Privacy Policy

1. Introduction
Fly Finance LTD (“we”, “us”, “our”, “Fly”) take data protection very seriously and we are committed to taking care of your business data and any data that may be used to identify individuals’ personal data in the course of operating the Fly Finance LTD service. This Privacy Policy, along with our Cookie Policy sets out the basis on which we will collect, process, store and disclose personal data as a controller. It includes how we process data in relation to our staff, applicants, customers, suppliers, partners (introducers and lenders), business contacts and visitors of our site. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By using our Services, you agree to grant us a royalty-free, transferable, sub-licensable, license to use your personal data for the purposes and on the basis set out in this Privacy Policy. This policy applies to Fly Finance LTD. If you have any comments in relation to this privacy policy, please email them to support@flyfunding.co.uk Here are the details that the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regards to the processing of personal data and on the free movement of such data, known as General Data Protection Regulation (GDPR) says we have to give you as a ‘data controller’:

2. Who We Are Fly Funding LTD
Our site address is www.flyfunding.co.uk
Our company is Fly Finance LTD, registered in England with registration number 14859351 and registered address at 259 Carrara Tower, 1 Bollinder Place, London, EC1V 2AG.

3. What information we collect, We collect and process the following data about you: Identity data
Including name, username or similar identifier.
Contact data
Including email address, postal address, residential address and telephone numbers.
Financial and business data
Including financial requirements (e.g. how much our customers would like to borrow), business information, bank statements, filed accounts, VAT returns, bank account information, file and payment details; in case of sole traders – other personal financial data relevant to business finance application, such as value of personal pension, value of property equity, county court judgements (personal and business), credit ratings (personal and business).
Transaction data
Including details about payments to and from you and other details of products / services you have purchased from us or products / services we have purchased from you.
Profile data
Including your username and password, your interests, preferences, feedback and survey responses.
Usage data
Including information about how you use our website and products and services that you purchase from us
Marketing and communication data
Including your preferences in receiving marketing from us and our third parties and your communication preferences.
To keep your personal information up to date, please advise us of any changes by e-mail to support@flyfunding.co.uk, and as soon as possible after any change in your name, residential address, telephone number, e-mail address and any other such important details. We do not generally 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). Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following bases applies:
you have given consent to the processing of your personal data for one or more specific purposes;
processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
processing is necessary for compliance with a legal obligation to which we are subject;
processing is necessary to protect the vital interests of you or of another natural person;
processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our credit card payment processing, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data.
We use different methods to collect data from and about you, including:
Direct interactions when you make enquires or we purchase your products or services, you create an account on our site, request marketing to be sent to you, enter a promotion or survey, or give us feedback or contact us.
Third parties or publicly available sources, including existing or prospective providers of finance to you (in the course of considering whether to make an application or making an application to them), analytics providers such as Google, advertising networks, search information providers,] and identity and contact data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
4. Cookies We use various cookies to distinguish users and improve our site. How we use what we collect

We use information about you to:
Help make decisions about credit and credit related services
Provide partner and event information
Retargeting purposes
Improve our service
Trade debtors, recover debt, prevent fraud, and to manage your accounts
Prevent fraud and money laundering
Present our site content effectively to you.
Provide information and products and services that you request, or (with soft opt-in following your purchase, your consent or if we have another lawful basis, such as legitimate interest) which we think may interest you.
Carry out our contracts with you.
Tell you our charges.

