Our ICO registration number is [ZA412677].
What information do we collect from you?
Information you give to us
We may collect and process the following personal information about you:
- General personal details, which may include:
- Your name
- Your residential address
- Your contact details (email address and/or your telephone number)
- Your date of birth
- Your email address
- Your phone number
- Know Your Customer (KYC) information, which may include:
- Information used to verify your identity, such as copies of passports or other identity documentation
- Information used to verify your address, such as utility bills or bank statements
- Your contact details (email address and/or your telephone number)
- Information used to verify corporate status, company directors, persons of significant control and Ultimate Beneficial Owners (UBOs)
- Other information we may request from you in order to fulfil our obligations under Anti-Money Laundering legislation
- Invoice information, which may include:
- The invoice payer’s name
- Invoice date and reference
- Other details relating to the relationship between supplier and buyer, which may include details of the goods and services provided to buyers and the length of commercial relationships
- Information collected through API links to your accounting or ERP software, which may include:
- Any information we need in order to confirm the invoice and list it for sale on our platform, which may include invoice date, purchase order, proof of pricing,acceptance of underlying goods/ services and confirmation of Payer obligation to pay at maturity
- Information used to assess creditworthiness, which may include:
- Details on your financial and credit history
- Details of your company and trading history
- Lists of suppliers and company partners
- Information about you and your company from public sources, including Companies House, government registries, media and social media sources, and internet search.
- Other information as requested by us from time to time
- Account registration information, which may include the following as submitted by you:
- Profile picture
- Company details
- Position held at your company
- Company documentation, which may include incorporation documentation, annual accounts, and details of the company’s beneficial owners and directors
- Information you provide when participating in website discussion boards or social media functions this may include personal data depending on the content of the information you provide
- Other communications you send to us (by telephone, email or otherwise), for example, to report a problem or to submit queries, concerns or comments regarding the website, our service, or general comments
Information we collect about you
With regard to each of your visits to the website we may automatically collect the following information:
- Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system;
- Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from the website (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
This data is necessary for us to keep a record of website activity and statistics, to improve our products and services, and to use analytics to grow our business.
The information detailed above will not be linked to any personal details we hold and will therefore not constitute personal data.
Cookies can be used to recognise you when you visit a Website or use Finverity Service, remember your preferences and give you a personalised experience that is consistent with your settings. Cookies also make your interactions faster and more secure.
We use the following categories of cookies and similar technologies on this website:
- Strictly necessary cookies: These cookies are essential to enable you to move around the website and use its features. Without these cookies, services you have asked for (such as remembering your login details or the items you placed in your basket) cannot be provided.
- Analytics cookies: These cookies collect information about how you use the website, for instance, which pages you go to most often, what searches you perform and if you get error messages from web pages. The information these cookies collect can be used to improve how the website works.
- Customization cookies: These cookies allow the website to remember choices you make (such as your user name) and provide enhanced, more personal features. These cookies cannot track your browsing activity on other websites.
- Social media cookies: These cookies allow you to share your activity on the website on social media such as Facebook and Twitter. These cookies are not within our control. Please refer to the privacy policies of social networks in question for information regarding how their cookies work.
- Targeting or advertising cookies: These cookies record your visit to the website, the pages you have viwebsited and the links you have followed. We use this information to make Website and the advertising displayed on it more relevant to your interests.
When you visit the website for the first time (and periodically after that), we will request your consent to the setting of all cookies other than strictly necessary cookies.
You can delete existing cookies and disable some or all types of cookies in the future if you wish. To disable some or all types of cookies, you will have to change the settings on your browser. If you change your mind, you can enable cookies again at any time.
Disabling cookies on your browser may stop the website from working properly and can interfere with the availability of Finverity Service.
To find out more about cookies please visit www.allaboutcookies.org.
What we do with your data
We use your personal data for the following purposes
Providing Finverity Service to you
We need to process certain personal information in order to provide Finverity Service to you, which includes our core business of connecting invoice sellers, investors and invoice payers as well as related administration activity.
In order to deliver Finverity Service, your personal data may also be transferred to the following third parties:
- Third-party credit reference agencies, in circumstances where we need to assess your creditworthiness.
- Fraud prevention and law enforcement agencies, in circumstances where we suspect fraud or financial crime has occurred or when we need to verify the authenticity of documents you have submitted to us.
- Payment service providers, to facilitate payments on our platform and for payment of our own fees.
- Our technology partners, including our cloud hosting provider, to store your personal data securely and administer your account.
Contacting you about our services
If you have given us your contact information, we may use these details to get in touch with you about the services we offer such as by following up on an incomplete registration process or to email you details of invoice offers or related Finverity services you may be interested in.
You may opt out of this at any time by telling us, or if we have contacted you via email, you will be given an option to opt out by clicking the “unsubscribe” email link.
Improving our services
We may use your personal data to analyse how you are using the Finverity service and to gain insights into how we can improve our products and services.
Customer Support and account administration
We may use your personal data to provide you with customer support or to investigate complaints or concerns about your account.
Related products and services
We may use your personal data to provide you with information on additional opportunities on the Finverity platform. This information will be provided electronically, either via Website, app, or email.
We will not transfer any of your personal data to third parties for this purpose unless you give us your explicit consent.
Recommending you as a partner to other users of the Finverity platform
We may use your personal information and statistics we derive from your use of Finverity Service to recommend you as a partner to other companies on our platform where we believe you would benefit from this.
