00.PL.11_13_0726

Who we are
Moorgate Finance Limited, trading as MBN®, Transition Finance and Finance British Business (“we”, “us” or “our”), is responsible for your personal data.

Registered address: The Dovecote, Pury Hill Business Park, Alderton Road, Towcester, NN12 7LS
Email: compliance@thembn.co.uk
Phone: 01908 926262

For data protection purposes, we may act as:

• Data Controller: where we decide how and why your personal data is used; or
• Data Processor: where we process personal data on behalf of another organisation, following their instructions.

What this notice covers
This notice explains:

• What personal data we collect
• How and why we use it
• Who we share it with
• How long we keep it
• Your rights and how to exercise them

It should be read alongside any other privacy information we provide to you.

How we collect your personal data

We may collect personal data from you directly or indirectly, including through:

• Application forms and enquiries
• Telephone calls, emails and other correspondence
• Our website and cookies
• Credit reference agencies and fraud prevention agencies
• Publicly available sources (such as Companies House)
• Third parties acting on your behalf

If you provide information about another person, you must ensure they have given their permission for you to do so.

If you do provide such information, you confirm that the individual has:

• Authorised you to act on their behalf
• Consented to the provision of their data to the Company
• Consented to the processing of their data
• Agreed to receive data protection notices through you
• Consented to any potential transfer of their data outside the UK/EEA, if required

Information about others, such as financial associates, may be considered alongside your own personal data when assessing applications or eligibility for services.

Where we receive your information from

We may receive your personal information:

• directly from you
• from another business or professional adviser who has referred you to us
• from a lender, finance provider or intermediary involved in your application
• from other third parties where permitted by law

Where your information has been provided by another business or professional adviser, we expect that they have informed you:

• who your information is being shared with
• why it is being shared
• what information is being shared
• that we will contact you regarding the services we provide

Once we receive your personal information, we are responsible for processing it in accordance with this Privacy Notice.

If you have any questions about how we use your personal information after we receive it, please contact us using the details set out in this Privacy Notice.

Call recordings

We may record telephone calls to:

• Maintain security
• Resolve complaints
• Train staff and improve service quality

Cookies & Website Technologies

Our website uses cookies and similar technologies to:

• Ensure the website functions correctly.
• Improve website performance and user experience.
• Analyse website traffic.
• Support marketing activities where you have given consent.

Where required by law, we obtain your consent before placing non-essential cookies on your device. You can manage your preferences through our Cookie Banner or browser settings at any time.

Further information is available in our separate Cookie Policy.

What personal data we collect

Depending on your interaction with us, we may collect:

• Personal and contact details
• Date of birth and identification information
• Employment and income details
• Financial, banking and credit information
• Information relating to applications, accounts or services
• Marketing preferences
• Information from credit reference and fraud prevention agencies

Special Category Data
In limited circumstances, we may process sensitive personal data (such as health information). We only do this where it is necessary and permitted by law, and with appropriate safeguards in place.

Customer Vulnerability

In certain circumstances, we may collect information relating to a customer’s vulnerability, such as physical or mental health conditions, bereavement, financial resilience, caring responsibilities or other life events where this information is relevant to providing appropriate support or ensuring suitable financial outcomes.

We process this information only where permitted by law, applying appropriate safeguards to protect your privacy. This information helps us meet our legal and regulatory obligations, including our duties under the Financial Conduct Authority’s Consumer Duty.

If you do not provide personal data

If you choose not to provide information that is necessary for us to provide a service, we may be unable to proceed. We will explain this to you at the time.

How we use your personal data

We use personal data only where the law allows us to do so. This includes where processing is:

• Necessary to provide or arrange services
• Required to meet legal or regulatory obligations
• Necessary for our legitimate business interests (where these do not override your rights)
• Based on your consent (where required)

We may use your data to:

• Assess applications and eligibility for services
• Communicate with you
• Carry out identity, credit and fraud checks
• Meet legal and regulatory requirements
• Improve our services and systems
• Send marketing communications where you have agreed

Credit reference and fraud prevention agencies

We and our lenders carry out checks to prevent fraud and money laundering, and to verify your identity. These checks require the processing of personal data.

The personal data used may include your name, address, date of birth, contact details, financial and employment information, application details, and technical data such as device identifiers and IP address.

This information may be shared with credit reference agencies and fraud prevention agencies, who may combine it with data from other organisations and public sources. Fraud prevention agencies may also allow law enforcement authorities to access and use this information to detect, investigate and prevent crime.

Our lenders process this information where it is necessary:

• to comply with legal and regulatory obligations
• to protect against fraud and financial crime; and
• as a contractual requirement of the services or finance you have requested

If a fraud or money-laundering risk is identified, services or finance may be refused, and additional checks may be required. Records held by fraud prevention agencies may be kept for up to six years and may be used by other organisations when assessing future applications for services, finance or employment.

Automated Processing / Automated Decision-Making

Some decisions may be supported by automated processes, such as credit scoring. Where required by law, safeguards are in place and you may request a human review.

Artificial Intelligence

We may use technology, including artificial intelligence (AI) assisted systems, to support administrative activities, improve operational efficiency and enhance customer service.

AI is not used to make decisions that produce legal or similarly significant effects without appropriate human oversight. Where automated processing significantly affects you, you have the right to request human intervention, express your views and challenge the decision.

Who we share your data with

We may share your personal data with:

• Other companies within our corporate group
• Finance providers and service partners
• Professional advisers and service providers
• Regulators, law enforcement or authorities where legally required

We do not sell your personal data. If our business is restructured or sold, personal data may be shared with relevant parties subject to appropriate safeguards.

Lenders’ Privacy Notices

Where we share your personal data with lenders or finance providers, those organisations will process your personal data as independent data controllers in accordance with their own privacy notices.

Links to our lenders’ privacy notices are available at: https://www.moorgatefinance.com/lender-privacy-policies/

You should review the relevant lender’s privacy notice to understand how your personal data is used by that organisation.

International Transfers

We do not routinely transfer personal data outside the United Kingdom. Where personal data is transferred outside the UK, including to countries within the European Economic Area, we ensure appropriate legal safeguards are in place, such as adequacy regulations or approved contractual protections.

How long do we keep your data
We keep personal data only for as long as necessary. Typical retention periods include:

• Enquiries: up to 3 years
• Contracts and services: at least 6 years after the relationship ends
• Legal or regulatory records: as required by law

Managing your marketing preferences
We may contact you with marketing communications where you have agreed to receive them. You can opt out at any time by:

• Using the unsubscribe link in emails, or
• Contacting us at compliance@thembn.co.uk

Service-related messages will still be sent where necessary.

Your data protection rights

You have the right to:

• Be informed about how your data is used
• Access your personal data
• Request correction of inaccurate data
• Request deletion or restriction of processing in certain circumstances
• Object to processing, including direct marketing
• Request data portability
• Request human review of certain automated decisions

To exercise your rights, contact us at:

Moorgate Finance Ltd T/A MBN®
The Dovecote, Pury Hill Business Park, Alderton Road, Towcester, NN12 7LS
Email: compliance@thembn.co.uk
Phone: 01908 926262
ICO Registration Number: ZA087435

We may need to verify your identity before responding to a request.

Complaints
If you are unhappy with how we handle your personal data, please contact us first so we can try to resolve the issue.
You also have the right to complain to the Information Commissioner’s Office (ICO):
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF

Helpline: 0303 123 1113
Website: https://ico.org.uk
Email: casework@ico.org.uk

00.PL.11_13_0726