Glenhawk takes your privacy very seriously and we ask that you read this Privacy Notice carefully as it contains important information on who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights. This Privacy Notice applies to personal information that we collect through our website at glenhawk.com and its subdomains (“Website”) and when we provide services to you (collectively “Services“).
If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this Privacy Notice.
What does Glenhawk do?
Glenhawk is a leading non-bank lender providing bridging finance, headquartered in the UK.
For more information about Glenhawk, please see the “About Us” section of our Website at glenhawk.com/about-us.
What personal information does Glenhawk collect and why?
The personal information that we may collect about you broadly falls into the following categories:
Information that you provide voluntarily
Certain parts of our Website may ask you to provide personal information voluntarily: for example, when you submit enquiries to us we will collect your name and contact details or your marketing preferences. We may also collect personal information if you contact us via social media including your social media handle.
As part of an application for Services, we may also collect your job title, address history, and demographic information such as postcode, preferences and interests.
The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.
Information that we collect automatically
When you visit our Website, we may collect certain information automatically from your device. In some countries, including countries in the UK, this information may be considered personal information under applicable data protection laws.
Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Website, including the pages accessed and links clicked.
Collecting this information enables us to better understand the visitors who come to our Website, where they come from, and what content on our Website is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Website to our visitors.
Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading “Cookies and similar tracking technology” below.
Information that we obtain from third party sources
From time to time, we may receive personal information about you from third party sources as part of the Services, but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us. This includes:
- loan and financial intermediaries who you have agreed will provide us with information to assist with your loan application;
- credit search agencies to determine your suitability for the loan; and
- your employer to determine your suitability for the loan.
How does Glenhawk use your personal information?
We use and process the personal information we collect receive (alone or in combination) for the purposes identified below:
- fulfil our contractual obligations;
- provide the Services;
- carry out due diligence to determine your suitability for any loans you are applying for;
- communicating with you about the Services and responding to any requests for information from you;
- internal record keeping;
- improve our products and services;
- send you promotional emails about new products, special offers or other information which we think you may find interesting where you have provided us with consent to do so;
- contact you for market research purposes where you have provided us with consent to do so;
- ensuring the security of the Website and Services;
- for internal business purposes; and
- compliance with our legal obligations.
Who does Glenhawk share my personal information with?
We may disclose your personal information to the following categories of recipients:
- to our group companies – as listed here: Glenhawk Group Limited (Co Reg: 11481088), Glenhawk Financial Services Limited (Co Reg: 10962610), GFS Invest Limited (Co Reg: 11389824), GFS 1 Ltd (Co Reg: 11387725), GFS 3 Ltd (Co Reg: 12266361), and Glenhawk Property Finance Ltd (Co Reg: 11539817). The Registered Office for all these entities is 2nd Floor, Mutual House, 70 Conduit Street, London, England, W1S 2GF. Glenhawk Property Finance Ltd is authorised and regulated by the Financial Conduct Authority (firm reference number 826671);
- to third party services providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Website), or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information. We will also share information with:
- legal advisers
- credit search companies
- RICS property valuers
- our lenders, our investors and funders
- external finance agents for the purposes of fulfilling our obligations to you and determining your suitably for the loan you have applied for
- fraud prevention agencies and any other authorised bodies including for the purposes of investigating any actual or suspected criminal activity or other regulatory or legal matters, etc.
- Your advisers (such as accountants, lawyers and other professional advisers) who you have authorised to represent you, or any other person you have told us is authorised to give instructions, administer your account, on your behalf (such as under a power of attorney)
- Other financial institutions who you ask us to deal with
- Our third party service providers and partners operate in the Credit Reference, Anti-Fraud and Money Laundering, Legal, Valuation and Legal services sectors;
- to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
- to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice;
- to any other person with your consent to the disclosure.
- Credit reference checks – When you apply for a new product, we will perform credit and identity checks on you (and certain individual(s) connected to your business) with one or more credit reference agencies (CRAs).
To do this, we’ll supply your information (and information of certain individual(s) connected to your business) to CRAs and they’ll give us information about you and them. This will include information from your loan application and about your financial situation and financial history (and the financial situation and history of the relevant individual(s) connected to your business). CRAs will supply us with both public (including the electoral register) and shared credit information, financial situation, history, and fraud prevention information.
We may use this information to:
- assess if we can offer you a loan and whether you can afford the servicing of the product offered to you;
- verify the accuracy of the data you’ve provided to us;
- prevent criminal activity, fraud and money laundering;
- trace and recover debts; and
- ensure any offers provided to you are appropriate to your circumstances.
We’ll continue to exchange information about you (and individual(s) connected to your business) with CRAs for the duration of your relationship with us. We’ll also inform the CRAs about your repayment history. If you borrow and do not repay on time and in full, CRAs will record the arrears. This information may be supplied to other organisations by CRAs.
When we send a search request to CRAs they’ll place a search footprint on your credit file (or that of the relevant individual(s) connected to your business) that may be seen by other lenders. We may use this information to verify the accuracy of the information you’ve provided to us, to prevent criminal activity, fraud and money laundering, to trace and recover debts and to ensure any offers provided to you are appropriate to your circumstances.
If you inform us of financial associate(s) (this may include a spouse), we’ll link these records together. Please discuss this with the individual(s) and share this information with them before submitting the application. Your records (and those of individual(s) connected with your business) will also be linked by the CRAs and these links will remain on both files until you or the relevant individual successfully files for a disassociation with the CRAs to break that link.
The identities of the CRAs, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share information, data retention periods and data protection rights with the CRAs are explained in more detail on their websites. They’ve created a joint document called the Credit Reference Agency Information Notice (CRAIN) which is accessible from each CRA – clicking on any of the links below will also take you to the same CRAIN document:
Credit reference agencies:
- Call Credit – www.callcredit.co.uk/crain
- Equifax – www.equifax.co.uk/crain
- Experian – www.experian.co.uk/crain
Legal basis for processing personal information
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “How to contact us” heading below.
Cookies and similar tracking technology
We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use personal information about you. Please see our Cookie Notice for more information.
How does Glenhawk keep my personal information secure?
We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
International data transfers
Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).
Data retention
We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements). Where you obtain a loan through us, we will retain this information for the period your loan is in force and 6 years after.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
Your data protection rights
You have the following data protection rights:
- If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the “How to contact us” heading below.
- In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below.
- You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “How to contact us” heading below.
- Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about our collection and use of your personal information.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
Links to other websites
Our Website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this Privacy Notice. You should exercise caution and look at the privacy notice applicable to the website in question.
Updates to this Privacy Notice
We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make.
You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the bottom of this Privacy Notice.
How to contact us
If you have any questions or concerns about our use of your personal information, please contact us using the following details: compliance@glenhawk.com.
The data controller of your personal information will be one of the Glenhawk group companies listed here: Glenhawk Financial Services Limited (Co Reg: 10962610), GFS Invest Limited (Co Reg: 11389824), GFS 1 Ltd (Co Reg: 11387725), GFS 3 Ltd (Co Reg: 12266361), and Glenhawk Property Finance Ltd (Co Reg: 11539817). The Registered Office for all these entities is 2nd Floor, Mutual House, 70 Conduit Street, London, England, W1S 2GF. Glenhawk Property Finance Ltd is authorised and regulated by the Financial Conduct Authority (firm reference number 826671). Depending on your interaction or service request this may vary.
Last updated: December 2022