Privacy Policy

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Who we are:

We are AP Commercial Finance Limited (known as ‘Our Company’) and we can be contacted using the following

details:

Telephone Number: 01277 287 815

Address: Hill House, 24 High Street, Billericay, CM12 9BQ

Email address: info@ap-commerical-finance.com

Data Protection Officer/ contact: Mr Alex Phillips

ICO Registration Number: ZB877717

Our legal grounds for holding your data:

The UK’s data protection laws allow us to use your personal data provided we have a lawful basis to do so. This

includes sharing it in certain circumstances, as described below.

We consider we have the following reasons (legal bases) to use your personal data:

• Performance of contract with you: we need to use your personal data to be able to successfully legally

contract with you.

• Compliance with our legal obligations: we need to use your personal data so as to comply with certain

legislation such as financial crime legislation.

• Legitimate interests: these are our business and commercial reasons for using your data, which we have

balanced against your interests. We have certain legitimate interests in using your data which are not

outweighed by your interests, fundamental rights or freedoms. These legitimate interests are to help prevent

and detect financial crime, fraud and money laundering, to promote responsible lending and to assist our

compliance with the legal and regulatory requirements placed upon us.

• Your consent: You can withdraw this consent at any time, in which case we will cease to use it, unless we

have a right and a need to continue processing it for one of the other reasons set out above.

More information on how we use your personal data and for what purposes is set out below.

What data do we collect?

Data provided by you:

• Funder application details: for example but not limited to, your name, national insurance number, postal

address, your email address, telephone numbers, date of birth, bank account details, equipment requirement

details, home ownership details, reason for borrowing, your assets and liabilities, details of your proof of

identity documentation, proof of address documentation, evidence of additional equity available and evidence

of any other business interests

• When you talk to us: for example, on the phone, or in person including call recordings and voice messages.

We may monitor or record calls with you to check we have carried out your instructions, to resolve queries or

disputes, to improve the quality of our service or for regulatory or fraud prevention purposes

• In writing: for example, letters, emails, texts and other electronic communications

• Online: for example, when you use our website or mobile app

• In financial reviews, for renewals and in any surveys etc

Data we collect when you use our services?

• Transaction data: for example, what sort of products you are selecting, the length of term, the types of asset

you are looking at financing, business type and geographical location

• Payment data: for example, the amount, origin, frequency, history and method of your payments

• Usage and profile data: for example, the profile you create to use our website and mobile app and how you

use it. We gather this data from the devices you use, using cookies and other software

• Register online or other communication methods for our services.

• Voluntarily complete a customer survey or provide feedback on any of our message boards or via email.

• Use or view our website via your browser’s cookies.

Our Company may also receive your data indirectly from the following sources:

Data provided to and by third parties

• Data from persons that introduce you to us: for example, brokers, product suppliers, financial advisers,

agents, finance providers or other third parties

• Data from credit reference agencies, most likely to be either Experian, Creditsafe, Equifax or CallCredit

• Data from fraud prevention agencies

• Publicly available information: for example, from the land registry, companies house, the electoral register,

other information available online or in the media, including social media

• Data from your representatives where relevant: for example, your legal and financial advisers, such as

lawyers and accountants*

*We may also require a statement signed by an independent qualified accountant as to your financial worth which may

include information such as your gross and net worth, your assets and liabilities and information as to your available

collateral or security. You will be asked to consent to the provision of this information.

Special Category Data

In the course of your interactions with Our Company, you may share information that is classified as ‘Special Category

Data’. This could include data about:

• Race

• Ethnic origin

• Politics

• Religion

• Trade union membership

• Genetics

• Biometrics

• Health

• Sex life

• Sexual orientation

Where you do share information relating to any of these categories e.g., when you may share information about your

health or a characteristic of vulnerability, Our Company will always seek explicit consent from you to store and

process such information.

Why is personal data collected by us

Our Company collect personal data for a number of reasons

From time to time, we may contact you to ask for your consent to use your personal data for other purposes. Your

personal data may also be used for other purposes where required or permitted by law.

When we and fraud prevention agencies process your personal data, we do so on the basis that we have a legitimate

interest in preventing fraud and money laundering, and to verify identity, in order to protect our business and to comply

with laws that apply to us. Such processing is also a contractual requirement of the services or financing you have

requested. We, and fraud prevention agencies, may also enable law enforcement agencies to access and use your

personal data to detect, investigate and prevent crime. Fraud prevention agencies can hold your personal data fordifferent periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for

up to six years.

In order to process your application, we may supply your personal information to credit reference agencies (CRAs) in

which case they will give us information about you, such as about your financial history. We do this to assess your

creditworthiness and product suitability, check your identity, manage your account, trace and recover debts and

prevent criminal activity. When CRAs receive a search from us they may place a search footprint on your credit file

that may be seen by other lenders and used to assess applications for finance from you and members of your

household. The CRA may also share your personal information with other organisations. We may also continue to

exchange information about you with CRAs on an ongoing basis, including about your settled accounts and any debts

not fully repaid on time. CRAs will share your information with other organisations. Your data will also be linked to the

data of your spouse, any joint applicants or other financial associates. We can provide you with the identities of the

CRAs and the ways in which they use and share personal information upon your request.

From time to time, we may provide your information to our partners, third parties and customer service agencies for

research and analysis purposes so that we can monitor and improve the services (or as the case may be) we provide.