Providing information to third parties for marketing purposes and for related products and services
In certain circumstances we may ask for your consent to share your personal data with explicitly identified third parties so that they can contact you for marketing purposes or provide you with their own products or services. We will only do so if you have given us your explicit consent to share your personal information in this way, which can be given via a pop-up screen on Website. You can withdraw your consent at any time by contacting us at email@example.com
Our lawful basis for processing your personal data
Under Article 6 of the EU General Data Protection Regulation (GDPR), we are required to tell you about the legal basis under which we collect and process your data.
We will only collect and process your personal data in accordance with one of the below lawful bases:
- Performance of a contract: This is where the processing is necessary for a contract we have with you, or you have asked us to take specific steps before entering into a contract, such as providing you with a quote. This lawful basis covers the following purposes:
- Providing Finverity Service to you
- Our legitimate interests: This is where we collect and process data in accordance with our “legitimate interests”. Our legitimate interests include:
- Improving our service
- Providing you with marketing information about Finverity Service
- Providing you with customer support and administering your account
- Recommending you as a partner to other users of the Finverity platform
- Providing you with information about related products and services offered by Finverity
- Consent: You may be given the option to explicitly consent to share your data with selected third parties for marketing purposes or to receive information about related products and services. This will be via a separate notice on Website. We will never assume that we have your consent unless you have explicitly opted in, and you can withdraw your consent at any time by contacting us.
- Compliance with our legal obligations: We may be required to process or share your personal data in compliance with a legal obligation, such as in response to a request by law enforcement or when investigating a civil claim. We also need to process your data and share it with carefully selected KYC verification agencies in order to comply with our obligations under Anti-Money Laundering (AML) legislation.
Data storage and international transfers
We take the security of your data very seriously, and all of your personal data will be kept according to strict safeguards and in compliance with the GDPR. Your data will be stored on cloud servers within the EEA and we will only store your data outside the EEA in the event that the jurisdiction in question has been assessed as compliant with the GDPR.
Automated decision making
When you enter in your personal details to obtain an initial quote using Finverity Service, we may use this data to process commercial, financial and legal risks relating to onboarding of our customers. This does not affect your legal rights.
You have the right to be informed over what personal data we hold and how we are using it. This information is contained within this privacy notice.
If you have consented to particular uses of your personal data, you have the right to withdraw this consent at any time.
You have the right to “portability” of your personal data that we have collected with your consent or in performance of a contract that is used in automated decision-making. This means that you can request copies of all the personal data we hold for this purpose in a structured, commonly used, and machine readable form, and we will supply this to you free of charge on request. We will respond to these requests within one month, unless the request is particularly complex, in which case we will inform you of how long it will take as soon as possible.
You have the right to request a copy of the personal data we hold under the GDPR by making a “subject access request” to us in writing. We will comply with all valid subject access requests within 30 days unless the request is particularly complex; in this case, we will contact you within 30 days with further information. You will not be charged for making a subject access request unless we reasonably deem this to be manifestly unfounded or excessive request, in which instance you will be charged a reasonable fee based on the administrative costs of providing the information.
If some of the personal data we hold is inaccurate or incomplete, you can request that we rectify our records by writing to us. We will comply with all requests within 30 days unless the request is particularly complex; in this case, we will contact you within 30 days with further information.
Where we are using your personal data in accordance with our legitimate interests, you can object to further use of your data. This objection should be based on grounds relating to your particular situation. If you object, we will stop using your personal data in this way immediately, unless there are compelling legitimate grounds for processing your personal data which override your interests, rights and freedoms (such as requests by law enforcement) or we need to process your data for the establishment, exercise or defence of legal claims. You may always object to further use of your data for direct marketing purposes by clicking the “unsubscribe” button within marketing emails or by contacting us by writing to us at firstname.lastname@example.org
You have the right to request the erasure of the personal data we hold by contacting us. Please note that it is not always possible for us to comply with a request for erasure; for example, if we have collected data from you in performance of a contract, we cannot normally comply with a request for erasure unless we no longer have an active contract with you and the data is more than six years old.
You have the right to restrict the processing of your personal data in certain circumstances, such as when you object to us using your data in accordance with our legitimate interests or when you contest the accuracy of the data we hold on you.
You can exercise any of your rights by contacting us via the details at the bottom of this page. Please note that we may need to verify your identity before complying with any of the above requests.
How long we will keep your data for
We will only keep your personal data for as long as is necessary. This means that we will retain your personal data for as long as we have an active contract or business relationship with you, and after this, we will only keep your data for as long as is necessary for the purposes which it is stored.
For example, we will need to retain most contractual information for a period of six years following the end of our business relationship with you in order to establish, exercise or defend our legal rights in relation to the contract.
What happens if you don’t provide us with the information we need
As outlined above, some of the personal data you provide to us will be used in order to enter into a contract with you and to comply with our legal obligations.
Should you not provide us with the data we require to offer our service or request that we erase the personal data we hold, it is likely that we will not be able to continue to deliver Finverity Service to you.
If you feel that we have not been complying with our obligations on data protection law, you wish to assert one of your rights, or you need further information about how we process your data please contact us without delay by emailing email@example.com or writing to us at Finverity Ltd, 1 Fore Street Avenue, Office 3014 Wework, London, England, EC2Y 9DT.
Should you be dissatisfied with our response or wish to complain to the relevant supervisory authority, you can do so by contacting the Information Commissioner’s Office (ICO). Contact details for the ICO can be found on this webpage.