for these purposes. We may disclose personal data to comply with a legal or regulatory obligation. By providing us with your personal data you consent to our processing your data, including sensitive personal data, for the above purposes.  If you provide us with information about someone else you confirm that they have appointed you to act for them to consent to the processing of their personal data, including sensitive personal data, and that you have informed them of our identity and the purposes (as set out above) for which their personal data will be processed.

Where we process your personal information, we will ensure that we have a lawful basis to do so. The lawful basis depends on the type of processing.  The lawful bases which we may apply to include: to ensure performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract; where the processing is necessary in order to comply with a legal obligation; where the processing is necessary for our legitimate interests or those of a third party; or where you have given clear consent to process your data for a specific purpose

Your rights in relation to personal data which we process relating to you

You have the following rights over the way we process personal data relating to you. We aim to comply without undue delay, and within one month at the latest.

Marketing opt-out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see below.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the lawful basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

International transfers

We do not transfer your personal data outside of the EEA.

Data retention

When it is no longer necessary to retain your personal information, we will delete or anonymise it.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. In summary, these rights include:

Be Informed: right to be informed over how we use your use personal information.

Access: right to access to your personal information and to certain other supplementary information. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it (commonly known as a "data subject access     request"). A Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us     everything we need to know to respond to your request as quickly as possible.

Rectification: right to request the correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Erasure: right to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Restrict processing: right to request restriction or suppression of processing your personal data in the following scenarios:
If you want us to establish the data's accuracy.  
Where our use of the data is unlawful but you do not want us to erase it.  
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.  
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.  

Data Portability: the right to move, copy or transfer your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Object: right to object to the processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms and an absolute right to stop your data being used for direct marketing. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Automated decision making (including profiling): right to object to decisions being taken by automated means including profiling which produce legal effects concerning you or similarly significantly affect you or to our continued processing of your personal information.

Withdraw consent: right to withdraw your consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

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

Cookies

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or device. It gets stored, if you agree to our Privacy and Cookies Policy, when first visiting our website. Cookies contain information that is transferred to and from your computer's hard drive. You can use your browser’s clear history” tool to remove cookies before their expiration date. Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. Our cookies are carefully selected to ensure that your privacy is protected and respected at all times. We have set out below, in a table format, a description of the cookies we may use:

Type of cookie

Purpose

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 or make use of e-billing services.
Analyticalor performance cookies
These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily
Functionality cookies
These are used to recognise you when you return to our website.
Targeting cookies
These record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or block all cookies (including essential cookies),some parts of this website may become inaccessible or not function properly. You can choose to delete cookies at any time; however you may lose any information that enables you to access the website more quickly and efficiently including, but not limited to, personalisation settings. It is recommended that you ensure that your Internet browser is up to date and that you consult the help and guidance provided by the developer of your Internet browser if you are unsure about adjusting your privacy settings.

Governing Law and Jurisdiction

These terms and any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with it or its subject matter or formation shall be governing by and construed in accordance with the laws of England and Wales. Each party irrevocable agrees that the courts of England and Wales shall have non-exclusive jurisdiction to settle any dispute or claim (including non-contractual disputes or claims)arising out of or in connection with these terms or its subject matter or formation.

Other information

You should note that if our business (or any part of it) is sold or transferred at any time, the information we hold may form part of the assets transferred although will still only be used in accordance with this policy unless and until you are notified otherwise.

Disclaimer

Although Fintern has attempted to provide accurate information on this Website, information on this Website may contain technical inaccuracies or typographical errors. The contents of any documents on this Website are believed to be current and accurate as of their publication dates. Fintern assumes no responsibility for the accuracy of the information. Fintern may change the programs or products mentioned at any time without notice. For the most current and complete documents, please contact Fintern directly.

Changes to this privacy notice

We can update this Privacy Notice at any time and keep it under regular review.  This privacy notice was updated on 12 March 2024.