We may contact you by post, e-mail or telephone (or as required) to ask you for your feedback and comments on our

services (or as the case may be).

We may also contact you about our other goods or services that may be of interest to you.

How will we use your data?

Our Company collects your data so that we can:

• Process your application and manage your request.

• Email you with special offers on other products and services we think you might like.

• To monitor the performance of our products and services to ensure consumer outcomes are being achieved

Lawful Basis for Processing Data

transaction record)

Data Type Lawful Basis for Processing

Personal Identification Information (e.g.,

name, address, date of birth

Contractual Necessity, Legal Obligation, Consent

Contact Information (e.g. email address,

phone number)

Consent, Contractual Necessity, Legitimate

Interest

Financial Data (e.g., bank account details,

credit card numbers

Contractual Necessity, Legal Obligation

Employment Information (e.g., job title,

salary)

Contractual Necessity, Legal Obligation

Transactional Data (e.g., purchase history,

Contractual Necessity, Legitimate Interests

When Personal Data is shared

Your personal data may be used by our partners, lenders, brokers, agents, sub-contractors, lawyers and by any of our

or their subsidiary or associated companies before, during and after your agreement facilitated by us. We may also

use organisations to perform tasks on our behalf including information technology service providers, banks and

transportation companies who we will then be sharing your personal data with and who may also process and retain

your data both before, during and after your agreement facilitated by us. Any of these third parties may contact you by

post, e-mail or telephone (or as required).

We may also share your personal data with CRAs, fraud prevention agencies, law enforcement agencies, regulators

and other authorities, the UK Financial Services Compensation Scheme, any agent that you have given us authority to communicate with and persons you ask us to share your data with, companies that we introduce you to, market

researchers tracing and debt recovery agencies and customer service agencies for the purposes set out above. These

agencies and firms may also share your personal data with others.

Your personal data may also appear on the V5, service history, manufacturers record, insurance documentation or

within receipts in relation to the asset which may be shared by us with third parties who store, transport, advertise,

sell, express interest in purchasing, own or later hire the asset– NON-PROPERTY CLIENTS ONLY.

If, in the future, we sell, transfer or merge all or part of our business or assets, including the acquisition of other

businesses, we may share your data with other parties. We will only do this if they agree to keep it safe and private

and to only use it in the same ways as set out in this notice.

What are your data protection rights and choices?

Your personal data is protected by legal rights, which include:

• Right to be informed – Individuals have the right to be informed about the collection and use of their personal

data

• The right of access to your personal data – Individuals have the right to access and receive a copy of their

personal data and other supplementary information.

• The right to rectification- Individuals have the right to have inaccurate personal data rectified or completed if

incomplete.

• The right to erasure – Individuals have the right to have their personal data erased.

• The right to restrict processing – Individuals have the right to request the restriction or suppression of their

personal data.

• The right to portability – This allows individuals to obtain and reuse their personal data for their own purposes

across different services.

• The right to object – this gives individuals the right to object to the processing of their personal data in certain

circumstances, it also gives individuals the absolute right to stop their data being used for direct marketing

• The right in relation to automated decision making and profiling – this allows individuals to object to their data

being used in an automated individual decision-making process (making a decision solely by automated

means without any human involvement) and profiling (automated processing of personal data to evaluate

certain things about an individual). Profiling can be part of an automated decision-making process.

There may be reasons why we need to keep or use your data, but please tell us if you think we should not be

processing your data.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please

contact us at our email info@ap-commercial-finance.com

For further information on how your information is used, how we maintain the security of your information and your

rights in relation to it, please contact us via email infor@ap-commercial-fianance.com or call us on 01277 287 815.

How long is your data kept

We will retain your personal data as long as you are a customer with us. We may retain your personal data beyond

this date for the purposes mentioned above and will in any case at all times retain your personal data for the minimum

period required by law. We may also retain your data to deal with any disputes, to maintain records and to show we

have dealt with you fairly.

We may also retain your data for research and statistical purposes in which case we will ensure it is kept private and

used only for these purposes.

Data about live and settled accounts is kept on credit files for six years from the date they’re settled or closed. If the

account is recorded as defaulted, the data is kept for six years from the date of the default.

Changes to our privacy policy

Our Company keeps its privacy policy under regular review and places any updates on this web page. This privacy

policy was last updated on 20/03/25.

How to contact us

If you have any questions about Our Company’s Privacy Policy, the data we hold on you, or you would like to exercise

one of your data protections rights, please do not hesitate to contact us.

Email us at:

Call us: 01277287815

Or write to us at: Hill House, 24 High Street, Billericay, CM12 9BQ

How to make a complaint and contact the appropriate authority

If you are unhappy about how your personal data has been used by us, please contact us and we will be happy to

register a complaint.

You also have a right to complain to the Information Commissioner’s Office which regulates the processing of

personal data. You can contact them at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow,

Cheshire, SK9 5AF, on 0303 123 1113 or by email to casework@ico.org.uk. See also https://ico.org.uk/global/contact-

us/.

Marketing

Our Company understands that with the introduction of the Consumer Duty, it is likely the level of communications

issued by our business will increase. This will be necessary to support customers to understand the products and

services offered and to provide support to customer throughout the lifecycle of the relationship.

Our Company would like to send you information about products and services of ours that we think you might like, as

well as those of our partner companies.

If you have agreed to receive marketing, you may always opt out at a later date.

You have the right at any time to stop Our Company from contacting you for marketing purposes or giving your data

Our Company group.