This policy sets out how Bluecastle Capital Limited complies with UK data protection law. The policy is published to our website to explain how we use personal data and linked from our email signatures.  It will also be included with documents sent to our clients.

Privacy Notice

How we use your personal data

We are Bluecastle Capital Ltd of units 11 & 12. 16 Porteus Place, SW4 0AS.  Our Data Protection Coordinator is Edward Williams who can be contacted at this address. We take our data protection responsibilities seriously.  This Notice explains how we use personal data. All the information we request is essential to assess and progress transactions with our clients.  Failure to provide accurate information or to make full disclosure of relevant facts could be fraudulent in relation to seeking funding.

Our first contact

We might have met face to face at an event or conference and exchanged business cards or you might have contacted us via our website.  From this contact we will have your name and contact details, job title and employer details, if any.  We will follow up these contacts by phone and email.  If you are no longer interested in hearing from us you can let us know by email or phone at any time.  This type of marketing activity is in our legitimate business interests to generate new business leads and your rights are safeguarded by marketing laws and the ability to stop our contact at any time.

Assessing the transaction

Before agreeing to provide our services to you we undertake checks to verify your identity and the suitability of the application you wish to make as steps preparatory to entering into a contract with you.  Checks include taking up references, a personal and business credit reference check as well as an evaluation of the deal for which you are seeking funding, and its financial model.  

What personal data do we collect?

We keep records of communications between us, copies of passports, driver’s licenses and utility bills to confirm identity where necessary and information required to assess the suitability of the proposed transaction.  For Borrowers this means financial information including details of personal guarantees, assets and liability documents (including accounts statements), credit information, bank statements; marriage and birth certificates, details of your project including architect drawings, CVs and financial details of contractors used by you on the project (where adverse information is found on contractors, we will also ask for information on directors).  We also would need details of any criminal convictions as these are pertinent to parties considering funding a property development, this information is supplied by you and we rely on your consent to its use.

For Investors we will also carry out “Know your customer” checks on identity and we hold name and contact details and information relating to current and former transactions. For representatives of Investors we will hold name and contact details and information relating to current and former transactions. For Lenders and their representatives, we will hold name and contact details and information related to current and former transactions.

Where do we obtain personal data? 

Most of the information we hold is supplied direct to us by you, when you approach us directly or via our website or from face to face or other communication.  Some financial data is obtained from publicly accessible sources such as Companies House, the Courts and credit reference agencies. The other source for company representatives is their employer.  

How long is personal data kept?

When we have a contract with you, we will retain the data until the transaction completes satisfactorily and for a period of six years after.  Some transactions may require refinancing and we have a legitimate interest in retaining data which would help us to arrange further finance as quickly as possible.  We also have a legal right to keep data relating to a contract for six years after termination of the contract.  If we wanted to keep the data for a longer period, we would ask your permission. Where we decide not to proceed with your application for our services, we keep a summary of your information as an archive.  This is deleted periodically.

Is the personal information shared with any third parties?

We share your personal information with other parties in the transaction, Borrowers, Investors and Lenders.  We also use third party contractors to support our services, for example contractors who provide us with financial analysis professional services.  To carry out a credit reference check we share your name and address to identify you. 

Is the data transferred outside the EU/EEA

We transfer your personal data to the Ukraine to be processed by third parties who provide us with professional services relating to financial analysis and transaction processing.  We rely on standard contract clauses approved by the EU to legitimise this transfer. We undertake regular training of our contractors to ensure that they are fully aware of their obligations to you under UK data protection legislation.

Your data protection rights

You have the right to ask for a copy of the personal data we hold that relates to you as an individual.  If you think that information about you which we hold is incorrect or misleading you have the right to have the information corrected provided you can demonstrate that it is incorrect.  You can also request the erasure of personal data relating to you in certain circumstances, where we do not require it to meet a legal obligation.  You can also request or restriction of processing so that your records are maintained beyond our usual retention period.  You have the right to object to processing on the grounds that it causes you damage or distress and the right to take away a copy of your personal data in electronic format in certain circumstances.

If you are unhappy about the way we use your personal data or the way in which we respond to your request to exercise your data protection rights, you can contact the Data Protection Officer at Bluecastle Capital Ltd of 11 & 12, 16 Porteus Place, SW4 0AS but you also have the right to lodge a complaint with a supervisory authority, the Information Commissioner at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.