Privacy Policy & Cookie Policy for CAS Bridging & Commercial Ltd.

(An Appointed Representative of Swoop Finance Ltd)

1. About Us

CAS Bridging & Commercial Finance Ltd (company number 8860091) is an Appointed
Representative of Swoop Finance Limited.
Swoop Finance Limited is registered in England and Wales (company number 11163382) and
has its Registered Office at The Stable Yard, Vicarage Road, Stony Stratford, Milton Keynes,
Buckinghamshire, England, MK11 1BN.
Swoop Finance Limited is an authorised and regulated provider by the Financial Conduct
Authority as an Account Information Services Provider (reference number 833145) and as a
credit broker under FCA registration number 936513.
Swoop Finance Limited is registered with the Information Commissioner’s Office (reference
number ZA600162).

2. Who we are and how to contact us

We are CAS Bridging & Commercial Finance Ltd (“we”, “us” and “our” in this privacy
policy), an Appointed Representative of Swoop Finance Limited. We assist you with business
finance and cost savings options by using the Swoop platform and their network of providers.
Swoop Finance Limited is the data controller responsible for all personal information
collected and processed through our services and by the company.
‘Business’ refers to customers who use our services (“you “and “your” in this privacy policy).
You must have provided permission to us to act on your behalf.
It is most important that you read this privacy policy carefully so that you are fully aware of
how and why your personal information is used. We do not knowingly collect personal
information relating to children under the age of 18 – children under the age of 18 should not
use our services.
If you have any questions about this privacy policy or if you wish to exercise your legal rights,
please contact our Data Protection Officer (DPO) at Swoop.

2.1 Our contact details are:

• For all business and initial privacy inquiries:
  CAS Bridging & Commercial Finance Ltd
  Spaces, The Maylands Building
  Maylands Avenue
  Hemel Hempstead
  Herts
  HP2 7TG
  Tel. 01923 375775
  E: [email protected]
• For Data Protection Officer (DPO) and regulatory matters:
  Swoop Finance Limited
  120 Regent St. London, W1B 5FE
  Tel: 0203 511 3044
  Email: [email protected]

3. Changes to this privacy policy

We reserve the right to amend or modify this privacy policy from time to time. All amended
versions of this privacy policy will be posted on our website and on the Swoop website.

4. Types of personal information we collect

Depending on the requirements of your business, we may obtain any of the following:
● personal information, so that we can identify who you are (e.g. your name and your date
and place of birth)
● personal information so that we can contact you (e.g. your home address, your email
address and your contact telephone number)
● other more personal information so that we can help you with your business
requirements (e.g. details about your health or criminal convictions/ offences – this data
is known as “special category data” and we will only collect this data if the law allows us
to do so)
● behavioural and/or technical personal information (e.g. details about how you browse
the Swoop website, and the devices and technology you use to browse the website)

4.1 How we use personal information:

Swoop Finance Limited is the data controller responsible for all personal information
collected and processed through our services and by the company. The personal information
we collect is used to:
• Provide you with our Service: To offer you finance and savings options, to provide
you with access to Swoop’s services and to share your information with our approved
finance/service providers, credit reference agencies, and other third parties.
• Carry out our business services: To verify your identity, assess your business’s
eligibility for finance and savings options, and to communicate with you about your
account.
• Manage our relationship with you: To keep our records updated, provide customer
support, and to ask you to complete surveys to help us improve our services.
• Prevent fraud and illegal activity: To protect you and our business from fraud and
illegal activity.
• To comply with the law: To meet our legal and regulatory obligations, including
reporting to the Financial Conduct Authority and the Information Commissioner’s
Office.
• For marketing purposes: To send you marketing communications about products
and services that we believe may be of interest to you. We will only do this where you
have provided your consent.

