Novellus Limited (together with its affiliated companies – “Novellus”, “we”, “our” or “us”) puts great efforts in making sure that your personal data is kept safe and used properly and responsibly. We an experienced private lender located in Novellus Bridging, T Bromley, 15-17 London Road, Bromley, BR1 1DE. Our dedicated team have vast experience in lending to the UK and Ireland property market. We provide loans secured against a wide range of assets including (but not limited to) buy to let and commercial properties, land (with or without planning) and properties requiring refurbishment or change of use (our “Services”).
- Borrower Data relating to individuals or companies who are borrowers or potential borrowers of Novellus (“Borrower(s)”);
- Introducer Data relating to individuals (Introducers, Partners and Brokers) who engage with Novellus and may provide personal data regarding potential Borrowers. (“Introducer(s)”);
- Sites Usage, Customer Relationship Management (“CRM”) & Prospect Data, relating to visitors of our website, participants at our events, business clients, partners, and any prospective Borrower and Introducer who visits or otherwise interacts with any of our websites, online ads and content, emails or other communications under our control (“Novellus Sites” or “Sites”).
- Data Collection
- Data Uses
- Data Location and Retention
- Data Sharing
- Cookies and Tracking Technologies
- Data Security
- Data Subject Rights
- Data Controller/Processor
- Additional Notice & Contact Details
You are not legally required to provide us with any personal data, and you are free to do so or not to do so. If you do not wish to provide us with your personal data, or to have it processed by us or any of our Service Providers (defined below), please refrain from accessing, using or registering to our Services or sending us your personal data.
1. Data Collection
(i) Borrower Data. We may collect the following types of personal data relating to our customers (“Borrower Data”):
- Personal Data: full name, date of birth, nationality, passport number, contact details (e-mail address, mobile number), address and further information relating to residence (e.g. owned or rented and time at previous address – if the individual resided less than three years at the current address).
- Employment History Data: employment status, employer name, nature of business, length of time employed/self-employed.
- Financial Data: Credit history, mortgage status, bank account information, bankruptcy, Individual Voluntary Arrangement, court judgments, and other information which may impact the Borrower’s creditworthiness.
- Direct Interactions and Communications Data – including recordings and transcripts of your calls, emails, form submissions and chats with us, e.g. for customer support, feedback etc.
- In the case of a corporate Borrower, in addition to the information listed above, we may also collect Director/Shareholder Data: full name, date of birth, nationality, contact details (e-mail address, mobile number), address and further information relating to residence (e.g. owned or rented, time at previous address) and shareholding percentage.
(ii) Introducer Data: we may engage with Introducers, and receive information relating to potential Borrowers form them.
We may collect and generate the following types of personal data relating to Introducers (“Introducer Data”):
- Personal Data: full name, contact details (e-mail address, mobile number, etc).
- Direct Interactions and Communications Data: including recordings and transcripts of Introducer’s calls, emails, form submissions and conversations with us, e.g. for customer support, feedback, training purposes, etc.
(iii) Sites Usage, CRM & Prospective Client Data, and Human Resources Data. We may collect and generate the following types of personal data concerning our website visitors, partners Introducers, Borrowers and prospective Borrowers (collectively, “Non-Services Related Data”):
- Sites Usage Data – connectivity, technical and aggregated usage data, such as user agent, IP addresses, device data (like device type, OS, device ID, browser version, locale and language settings used), activity logs, session recordings, and the cookies and pixels installed or utilized on our Sites and/or a user’s device;
- Business Account Data – contact details, contractual and billing details relating to our vendors, which may also contain the details of their internal focal persons who directly engage with Novellus on behalf of their organization (e.g. the account administrators, billing contacts and authorized signatories on behalf of the vendor, as well as their needs and preferences, as identified to us or recognized via our engagement with them);
- CRM and Prospective Client Data – contact and business details, our communications with Borrowers and prospective Borrowers (correspondences, call and video recordings, call transcripts, and analyses thereof), as well as any needs, preferences, attributes and insights relevant to our potential engagement.
