Privacy Policy

This Policy contains important information about your personal rights to privacy. Please read this Policy carefully beforeusing the services provided through the Website or providing your personal information to Charm Impact. This Policy is a supplement to our Terms of Service. In case of any contradiction between the provisions in this Policy and in our Terms of Service the latter shall prevail. Unless otherwise defined in this Policy, terms used in the Policy shall be given the same meaning as in our Terms of Service that are accessible at www.charmimpact.com.

By accessing and using our website, marketplace and services, you confirm that you have had a proper opportunity to readthis Privacy Policy, that you understand it and that you agree to be bound by it. If you do not, you must immediately cease use of our website and marketplace, and any services provided by us.

Who are we?

www.charmimpact.com (this “Website”) is a site operated by Charm Impact Ltd. (“us”, “we”, “ours”). We are incorporated in England and Wales (registered company number 11674620) whose registered office is at 23 Milton Drive, Borehamwood, WD6 2BA.

To contact us, please email hello@charmimpact.com

How Charm Impact collects personal data

If you engage with us in any way, we may collect the following information about you through the methods of contact you choose to use at the point of engagement:

information you provide through our website and through our application and verification processes;
information you provide through communications with us, whether in writing (including by letter or email) or on the telephone (including by way of recorded calls) or online chat;
information we obtain through your engagement with us on social media, including on blogs, forums and through Facebook, Instagram and Twitter;
information provided on your behalf by your representatives or agents (“Agents”) who engage with us on your behalf in the ways described above.
information and reports from credit reference agencies, fraud prevention agencies, insolvency practitioners, debt advisers and tracing agents;
commercial and marketing databases;
public records and other publicly available information sources.

If you wish to become a user you will need to provide us with the following information, which we may also collect from third parties:

your personal details (including name, date of birth, current and previous postal addresses);
your contact information (including phone and email details); (for borrowers, those representing borrowers and relevant institutional investors) your business name and contact information;
financial information (including bank or building society account details);
information you provide in our registration or application processes (including, if you are a borrower, Agent or relevant investor, certain personal data, identity verification, contact details and financial information about directors, partners, members, shareholders, beneficial owners and guarantors);
information you provide in your dealings with us and through your interaction with the Website;
if you are a borrower or a director, partner, member, shareholder, beneficial owner or guarantor of a borrower:
information about your business or company, such as previous credit applications and the conduct of your accounts, and similar personal credit information;
electoral register information;
fraud prevention information;
passwords and security question answers.

In addition to the personal and financial information you submit or we collect, we may also collect information about your computer (including, where available, your IP address, operating system and browser type), your interaction with our website, and email performance data. We use this information for several reasons, including for marketing, for marketplace administration and for service improvement. Our Cookies Policy describes these processes in more information.

We also collect and retain copies of our correspondence with you as well as other data relating to your activities on the website; details about visitors to our website for the purposes of aggregating statistics or reporting purposes and to calculate referral fees; and comments made on blogs and discussion forums in connection with the website.

We may receive personal data (such as medical information or criminal records). Where relevant, we will hold and process this data to allow us to make decisions about you and your accounts with us (or with which you are connected). This may involve us sharing your sensitive personal data with Agents. We will process sensitive personal data only in accordance with the requirements of applicable privacy law.

If you provide information about other people (for example, if you represent a borrower and you provide information about directors, partners, members, shareholders or beneficial owners other than yourself) then you confirm:

you have provided a copy of this Privacy Policy to those persons and you have ensured that they are aware of and understand the contents of this Privacy Policy; and
by providing information about other people, that you have all relevant permissions and authority (i) to make all those disclosures, (ii) to act on their behalf and (iii) in relation to partners, members, shareholders or beneficial owners of borrowers, to allow us to make credit checks at credit reference agencies in respect of those persons.

Using your information

We collect, store and use your personal data:

to inform you of developments and activity and of changes to our products and services;
to develop and improve our services, products and business, including analysing and improving our credit risk models and our customer service offering;
if you are a borrower (or a director, partner, member, shareholder, beneficial owner or guarantor of a borrower):
to ascertain your borrowing needs;
to assess your creditworthiness and to make credit-related decisions; and
if you miss any repayment of your loan, to trace your whereabouts and recover debts or enforce a loan contract and to verify any payment plan you have proposed or income and expenditure form you have submitted;
to transfer money;
to carry out mandatory or other regulatory checks;
to comply with our legal and regulatory obligations;
to carry out statistical analysis, market research and testing;
to contact you (including by SMS and email) with products and services which we believe may interest you (at all times taking into consideration your rights at law including your right to opt-out from receiving marketing from us);
to open accounts with us and to manage and maintain those accounts;
to verify your identity and the other information you have provided to us, including your bank account information and (if relevant) the identity of your business associates;
to update the records we hold about you from time to time;
to provide and administer the marketplace and our related services; and
for the prevention and detection of fraud or other illegal or criminal activity.

