This notice sets out the ways in which West One Loan Ltd (WOL) will collect and use your personal data in providing you with investment opportunities in residential and commercial backed property loans. It is important that you read and understand this document as this gives detail on how and in what circumstances your data will be used and to which other third parties, we will share the data in order to effect your investment participation.
If you have any concerns or queries in regards to this, or the information set out within, please feel free to contact us to discuss these.
You can contact our Data Protection Officer or Head of Compliance by the following methods:
In writing: West One, 3rd Floor, The Edward Hyde Building, 38 Clarendon Road, Watford, WD17 1JW
By phone: 020 8731 5333
WOL is a small authorised UK Alternative Investment Fund Manager (AIFM). The company is a manager of Alternative Investment Funds which are designed to enable Professional Investors invest monies into loans which are provided to individuals and corporate borrowers for short term bridging finance. The firm is also authorised as a mortgage lender with the FCA, under which we underwrite the loans for which you, as an investor, provide funds.
The firm’s reference number with the FCA is 510024. You can check this, and obtain more detail on the company, on the Financial Services Register website: https://register.fca.org.uk/ or by contacting the FCA on 0800 111 6768.
WOL is also registered with the Information Commissioner’s Office under reference number: Z2651210. Further information on how the company uses and stores your data can be found on their register at: https://ico.org.uk/esdwebpages/search
The information that we use in order to provide our services is obtained directly from you as well as details obtained from Credit Reference and Fraud Prevention Agencies.
WOL collects your personal data in order to manage your investments into the individual loans for which you choose to fund. This will enable us to contact you directly to offer investment opportunities, manage your current investments and provide investment returns to you.
We, as a regulated business, must also assess your ability to invest in the funds. As AIFs are considered high risk financial products, those that WOL manages are not open to investment by retail clients. The investor must be able to demonstrate a degree of experience in the financial services market. WOL will therefore request that you provide us details of your past experiences in managing investments or lending to enable us to ensure you can be classified as an Elective Professional under regulatory definitions. We collect this information purely for internal use and will not share this for any purpose.
To meet the above we may need to see all or a selection of the following information:
The list of data items we may ask you for in order to provide finance is not exhaustive and will depend on your personal financial situation. you should be aware that the company may ask additional details in order to enable us to fully assess your circumstances. ny additional information will always be pertinent to your financial situation. Information that will never ask for are details on:
The primary reason that we collect your data is to enable us to manage your investments made through WOL as set out in your Participation Agreement with the firm. This includes the offering of investment opportunities in loans underwritten by WOL and the management of your investment returns in those loans which you have chosen to participate in.
All personal data that you submit will be stored to our company databases and will only be used in the provision of this particular product. We do not pass any of your information to any other external third parties for any form of marketing purposes. If this changes at any time in the future you will receive a written request from this firm to provide your explicit consent.
WOL will share your personal data within our group of companies purely for statistical purposes and for the management of investments. These firms are also subject to the requirements of data protection regulation and legislation and will not pass these details outside of this organisation without gaining your written consent.
We will also share certain of your personal and financial details with the FCA for their use in its supervision of the firm and its oversight of the financial services market. This requirement to provide personal and investment data to the FCA is a requirement under legislation.
As part of the application process, and in our legitimate interest to prevent financial crime, WOL will use your personal data to ensure against fraud and money laundering. In order to do this we will submit your data to specific fraud and money laundering prevention agencies. Details of which agencies we use can be obtained from our Data Protection Officer at the above address.
We and the particular agencies may also enable law enforcement agencies, where there is a statutory requirement, to access and use your personal data to detect, investigate and prevent crime.
If we, or one of the mentioned agencies, determine that you pose a fraud or money laundering risk, we, and others, may refuse to provide the services and investments you have requested or may request.
A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing, or employment to you. If you have any questions about this, please contact us on the details provided.
These agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.
As well as the provision of your data to the above mentioned external agencies, WOL will also submit your data to a Credit Reference Agency (CRA) as part of the application process for the assessment of your ability to invest in loan opportunities to understand your financial circumstances.
You should note that when we perform a search on your credit file a “soft search” is recorded. This is only viewable to you and will not be seen by any other financial institutions when accessing your credit file.
The identities of the CRAs, and the ways in which they use and share personal information, are explained in more detail on West One’s website under the Credit Reference Agency Information Notice (CRAIN) link.
WOL will store your personal data only for as long as it is necessary for us to maintain the relationship that has been established through your participation in investing in loan opportunities with the firm.
The length of time for which we hold your data is dependent on the length of the relationship you maintain with WOL and our regulatory responsibilities. In general, we will retain your data for the duration of your investing in loans and for a period of 6 years after that coming to an end.
Your personal data is protected by legal rights which includes your rights to:
Where you request WOL to cease processing your data prior to the assessment of your application to invest through WOL, this will affect our ability to provide you with investment opportunities.
The right to your objection to our processing, or request erasure , of your data is subject to our regulatory and legislative responsibilities as well as to the correct maintenance of any contract that we may enter into for the provision of investment opportunities. This means that we have a legal necessity to retain your data while you have investments underway with the company in order that we correctly manage the contract set out at the signing of your Participation Agreement. We also must retain your data for a period of 6 years after the completion of any investments with the business to meet our regulatory obligations.
Where we have made an error on your data and you wish to submit a correction please contact us via the above methods.
The above contact details should also be used to request copy of all personal data we hold on you. We will endeavour to provide all data that we hold as soon as possible upon receipt of your request and will take no longer than 30 days to do so.
You also have a right to complain to the Information Commissioner’s Office (ICO) which regulates the processing of personal data. WOL’s registration number with the ICO is Z2651210. The ICO can be contacted via the following methods:
Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF
Telephone: 0303 123 1113