If you are a sole trader, you acknowledge that credit reference agencies link together the records of you and anyone that you have advised is a financial associate (joint credit account). Links between financial associates will remain on your, and their, credit reference files until such time as you or your partner successfully files for a disassociation with the credit reference agencies. When assessing the affordability of your repayments, we may take into account information about your financial associates in your credit reference. If you are already our customer, we will only contact you electronically about things similar to what was previously provided to or of interest to you and you will be given an opportunity to opt-out and unsubscribe from further communications. Please note: We don’t identify individuals to our advertisers, but we do give them aggregate information to help them reach their target audience, and we may use information we have collected to display advertisements to that audience. If you don’t want us to use your personal data for any of the reasons set out in this section, you can let us know at any time by contacting us at support@flyfunding.co.uk, and we will delete your data from our systems. However, you acknowledge this may limit our ability to provide our products and services to you. In some cases, the collection of personal data may be a statutory or contractual requirement, and we will be limited in the products and services we can provide you if you don’t provide your personal data in these cases. 5. Where we store your data
We store your personal data on our own service databases as well as selected third party providers, including Hubspot servers. This is used by the Fly Funding service which sends customers emails and tracks the status of applications. We may transfer your collected data outside the European Economic Area (EEA). It may be processed outside the EEA as may be necessary to provide our products and services to you, to provide our service to you, or if we have your consent. By giving us your personal data, you agree to this arrangement. We will do what we reasonably can to keep your data secure. If we give, or you create a password, you must keep it confidential. Please don’t share it. Although we try to provide protection, we cannot guarantee complete security for your data, and you take the risk that any sending of that data turns out to be not secure despite our efforts. We only keep your personal data for as long as we need to in order to use it as described above in section 3, and/or for as long as we have your permission to keep it. Our general retention period is 7 years but your data may be kept for shorter or longer periods of time, in accordance with our internal Data Retention Policy and applicable legislation. In any event, we will conduct regular reviews to ascertain whether we need to keep your personal data. Your personal data will be deleted if we no longer need it. 6. Disclosing your information We are allowed to disclose your information in the following cases:
If we want to sell our business, we can disclose it to the potential buyer.
We can disclose it if we have a legal obligation to do so, or in order to protect other people’s property, safety or rights.
We can exchange information with others to protect against fraud or credit risks.
We will also check your details with a fraud prevention agency or agencies and if you give false or inaccurate information and we identify fraud, this will be recorded and may be shared by those agencies with other organizations and us, so that we and other organizations, including law enforcement agencies and debt collection agencies may access, use and search these records as described in section3. With your permission we will share your personal data with suitable lenders for the purpose of loan underwriting. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under GDPR and the law. 7. Applicants In completing our job application form, submitting your CV or applying by LinkedIn or employment events, you will give us personal information about yourself. We will use your personal data only for the purpose of assessing your suitability for employment by us and in any subsequent interviewing process. Copies of the information you submit, and any further correspondence will be retained in order to progress your job application and as a record of our employment and fair access processes. Your application will only be processed by our People team. The information you provide to us will be stored and processed for internal recruitment purposes only. We may store and record any telephone calls you have with staff for record keeping and quality control purposes. We will retain your information in the event of an unsuccessful application for a period of 12 months, in line with GDPR. After this period the data will be anonymised. 8. Your rights You can ask us not to use your data for marketing. You can do this by ticking the relevant boxes on our forms, clicking the unsubscribe link contained in our marketing communications or by contacting us at any time at support@flyfunding.co.uk. Under the GDPR, you also have the right to:
request access to, deletion of or correction of, your personal data held by us at no cost to you;
request that your personal data be transferred to another person (data portability);
be informed of what data processing is taking place;
restrict processing;
to object to processing of your personal data; and
complain to a supervisory authority.
You also have rights with respect to automated decision-making and profiling. To enforce any of the foregoing rights or if you have any other questions about our site or this Privacy Policy, please contact us at support@flyfunding.co.uk. We may ask for further identification or confirmation via email. We will aim to respond to all requests within a 30 day period but if the request is complex we may have to extend this to a 90 day period. We shall notify you within the 30 day period if this is the case. In some cases, the deletion of your data may contravene with our requirements under other regulations, we shall inform you of such if this is the case. Where we have good reason, and if the GDPR permits, we can refuse your request for a copy of your information, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reasons for doing so. 9. Links to other sites Please note that our terms and conditions and our policies will not apply to other websites that you get to via a link from our site. We have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them. 10. Automated Decision-Making and Profiling We do not undertake any automated decision-making, including profiling.
11. Complaints
If you wish to raise a complaint on how we have handled your personal data, you can contact us to have the matter investigated. Email – support@flyfunding.co.uk. If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the Information Commissioner’s Office https://ico.org.uk
11. Notice to Staff
All staff have an obligation to read and adhere to all relevant Fly’s Policies. During the onboarding process e-learning will be assigned and completion is a requirement. Personal information held about staff will be stored securely and will only be accessible by authorized departments. All Fly hardware and software is the property of Fly Finance LTD. When leaving employment from Fly all staff are required to return all hardware. If staff use the facilities for personal use, they understand that Fly has the right to access the hardware and software at any time without notice. If communications are of a personal nature staff should clearly subject the content as personal. However, Fly will still have the right to access these if needed.
12. Changes to this Privacy Policy
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection. Any changes will be immediately posted on our site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of our site following the alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated on 24th August 2021.