4.2 How we collect personal information

We collect personal information from you when you interact or engage with us, including
when you register an account with Swoop via their website. We may also collect personal
information from you when you talk to us on the phone, by post or online, including via email.
We may also engage with you and hence collect personal information from you if you choose
to provide feedback or take part in any of our other market research initiatives, customer
surveys or promotions.
Occasionally, we may also collect personal information about you from our approved
finance/service providers, third parties or publicly available sources.

4.3 Third parties with whom we may exchange personal information

We may share personal information with or receive personal information from:
● Swoop Finance Ltd, our Principal Firm.
● Other members of our corporate group, including our and their professional advisers.
● Swoop’s approved finance/service providers,
● Other third-party providers (for example, Companies House),
● Our regulators and other regulatory bodies, including the Financial Conduct Authority
and the Information Commissioner’s Office.
● law enforcement and fraud prevention agencies.
● third parties to whom we may sell, transfer or merge parts of our business or assets or
third parties whose business or assets we may acquire; and
● our third-party suppliers (for example, IT software and service providers, IT maintenance
and hosting, marketing/PR agencies).
We work closely with our partners to ensure that we only share information with them, and
they only share information with us, that is either required to provide you with the services or
is required by law.

4.4 How third parties with whom we exchange personal information may use

that personal information
Third parties who receive your personal information from Swoop are only authorised to use
that information to the extent that it is required for them to provide you with the services that
you have requested. If any third party wishes to use your personal information for any other
purpose, they must seek your consent to do so. Our partners are obligated to operate in
accordance with their own data protection and privacy policies. The third parties with whom
Swoop may exchange personal information include, but are not limited to, the following:
• Providers of the finance or savings products you are applying for.
• Credit reference agencies and fraud prevention agencies.
• Banks and other financial institutions.
• IT and software providers.
• Marketing and communications service providers.
We have contractual arrangements in place with third-party service providers to ensure that
all personal information transferred to them is treated in accordance with applicable data
protection law.

5. What communications you may receive from us

Direct Marketing: We will only send you marketing communications where you have
provided your consent for us to do so. If you have provided your consent, we will send you
marketing communications by email, post, phone, and/or SMS/text message. You have the
right to withdraw your consent to receive marketing communications at any time.
Service Communications We will send you service communications by email, post, phone,
and/or SMS/text message to provide you with information about your account, your
applications, and to provide you with updates on the services you have requested. You
cannot opt out of receiving service communications.

5.4 How long we retain personal information

We will only retain your personal information for as long as necessary to fulfil the purposes
for which it was collected, including for the purposes of satisfying any legal, accounting, or
reporting requirements. As required by the FCA, we are obligated to retain certain records for
a minimum of five years from the date on which the records were created.

6. Data security

We have put in place appropriate security measures to prevent your personal information
from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
In addition, we limit access to your personal information to those employees, agents,
contractors and other third parties who have a business need to know. They will only process
your personal information on our instructions, and they are subject to a duty of
confidentiality.
Your Legal Rights. Under certain circumstances, you have the right to:
• Request access to your personal information (commonly known as a “data subject
access request”). This enables you to receive a copy of the personal information we
hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables
you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or
remove personal information where there is no good reason for us to continue to
process it. You also have the right to ask us to delete or remove your personal
information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information 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.
• Request the restriction of processing of your personal information. This enables
you to ask us to suspend the processing of personal information about you, for
example, if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.
Cookies: A cookie is a small file of letters and numbers that we store on your browser or the
hard drive of your computer. We use cookies to distinguish you from other users of our
website. This helps us to provide you with a good experience when you browse our website
and also allows us to improve our site.

7. Complaints

You can complain to us or the Information Commissioner’s Office at any time. However, we
appreciate the chance to deal with your concerns so please do contact CAS Bridging &
Commercial Finance Ltd in the first instance.
You can contact us at:
[email protected]
If we are unable to resolve your complaint, you can refer the matter to Swoop Finance Ltd as
our Principal Firm at:
[email protected]
The ICO may be contacted on 0303 123 1113 during normal opening hours of Monday to
Friday between 9am and 5pm (excluding bank holidays).