Privacy Policy

Purpose of this privacy policy

This privacy policy aims to give you information on how Pay2Day Ltd collects and processes your personal data through your use of this website (https://pay2day.co.uk/) our online platform or our services and when you communicate with us by completing a form or otherwise. When we refer to “you” or “your”, we mean visitors to our website, users of our platform and our services, individuals connected with the businesses using our services (including directors, partners, members, shareholders and beneficial owners, guarantors or any other individuals representing those businesses using our services). By accessing and using our website or platform or services, you are agreeing to be bound by this Privacy Policy. If you do not so agree, you should not use our website, platform or services.

This website is not intended for children and we do not knowingly collect data relating to children.

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.

Controller

We are the controller and responsible for your personal data.

We have appointed a data privacy manager 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 our data privacy manager using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager:

Full name of legal entity: Pay2Day Ltd.

Email address: Privacy@pay2day.co.uk

Postal address: 20-22 Wenlock Road, London, N1 7GU

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator 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.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator 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.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on [DATE].

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.

Third-party links

This website/ our platform 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.

How and when we collect your information and what do we collect

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).

We may collect, use, store and transfer different kinds of business and personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes home address, email address and telephone numbers.
  • Financial Data includes information relating to your financial requirements (e.g. how much you would like to borrow), business information, bank statements, filed accounts, VAT returns, bank account information, file and payment details. If you are a sole trader or partnership or individual guarantor, we may require personal financial data relevant to your business finance application, such as: the value of your personal pension, value of property equity, county court judgements (personal and business),
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us or from a Lender to whom we have introduced you.
  • 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, hardware devices and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, orders for services made by you, preferences, feedback and survey responses.
  • Usage Data which we obtain via log files includes information about how you use our website, and services. Such usage data is not linked to personally identifiable data and is used for analysing trends, administering our website, tracking users’ movement on the site and gathering demographic information.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties. If you consent to us communicating with you, we shall communicate via email, post or in person

We use different methods to collect data from and about you including through:

Direct interactions. You may give us, or our introducers or associates your Identity, Contact and Transaction Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • complete our Business Finance Fact Form or otherwise apply to use our services;
  • create an account on our website/platform;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us.

Or, when information is provided by your representatives or agents who engage with us on your behalf in the ways described above

Automated technologies or interactions. As you interact with our website/ platform, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources. We work closely with various third parties (including, for example, business partners, service providers, advertising networks, analytics providers, and search information providers) and may receive information about you from them.

This may include:

technical data from analytics providers such as Google based outside the EU; and advertising networks and search information providers such as LinkedIn, Instagram, Google Ads and Facebook, based outside the EU;

identity and contact data using publicly available records such as companies house, public-facing websites and social media platforms. Whilst we do not perform formal credit checks to provide our Services, to enable us to prevent fraud, we may carry out identity and soft credit checks from time to time. These may be carried out against either you as a company or as an individual (if you are a partner or sole trader, or if you are a director, shareholder or guarantor, for example). Our finance providers may wish to obtain a credit reference for you and your business, including your directors or partners or guarantors from a credit reference agency in order to determine your eligibility for their services.

The above information may be combined with other information you provide to us, as described below:

Transaction Data from finance providers.

Identity and Contact Data from our introducers and affiliates.

Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register, and fraud prevention agencies based inside the UK.

We will also collect information directly from you. If you provide information about other people (for example, if you provide information about directors, partners, members, shareholders, guarantors or beneficial owners other than yourself) then you must:

  • provide a copy of this Privacy Policy to those persons and ensure that they are aware of and understand its contents; and
  • when providing information about other people, ensure that you have all relevant permissions and authority: (i) to make all those disclosures; and (ii) to act on their behalf.

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.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). However, we do ask you about CCJ’s and bankruptcy on our Business Fact Find form as such information is required by our finance providers.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with 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 our services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

Using your information

We collect, store and use your personal data:

  • to inform you of developments and activity on our platform and of changes to our services;
  • to develop and improve our services and business, including analysing and improving our customer service offering;
  • if you are a director, partner, member, shareholder, beneficial owner or guarantor of a business signing up for our services, to ascertain your borrowing needs;
  • to carry out mandatory or other regulatory checks;
  • to comply with our legal and regulatory obligations;
  • to carry out statistical analysis and market research;
  • to contact you (including by e-mail) with products and services which we think 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, 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 platform and our related services; and
  • for the prevention and detection of fraud, money laundering, or other illegal or criminal activity.
Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out above.