Terms of business –

The client has provided or will provide upon request to Fly Finance LTD all such details of the application as Fly Finance LTD may in its opinion reasonably require and will co-operate generally with Fly Finance LTD to facilitate the processing of an application for commercial funding.
Fly Finance LTD and its providers will co-operate and liaise with the client’s legal and accountancy and other advisors in such manner as may reasonably be required in order to facilitate a successful outcome for the client.
Fly Finance LTD have been engaged in this matter to:
Source potential funding solutions;
Complete an application for commercial funding from information given by you;
Package information and documentation in an appropriate format to present to potential funders.
In carrying out our engagement Fly Finance LTD will make enquiries of management and undertake any procedures that they judge appropriate. The referred funder will also undertake Credit Reference Searches. Fly Finance LTD will look to find a lender that will offer a suitable product to meet your requirements. Fly Finance LTD will not be responsible for any detrimental information that may come to light whilst the lender undertakes their due diligence that results in the application being declined.

Conflicts of interest and confidentiality
Fly Finance LTD confirm that where you give confidential information, they shall at times keep it confidential, except as required by law or as provided for in regulatory, ethical or other professional pronouncements applicable to the engagement.
The client agrees that it will be sufficient compliance with our duty of confidence for Fly Finance LTD to take such steps as we in good faith think fit to preserve confidential information both during and after the termination of this engagement.

Limitation of liability
I/We understand that loan terms and interest rates are subject to change from time to time and the Company accepts no liability and shall not be liable for any of My/Our acts or omissions which result in the non-completion, withdrawal or cancellation of the Application;
I/We acknowledge and agree that the Company is not acting as an agent of the Lender, and any and all lending decisions will be solely at the discretion of the Lender for which the Company cannot accept any liability;
I/We hereby confirm that there is no relationship of principal and agent between Me/Us and the Company and I/We fully understand and acknowledge that the Company has not held itself out and is not holding itself out as My/Our agent;
I/We hereby acknowledge and agree that the Company does not warrant, expressly or impliedly, the accuracy or veracity of the information provided by Me/Us in the Application and that the Company shall not be liable for inaccurate or false information provided by Me/Us in the Application or otherwise;
I/We hereby unconditionally and irrevocably agree to indemnify and keep indemnified the Company from and against all and any losses, costs, claims, liabilities, damages, demands and expenses suffered or incurred by the Company and arising from My/Our acts or omissions relating to or connected with the Application and/or Me/Us providing false, inaccurate, misleading or untrue information in the Application and/or to the Company and/or the Lender in connection with the Application;
Fly Finance LTD will provide our professional services outlined in this letter with reasonable care and skill. However, we will not be responsible for any losses arising from the supply by you or others of incorrect or incomplete information, or yours or others failure to supply any appropriate information or your failure to act on our advice or respond promptly to communications from us.