- Human Resources Data – contact, business and personal details regarding Novellus job applicants, CVs, photographs and our communications with job applicants (correspondences, call and video recordings, call transcripts), as well as evaluations and feedback following interviews and other interactions with us.
We collect the above Non-Services Related Data either automatically, through the data subject’s interaction with us or with our Sites or Services; or through third party services, social media, analytics tools, events we organize or participate in, and other business initiatives.
2. Data Uses
We use personal data as necessary for the facilitation and performance of our Service; to comply with our legal and contractual obligations; and to support our legitimate interests in maintaining and improving our Services; providing customer service and technical support; and protecting and securing our clients, partners, ourselves and our Service.
Further detail about the legal basis on which we rely for each type of processing can be found in the table below.
|Borrower & Introducer Data|
|Purpose||Legal basis for processing|
|Provision of our Services||▪ Performance of a contract.
▪ Legitimate Interest
|To comply with applicable laws and regulations||▪ Compliance with a legal obligation|
|Sending marketing communications||▪ Legitimate Interest
|To support and enhance our data security measures, including for preventing and mitigating the risks of fraud, money laundering, error or any illegal or prohibited activity.||▪ Legitimate Interest
▪ Compliance with legal obligations
|To create aggregated data, inferred non-personal data or anonymized or pseudonymized data (de-identified data), which we or our business partners may use to provide and improve our respective Services, conduct research, or for any other purpose||▪ Legitimate Interest|
|To comply with applicable laws and regulations||Compliance with legal obligations|
|Non-Services Related Data|
|Purpose||Legal basis for processing|
|To facilitate, operate, and provide our Service||▪ Legitimate Interest
▪ Performance of a Contract
|To provide our visitors, Users Borrowers and Introducers with assistance and support.||▪ Legitimate Interest
▪ Performance of a Contract
|To evaluate and develop new features, technologies, and improvements of our Services.||▪ Legitimate Interest|
|To facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and services more effectively, including on other websites and applications.||▪ Legitimate Interest|
|To contact our Site visitors, Users and Borrowers (whether existing or prospective) with general or personalized service-related messages, as well as promotional messages that may be of specific interest to them.||▪ Legitimate Interest
|To facilitate, sponsor and offer certain events, contests and promotions.||▪ Legitimate Interest
|To publish your feedback and submissions to our Sites, public forums and blogs.||▪ Legitimate Interest
▪ Performance of a Contract
|To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity.||▪ Legitimate Interest|
|To create aggregated data, inferred non-personal data or anonymized or pseudonymized data (de-identified data), which we or our business partners may use to provide and improve our respective services, conduct research, or for any other purpose.||▪ Legitimate Interest
▪ Performance of a Contract
▪ Compliance with legal obligations
|To comply with applicable laws and regulations.||▪ Compliance with legal obligations|
3. Data Location & Retention
Data Location: Your personal data may be maintained, processed and stored by us and our authorized Service Providers (defined below) in multiple locations, including in the United States, Europe and the United Kingdom, as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law.
Data Retention: We will retain your personal data for as long as it is reasonably necessary for us to maintain our relationship with you and provide you with our Services and offerings; in order to comply with our legal and contractual obligations; or to protect ourselves from, or defend, any potential or actual disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our contractual terms and data retention policy. Generally speaking, we will hold Borrower Data (and any data related to financing we have provided) for a period of 5 years following the end of a contract.
Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your personal data for any particular period, and we are free to securely delete it or restrict access to it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by e-mail at [email protected].
4. Data Sharing
Legal Compliance: In exceptional circumstances, we may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement) and where such disclosure is necessary to comply with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; or (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect the security or integrity of our Services.
