Updated and effective as of 1st December 2022
This privacy policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you ("personal information") when you use our lending infrastructure platform (“Platform”), our website at www.kennek.io (or variations thereof), or our app, access our services or otherwise interact with us.
The Platform is used by:
each a “Platform User”.
The Platform is for Platform Users who are legal entities or individuals acting for purposes relating to their trade, business, craft or profession only. This Privacy Notice is for:
It is important that you read this Privacy Notice so that you are fully aware of how and why we are using your data.
The Platform is owned and operated by nuviu Products Ltd, a company registered in England and Wales with registered company number 14034172 and registered office address at The Phoenix Brewery, 13 Bramley Road, London, W10 6SZ, United Kingdom (“nuviu”).
Nuviu is registered as a data controller with the Information Commissioner’s Office under data protection registration number ZB260433.
If you have any questions about our Privacy Notice or your information, or wish to exercise any of your rights as described in this Privacy Notice or under data protection laws, you can contact us:
By post at:
The Phoenix Brewery, 13 Bramley Road, London, W10 6SZ, United Kingdom, Attn: The Data Protection Manager
By email at: hello@nuviu-browser.com
This privacy notice applies to our activities where we act as a controller (i.e. decision-maker) of your personal data and where we are directly responsible to you in respect of our handling of your data. We have set out below in the PERSONAL INFORMATION WE COLLECT ABOUT YOU AND HOW WE USE IT section, details of the types of your personal data we collect as a controller and the purposes for which we use it as controller.
Please note that in respect of some of our activities in relation to the Platform, we use (or process) your personal information on behalf of another business. In these circumstances, we are not controller but are processor instead. This can be the case when:
Where we are acting as a processor, we process your personal data on behalf of and in accordance with the instructions of the relevant controller. We are not responsible for the controller’s policies and practices surrounding data privacy and security. We encourage you to refer to the controller’s privacy policy.
We:
(a) collect personal information that you voluntarily submit to us, such as your name, job title and business contact details, when completing forms on the Platform or our other online services, using the Platform and our services, or otherwise interact with us in the course of our business activities;
(b) collect personal information about you from third parties such as Credit Checking Agencies (as defined below), customer due diligence providers, social networks, public databases (where permitted by law), our advertising partners, and our other business partners where we carry out joint business activities;
(c) if you are a borrower or investor, we obtain your business contact details and other personal information about you from a lender who has made a loan to you, or whose loans you have funded;
(d) also collect certain personal information automatically, including in relation to how you access and use the Platform or our other online services, technical information regarding the device you use to access the Platform or our other online services and the way in which you interact with our email messages (such as whether you open these);
(e) collect information about individual directors and beneficial owners of our lender clients, and people with a controlling interest in them, such as their name, date of birth, home address, contact details, copy of passport, identity card, driving licence, or residence permit, bank statement, mortgage statement or utility bill, or other proof of home address for the purpose of carrying out our customer due diligence checks (which could include credit checks, identity checks, sanctions screening, and anti-money laundering checks); this information may be provided directly by the individual concerned, by someone else at their organisation, by a broker, lawyer or accountant acting for the individual or their organisation, or by one of the third parties referred to at (b) or (c) above; and
(f) may link or combine the personal information we collect about you and the information we collect automatically. This allows us to provide you with a personalised experience regardless of how you interact with us.
We will indicate to you where the provision of certain personal information is required in order for us to provide certain services to the Platform User that you represent. If you choose not to provide such personal information, we may not be able to provide the services.
We may anonymise and aggregate any of the personal information we collect about you (so that it does not directly identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving our Platform and other services, and developing new products and features. We may also share such anonymised information with others.
We will only use your personal information if we have a legal basis for doing so. The purposes for which we use and process your information and the legal basis on which we carry out each type of processing is explained below:
Lawful basis: It is in our and your legitimate interests to ensure lenders, borrowers and investors are provided with the services they have requested from us and we have contractually agreed to provide and that we continually improve these. It is in our legitimate interests to communicate with you regarding billing to ensure we are paid for our services.