Retaining Data

We will not keep your personal data for longer than is necessary for the purposes for which it was collected and is processed and for the purposes of satisfying our legal, accounting or regulatory reporting requirements. These requirements generally permit us to retain our borrower and investor records for a period of six years after the end of the borrowing/investing relationship (i.e. the date on which we no longer provide services to you as a borrower or investor). We may retain data for longer than this in certain circumstances, for example in the event of an ongoing dispute.

Disclosing your information

We may disclose your personal data to other registered members of our website, including:
to provide transactional and performance information;
to provide updates (including if and when there are late repayments or if and when a risk-banding has been downgraded);
if required to enforce (or make preparations to enforce) any loan contract.

If you receive information about another user, then you must only use that information to communicate with us about your loan contract with that member. You acknowledge that we are not responsible for misuse of transactional or other information by our members but you must inform us promptly if you are the victim of any misuse of that information.

We may disclose your personal data to:

to companies in our group and our affiliates;
to our suppliers, sub-contractors and third party data processors (including card payment and direct debit payment processors, marketing and data analytics service providers, collection agents, tracing agents, insolvency practitioners, professional advisers and persons who provide us with the following services from time to time: identification and fraud check; marketing; technology; marketplace support; and back-up and business continuity);
with any third party you have asked us to share your personal data with, including social media sites if you have asked us to connect with your social media account;
to credit reference and fraud prevention agencies;

if we are unable to provide you with credit and if you consent, to third parties who may be in a position to arrange credit for you;

to a third party if it acquires all or part of our business or assets in connection with the acquisition, or to a successor in interest in the unlikely event of our insolvency, winding up or liquidation;
If we are required to do so by applicable law and regulation, governmental, tax or regulatory body or law enforcement agency;
if you are represented by an Agent, to your Agent; and
to any other person with your prior consent to do so.

Third parties who process your personal data on our behalf are only permitted to process your personal data in accordance with our instructions and we will take steps to ensure that the transfer and any on-going processing by those third parties is carried out securely and in accordance with applicable privacy laws.

Save as expressly provided above, we will not share your personal data with any third party without your consent.

Overseas Transfers

We are part of a global business, in order to support our business in the most efficient manner possible, we share infrastructure and functions across our business internationally. This means that we may transfer your personal data to, or your personal data may be accessible in, any location in which we do business.

We may transfer your information to other countries, including those outside the European Economic Area, either for storage purposes or if we engage suppliers, sub-contractors or third-party data processors who are based or have operations overseas. We will always take steps to ensure that your information is protected and that those transfers comply with applicable privacy laws.

False information and Fraud Prevention Agencies (“FPAs”)

If you give us false or inaccurate information or if we suspect or identify fraud we may record this and may also pass this information to FPAs (such as CIFAS) and other organisations involved in crime and fraud prevention including law enforcement agencies.

We and other organisations may access and use this information in order to prevent fraud, money laundering or other criminal activity (for example, by checking details on credit applications, for managing credit and recovering debt). Please contact us if you want to receive details of the relevant fraud prevention agencies at hello@charmimpact.com.

Your rights

You may, at any time:

exercise your right to request access to certain personal data records we hold about you (a subject access request), request that we update and correct any out-of-date or inaccurate personal data we hold or by emailing hello@charmimpact.com;
opt out of any marketing communications that we may send you by emailing us at hello@charmimpact.com; and
exercise your right to object to our continued processing or your right of erasure, neither of which is a guaranteed or absolute right. We will consider all requests of this nature and take into account any compelling legitimate grounds to continue processing, for example our need to continue to process your personal data in connection with any legal or regulatory requirements to which we are subject

You may also request that the CRAs we use provide you with information that they hold about you. You must contact them directly to do this.

Security and other Third Parties

We do our best to safeguard the personal data that you provide to us, but we accept no liability if communications are intercepted by third parties or incorrectly delivered or not delivered.

If we transfer your information to third parties we will take steps to ensure that the transfer and any on-going processing by those third parties is carried out securely and in accordance with applicable privacy laws.

The website and marketplace contain links to other websites operated by third parties. This Privacy Policy applies only to the personal data that we collect and we are not responsible for personal data that third parties may collect, store and use through other websites.

You also have a responsibility to ensure that your information is kept secure. If you are a member of our website, you must:

keep your login details secret;
log out of your account when not using it;
maintain good internet security (for example, be careful when using public WiFi or shared access internet connections); and
tell us immediately if you think your account has been compromised.