Privacy Notice & Data Protection
I/We hereby consent to the Company processing any personal data that I/We provide to the Company in the Application (both online and over the phone) or in connection with the Application, in accordance with the Company’s obligations under the Data Protection Act -2018(as may be amended from time to time) for the purposes of: processing and submitting the Application to the Lender; complying with applicable laws and regulations (including, but not limited to the prevention of money laundering and fraud and the administration of the Company and Company’s records and providing Me/Us with marketing information about the Company and its products and services;
I/We confirm that I/We have the consent of any third party whose information (whether personal or otherwise) I/We have or might disclose to the Company and/or the Relevant Parties to process such information (whether personal or otherwise) for the purposes of assessing the Application and Administering and enforcing any subsequent loan which may be granted to Me/Us by the Lender;
I/We consent and agree that each of the Company and the Lender shall be entitled to hold, use, process and share, in and by any medium, the information given by me/us in the Application or connected to the Application and any other information which either party may acquire during the lifetime of the loan made to me/us arising from or connected to the Application.
I/We consent to the Company sharing any information provided by Me/Us to the Company with such persons involved in the processing and submission of the Application, including service providers, banks, lenders, partners, agents, introducers, sales companies, the Lender, solicitors, banks, surveyors, mortgage brokers estate agents and each of their respective agents (the “Relevant Parties”);
I/We acknowledge and agree that before the Application is submitted and, if the Application is successful, before the Lender advances any monies to Me/Us, the Company and/or its agents will check My/Our details with fraud prevention
A Privacy Notice has been issued separately from the Terms of Business. Being transparent and providing accessible information to individuals about how We will use Your personal data is a key element of the EU General Data Protection Regulation (GDPR)

This Privacy Notice details;
lawful bases for processing data, who We are, how We use the information about You, marketing consent, what information is collected, why the personal data is required, our data retention periods and individuals’ rights to personal data. More detailed information can be obtained on request.
You must be confident You understand how your data will be processed. If you require further clarification, please contact us before entering into an Agreement
agencies, the electoral register, Companies House or such other appropriate registry (if applicable) and obtain Credit Searches from credit ratings agencies for the purposes of verifying My/Our identity;
I/We hereby acknowledge that if I/We or such persons acting on My/Our behalf provide the Company with information that is found, at any stage, by the Company to be false, misleading, incorrect or inaccurate and, as a result, fraud is identified, details of the Company’s findings will be sent to fraud prevention agencies and/or law enforcement agencies without further notice to Me/Us;

About our services and our costs
What products do we offer?
We offer a wide range of commercial financial products including: Commercial Mortgages, Property Development Finance, Buy to Lets, Cashflow finance, Unsecured Term Loans etc
Whose products do we offer?
We offer a comprehensive range of commercial financial solutions from across the market.
Which service will we provide you?
You will not receive advice or a recommendation from us. You will need to make your own choice about how to proceed.
What will you have to pay us for our service?
We may receive Commission from the Lender as well as receiving Fees separately from You; for the avoidance of doubt these sums are subject to the terms of our arrangements with the Lender who pays that Commission. Our fee charge is a minimum of 3% on Government backed products and a minimum of 2% on core products of the total amount funded

Agreement of terms
I/We understand and agree that the Company does not and cannot guarantee that the Application will be successful and/or that the Lender will advance any sums to Me/Us further to or in connection with the Application;
I/We hereby unconditionally and irrevocably agree that the Company cannot and shall not be held liable in such circumstances where the Application is unsuccessful and/or a lender or the Lender fails to advance or loan any monies to Me/Us in relation to the Application or otherwise;
I/We understand that the Company shall use reasonable, but commercially prudent, endeavors to process and submit the Application;
I/We acknowledge that the Company will not knowingly become or be involved in compounding client problems or contract races as the result of vendor pressure;
I/We understand that the Company provides a fully non-advised service and that I/We have not and will not be provided with advice by the Company.
Fly Finance LTD will not be liable in any way to the client should it be unable to provide finance on the terms or in the form or within the time required by the client and shall in no way be liable to the client in respect of failure by the client to comply strictly with any or all terms of any finance offered by a lender to the client.
I/We agree that Fly Finance LTD reserve the right to charge a one-off admin fee for any work carried out. Please note: Fly Finance LTD may receive (on some occasions) a commission that will vary depending on the lender, product or other permissible factors. If you wish to know the fee Fly Finance LTD will receive from the lender please feel free to contact a member of the Fly Finance LTD team. By complying with these terms you agree that Fly Finance LTD will receive a fee from its panel of lenders.
We agree that the Application and these Terms of Business shall be governed by English Law and that the courts of England and Wales shall have the exclusive jurisdiction to settle any dispute arising from or connected to the Application and these Terms and Conditions;
Fly Finance LTD acts as a Commercial Finance Broker and not a Lender.