Lawful basis: It is in our legitimate interests to ensure that the Platform and other services function properly and to resolve issues with them where required, and to ensure that the Platform and our other online services are secure and operate in accordance with applicable law and regulation. It is in our legitimate interests to ensure that any changes to our policies, terms and other such technical updates are communicated to you so that you are aware of these.
Lawful basis: it is in our legitimate interests to verify the identity of and assess the suitability of platform users to receive services from us and to protect us against the risk of a lender failing to pay us; compliance with laws.
Lawful basis: Compliance with a legal obligation. It is also in our legitimate interests to verify the identity of and assess the suitability of a lender that may receive our services to prevent criminal activity and to protect us against the risk of a lender failing to pay us.
Lawful basis: It is in our legitimate interests to ensure that the Platform, our website, app and other services function properly and to resolve issues with them where required.
Lawful basis: Your consent.
Lawful basis: It is in our legitimate interests to anonymise the personal data we collect in the course of providing our services in order that we can carry out research, prepare reports and promote our services.
Lawful basis: Your consent (if required under applicable law). Where consent is not required, such processing is necessary in our legitimate interests to grow and develop our business, and to provide the Platform to lenders, borrowers and investors.
We use a variety of methods to try to make sure that we do not provide our services to lender clients who are in financial difficulty or are otherwise unsuitable to use our services. One of these is to carry out credit reference checks. In order to do this, we share with and receive personal information about individual directors and beneficial owners of our lender clients, and people with a controlling interest in them, from, certain credit reference agencies and other third parties who collect, consolidate, and provide us with such personal information.
Such credit reference agencies and third parties are: None Used at Present
(together, the “Credit Checking Agencies”)
These Credit Checking Agencies provide us with data about the relevant individual’s credit history and borrowing habits.
You can contact these Credit Checking Agencies in writing (using the details above) to request the information that they hold about you.
We may share your personal information with third party vendors and other service providers that perform services for us or on our behalf as required to achieve the purposes described above, which may include providing web hosting or analytics services and may also include the Credit Checking Agencies and customer due diligence service providers.
If you are a borrower, we will also share your personal information with our lender client from which you have applied for or taken a loan and we may also pass the information on to the investor or funder of the loan.
As detailed above, we may share your data with our service providers and some of these may be based outside of the United Kingdom (“UK”) and European Economic Area (“EEA”). This may involve transferring your personal data internationally outside the UK and the EEA.
Where personal information is transferred to and stored in a country not determined by the UK or European Commission as providing adequate levels of protection for personal information, we take steps to provide appropriate safeguards to protect your personal information, including entering into standard contractual clauses approved by the UK or the European Commission, obliging recipients to protect your personal information.
If you would like further information on the specific mechanism used by us when transferring your personal information outside of the UK or the EEA, please contact us using the details set out in the Contact Us section above.
We use appropriate technical and organisational security measures (including encryption) to protect personal information from unauthorised use, loss, alteration or destruction. Where data processing is carried out on our behalf by a third party, we take steps to ensure that appropriate security measures are in place to prevent unauthorised disclosure of personal information.
Despite these precautions, however, we cannot guarantee the security of information transmitted over the Internet or that unauthorised persons will not obtain access to personal information.
We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
Personal information that we process for the purpose of carrying out anti money laundering checks (and ancillary functions related to this) as part of our customer due diligence checks will be retained for 6 years from the end of our business relationship with the Platform User (or such longer period as may be required by legal and regulatory requirements).
In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:
Please note that not all of the above rights are absolute and we may be entitled to refuse requests, wholly or partly, where exceptions under the applicable law apply.
You can exercise any of your rights as described in this Privacy Notice and under data protection laws by contacting us as provided in the Contact Us section above.
We use cookies and similar technologies on the Platform and our website for various purposes, including improving your experience of them. For more information about cookies and why we use these, please refer to our Cookies Policy.
If you have any questions or concerns regarding our Privacy Notice or practices, please contact us as provided in the Contacting Us section above. You also have the right to complain to the UK Information Commissioner’s Office (https://ico.org.uk/). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
We reserve the right to change this Privacy Notice from time to time. Any changes will be posted on the Platform and our website with an updated revision date. If we make any material changes to this Privacy Notice, we may notify you by email or by means of a prominent notice on the Platform and our website prior to the change becoming effective.
