Privacy Policy

1. Who We Are

The data controller for this website is:

Palisade Finance Ltd
167-169 Great Portland Street
London, England
W1W 5PF

Company number: 17108580.

2. Personal Data we Collect

We may collect and process the following categories of personal data:

Information you provide to us

• your name;
• business email address;
• telephone number;
• company name;
• job title; and
• the contents of any message, enquiry or other information you choose to send us.

Technical and usage information

• IP address;
• browser type and version;
• device and operating system information;
• referring website or source;
• pages viewed and time spent on the website; and
• cookie and similar technology data.

Business contact information from other sources

In some cases, we may obtain limited business contact information from publicly available sources or from third parties where this is relevant to a genuine business enquiry or relationship.

3. How We Use Personal Data

We use personal data to:

• operate, maintain and secure the website;
• respond to enquiries and communicate with you;
• arrange meetings, calls or demonstrations;
• assess and manage prospective business relationships;
• maintain internal records;
• analyse and improve the website and its performance;
• comply with legal and regulatory obligations; and
• establish, exercise or defend legal claims

We may also use aggregated or anonymised information for analytics, service development and operational monitoring. Where information has been irreversibly anonymised, it is no longer personal data.

4. Lawful bases for processing

We process personal data on one or more of the following bases, depending on the circumstances:

• legitimate interests, including operating and securing our website, responding to business enquiries, managing communications and developing our business;
• steps at your request prior to entering into a contract, where you contact us about potential services or a possible commercial relationship;
• compliance with a legal obligation, where processing is necessary to meet legal or regulatory requirements; and
• consent, where consent is required, including for non-essential cookies and any communications for which consent is the appropriate basis.

We process personal data lawfully, fairly and transparently, and we identify the lawful basis or bases that apply to each processing purpose. The ICO also states that your privacy information must include your lawful basis, and that the rights available to individuals can differ depending on that basis.

5. Cookies and similar technologies

We use cookies and similar technologies on the website. Some are strictly necessary for the operation of the website. Others, such as analytics cookies, are used only where required permissions have been obtained.

Further details are set out in our Cookies Policy.

6. Who we share personal data with

We may share personal data with:

• website hosting, IT, analytics and security providers;
• professional advisers, including lawyers, auditors and consultants;
• regulators, law enforcement agencies, courts or public authorities, where required or appropriate;
• service providers who support our operations; and
• prospective or actual counterparties, advisers, insurers or other professional participants where necessary in connection with a genuine business enquiry or relationship.

We require service providers acting on our behalf to handle personal data confidentially and in accordance with applicable data protection requirements.

7. International Transfers

We may process or store personal data outside the UK, including where our service providers use systems or personnel located in other countries.

Where we make a restricted transfer of personal data outside the UK, we will do so in accordance with applicable data protection law and will use a lawful transfer mechanism. Where required, this may include adequacy regulations or appropriate safeguards, such as the UK International Data Transfer Agreement or the UK Addendum, together with any required transfer risk assessment. If no lawful transfer mechanism applies, we will not make the transfer. The ICO states that organisations should explain international transfers in their privacy information and, where relevant, identify adequacy or the safeguards used.

8. Data Retention

We keep personal data only for as long as necessary for the purposes for which it was collected, including to meet legal, regulatory, tax, accounting or reporting requirements.

In deciding how long to retain personal data, we take into account the nature of the data, the purpose for which it was collected, the sensitivity of the data, legal and regulatory requirements, and whether we need the information to resolve disputes or enforce our rights.

If an enquiry does not progress, we will normally retain related correspondence only for as long as reasonably necessary for follow-up, record-keeping and protection of our business interests. If a relationship progresses, relevant information may be retained for longer in line with our internal retention practices and applicable legal or regulatory requirements.

The ICO says a privacy policy should state retention periods or, if a fixed period is not possible, the criteria used to decide how long information is kept.

9. Your rights

Subject to applicable law, you may have the right to:

• request access to your personal data;
• request correction of inaccurate or incomplete personal data;
• request erasure of your personal data;
• request restriction of processing;
• object to processing carried out on the basis of legitimate interests;
• request portability of personal data you have provided to us, where applicable;
• withdraw consent at any time, where processing is based on consent; and
• lodge a complaint with the Information Commissioner’s Office.

The ICO requires privacy information to explain the rights available to individuals, to tell people when they can withdraw consent, and to tell them they can complain to a supervisory authority.

10. Security

We use appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or unauthorised access.

11. Third Party Links

Our website may contain links to third-party websites or services. If you follow a link to any third-party site, that site will have its own privacy practices and notices. We are not responsible for the privacy practices, content or security of third-party sites.

12. Information you should not send through the website

Please do not send confidential portfolio data, loan-level data, special category personal data, criminal offence data, or other sensitive information through general website forms or ordinary email unless we have asked you to do so and an appropriate secure method of transfer has been agreed.

If you provide personal data about another person, you must ensure that you are entitled to provide it to us.

13. Automated decision-making

We do not use personal data collected through this website to make decisions based solely on automated processing that produce legal effects or similarly significant effects on individuals.

14. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page and will take effect when published.