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Privacy Policy

Welcome to MTL Financial Limited's (MTL) privacy policy

MTL respects your privacy and is committed to protecting your personal data. This privacy policy will tell you 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 policy is provided in a layered format so you can click through to the specific areas set out below. We have also provided a Glossary to explain the meaning of some of the terms used in this privacy policy.

  • (1) Important information and who we are
    • (a) Purpose of this privacy policy
      • (i) This privacy policy aims to give you information on how MTL 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 our marketing emails, submit an application for a product or services, or use this website.
      • (ii) This website is not intended for children and we do not knowingly collect data relating to children.
      • (iii) 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.
    • (b) Controller
      • (i) MTL Financial Limited is the controller and responsible for your personal data (collectively referred to as MTL, "we", "us" or "our" in this privacy policy).
      • (ii) We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
    • (c) Contact details
      • (i) If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:
        • (1) Full name of legal entity: MTL Financial Limited
        • (2) Email address: dpo@out.fund
        • (3) Postal address: 71-75 Shelton Street, Covent Garden, London, England, WC2H 9JQ
        • (4) Telephone number: 020 8089 5030
      • (ii) You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
    • (d) Changes to the privacy policy and your duty to inform us of changes
      • (i) We keep our privacy policy under regular review. This version was last updated on 20 January 2020.
      • (ii) 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.
    • (e) 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.
  • (2) The data we collect about you
    • (a) 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).
    • (b) We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
      • (i) Identity Data of individuals may include first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
      • (ii) Contact Data includes physical address, billing address, email address and telephone numbers.
      • (iii) Documentary evidence confirming identity and address, income and expenditure details, tax and accounting information, driving licence or utility bill.
      • (iv) Financial Data includes bank account and payment card details.
      • (v) 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.
      • (vi) Profile Data includes your username and password, applications made by you and products or services requested by or supplied to you, your interests, preferences and feedback responses.
      • (vii) Usage Data includes information about how you use our website, products and services.
      • (viii) Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
      • (ix) 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. 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.
      • (x) We may also collect certain Special Categories of Personal Data about you, this includes details about your criminal convictions and offences.
    • (c) If you fail to provide personal data
      • (i) Where we need to collect personal data by law, or in order to provide or procure the supply of the services to 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 a revenue share facility). In this case, we may have to cancel or cease to provide services to you but we will notify you if this is the case at the time.
  • (3) How is your personal data collected?
    • (a) We use different methods to collect data from and about you including through:
      • (i) Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by uploading this data to our website. This includes personal data you provide when you:
        • (1) apply for products or services via our website;
        • (2) create an account on our website;
        • (3) subscribe to our service or publications;
        • (4) request marketing to be sent to you; or
        • (5) give us feedback or contact us.
      • (ii) 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. Please see our cookie policy for further details.
      • (iii) Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
        • (1) Technical Data from the following parties:
          • (a) analytics providers such as Google UK Limited based outside the EU; and
          • (b) search information providers.
      • (iv) Contact, Financial and Transaction Data from providers of technical, payment and delivery services from any of the Credit Reference Agencies (CRA's) based inside the EU, specifically Transunion International UK Limited, further details found here and Experian Limited, further details found here.
      • (v) Identity and Contact Data from data brokers or aggregators such as Moody's Analytics UK Limited based inside the EU and from social media platforms such as LinkedIn based outside the EU.
      • vi) Identity and Contact Data from publicly available sources such as Companies House, the Electoral Register and CRA's based inside the EU.
    • (b) This information may have been collected directly from you through your online account or may have been submitted by someone else, such as another director of the company or a broker. We may also obtain information about you from credit reference and fraud prevention agencies, please see the section on data sharing below for more detail.
  • (4) How we use your personal data
    • (a) We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
      • (i) Where we provide you with a revenue share facility.
      • (ii) Where we need to provide services to you.
      • (iii) Where it is necessary for our legitimate interests (or those of a third party) e.g. to prevent fraud or to verify your identity and your interests and fundamental rights do not override those interests.
      • (iv) Where we need to comply with a legal obligation.
      • (v) The table below sets out the types of lawful basis that we will rely on to process your personal data.
      • (vi) Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
    • (b) Purposes for which we will use your personal data
      • (i) We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
      • (ii) The personal information we have collected from you will be shared with fraud prevention agencies that will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance, or employment. Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights, can be found by here. It is not compliant to replace the short notice with a link or reference to another document.
      • (iii) Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.