  • Internal Third Parties as set out in the Glossary below.
  • External Third Parties as set out in the Glossary below.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

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:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.
We may disclose your personal data:
  • to companies in our group and our affiliates in or outside the UK;
  • to our finance providers, sub-contractors, introducers and third party data processors (including marketing and data analytics service providers, professional advisers and persons who provide us with the following services from time to time: identification and fraud check; marketing; technology; platform support; and back-up and business continuity);
  • to 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;
  • if we are required to do so by applicable law and regulation or by any governmental, tax, regulatory body or law enforcement agency;
  • if you are represented by an agent, to your agent; and
  • to any other person within your business who is nominated to communicate with us on behalf of your business.

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

Purposes for which we will use your personal data

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.

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.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer including any prerequisites including completing our Business Fact Finding Form and carrying out (or for your proposed finance providers to carry out), anti-money laundering checks, fraud prevention agency checks or credit reference agency checks (a) Identity
(b) Contact
(c) Financial
(d) Transaction		 Performance of a contract with you and as a prerequisite of that contract and to fulfil our legal obligations
To process and deliver our services including:
(a) setting up and administering your account		 (a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications		 (a) Performance of a contract with you
(b) Necessary for our legitimate interests
To register you as a new customer (a) Identity
(b) Contact		 Performance of a contract with you
To process and deliver your order: (a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications		 (a) Performance of a contract with you
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey		 (a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications		 (a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to complete a form, or complete a survey (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications		 (a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business our website and platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Technical		 (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical		 Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical
(b) Usage 		Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile 		Necessary for our legitimate interests (to develop our products/services and grow our business)
(f) Marketing and Communications
Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a purchase, service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see cookie policy

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

International transfers

Some of our third parties are based outside the UK so their processing of your personal data may involve a transfer of data outside the UK and EEA or if we engage suppliers, sub-contractors or third party data processors who are based or have operations overseas. We share infrastructure and functions with our affiliate (see Glossary below). 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, including those outside the UK. If your information is transferred to or accessible in a country which is not considered to adequately protect personal data, we will always take steps to ensure that your information is protected and that those transfers comply with applicable privacy laws. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring that:

Where we use certain service providers, we use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. All information provided by you using our online platform will be stored on our server in the UK and all information you provide to our introducers and affiliates shall be through our online platform

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

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

keep your access details to our Online Platform 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.

We would advise that you do not provide any confidential information or personal data to us or our introducers or associates via WhatsApp as this is not considered a secure means of communication and if you do so, it shall be at your own risk.;

Data retention
How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see Your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Further information on the data security measures we put in place and our data retention policy can be found in our Data Protection Protection Policy and Data Retention Policy which is available on our website.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • If you want us to establish the data's accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

1. Glossary
LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES
Internal Third Parties

Our contractors (including our introducers) acting as joint controllers or processors and who are based in the UK.

Our affiliate based outside the UK (Kozmic Tech Solutionz Private Limited (‘KTS’)) based in Mumbai India, provides us with the following services: maintenance of our website, search optimisation and marketing services, and development and maintenance of our platform. KTS processes all information in accordance with this Privacy Policy and as permitted by applicable data protection law. We use standard contractual clauses approved for use in the UK which give personal data the same protection it has in the UK. All personal data processed by them and any contractors of our affiliate based overseas from time to time is kept on our cloud servers in the UK (see below).

External Third Parties
  • Service providers acting as processors based in the UK who provide IT and system administration services, including:
  • We are, and for your greater security, currently in the process of changing our CRM, website and email server hosting provider to IONOS Cloud Ltd. (t/a Ionos) whose registered office is at Discovery House, 154 Southgate Street, Gloucester GL1 2EX, United Kingdom and whose privacy policy can be found at https://www.ionos.co.uk/terms-gtc/privacy-policy/
  • UKDedicated Ltd (t/a Guru) whose registered office is at 3 Centro, Boundary Way, Hemel Hempstead, HP2 7SU currently host our CRM server where we store application forms and client communications and documents which you upload to our platform. You can find their privacy policy here: https://www.guru.co.uk/support/privacy-policy.
  • Hostinger UK Limited whose registered office is at Nwms Centre, 31 Southampton Row, Office 3.11, London WC1B 5HJ currently uhost our website and email server. See their privacy policy here: https://www.hostinger.co.uk/privacy-policy
  • Finance providers acting as processors and joint controllers based in the UK. See a list of our finance providers together with a link to their respective websites and privacy policies, and which we may amend to from time to time, attached as an annex hereto. Each finance provider we use has their own privacy policy that explains how your data will be processed and shared. Full details of the use and disclosure of your information by the finance provider is contained within the terms and conditions of any agreement you enter with such finance provider which you should read before signing.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

ANNEX

Finance providers Privacy Policy
Other service provider data protection links

We are proud members of the National Association of Commercial Finance Brokers, the NACFB. We adhere to their Minimum Standards and Code of Practice.

NACFB

Schedule a meeting

Business loans
Business loans
Business loans
Business loans
Business loans
Business loans
Images
WhatsApp