: We engage selected third-party companies and individuals to perform services complementary to our own. Such service providers hosting and server co-location services, communications and content delivery networks (“CDNs”), billing and payment processing services, data and cyber security services, fraud detection and AML prevention services, web analytics, e-mail, monitoring and analytics services, search engine optimization services, document storage (e.g. SharePoint), collaboration and backup (e.g. Dropbox) services, voicemails, support and customer relation management systems, and our legal, financial and compliance advisors (collectively, “Service Providers“).
Protecting Rights and Safety: We may share your personal data with others if we believe in good faith that this will help protect the rights, property or personal safety of Novellus, any of our users, partners or clients, or any members of the general public.
For the avoidance of doubt, we may share your personal data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have rendered such data non-personal and anonymous. We may transfer, share or otherwise use non-personal data at our sole discretion and without the need for further approval.
5. Cookies and Tracking Technologies
Cookies are packets of information sent to your web browser and then sent back by the browser each time it accesses the server that sent the cookie. Some cookies are removed when you close your browser session. These are “Session Cookies”. Some last for longer periods and called “Persistent Cookies”. We use both types.
We use Persistent Cookies to remember your log-in details and make it easier for you to log-in the next time you access the Services. We may use this type of cookies and Session Cookies for additional purposes, to facilitate the use of the Services’ features and tools.
Every browser allows you to manage your cookies preferences. Please bear in mind that disabling cookies may complicate or even prevent you from using certain parts of features of the Services.
We also use analytics tools such as Google Analytics. These tools help us understand your behavior on our Services, including by tracking page content, and click/touch, movements, scrolls and keystroke activities. Further information about the privacy practices of our google analytics is available at: www.google.com/policies/privacy/partners/;
Further information about your option to opt-out of google analytics services is available at: https://tools.google.com/dlpage/gaoptout.
Please note that if you get a new computer or device, install a new browser, erase or otherwise alter your browser’s cookie file (including upgrading certain browsers), you may also clear the opt-out cookies installed once you opt-out, so an additional opt-out will be necessary to prevent additional tracking.
Service Communications: We may send you notifications (through any of the means available to us, including by email, SMS and mobile notifications) of changes or updates to our Services, billing issues, service changes, etc. Please note that you will not be able to opt-out of receiving certain service communications which are integral to how we operate our Services (for example, payment notices).
Promotional Communications: We may also notify you about additional loan offerings, events and special opportunities or any other information we think you will find valuable. We may provide such notices through any of the contact means available to us (e.g. phone, SMS, mobile notifications or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms.
7. Information Security
We and our hosting services implement systems, applications and procedures to secure your personal data, and to reduce the risks of theft, damage, loss of data, or unauthorized access or use of personal data. These measures provide sound industry standard security. However, although we make efforts to protect your privacy, we cannot guarantee that the Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.
8. Data Subject Rights
Individuals have rights concerning their Personal Data. If you wish to exercise your privacy rights under any applicable law, including the EU General Data Protection Regulation (“GDPR”) or the UK GDPR, such as the right to request access to, and rectification or erasure of your Personal Data held by Novellus, or to restrict or object to your Personal Data’s processing, or to exercise your rights to portability with respect to your Personal Data or your right to equal services and prices (each to the extent available to you under the laws which apply to you) – please contact us at: [email protected].
Please note that when you ask us to exercise any of your rights under this policy or applicable law, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of personal information related to others and to ask you to provide further information to better understand the nature and scope of data that you request to access. Such additional data will be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request), in accordance with Section 3 above.
We may redact from the data which we will make available to you, any personal data related to others.
9. Additional Notices
Our Services are not designed to be used by children under the age of 16: We do not knowingly collect personal data from children and do not wish to do so. If we learn that a person under the age of 16 is using the Services, we will attempt to prohibit and block such use and will make our best efforts to promptly delete any personal data stored with us with regard to such child. If you believe that we might have any such data, please contact us by e-mail at [email protected]
Effective Date: 26 November, 2021