Privacy Policy

This Privacy Policy (“Policy”) explains how Luxfin Capital Ltd with registration number 10285479 and registered address 124 City Road, London, England, EC1V 2NX, United Kingdom and its head office address is 33 St. James's Square, London, SW1Y 4JS collect, use, and process your personal data when you use our website https://luxfincapital.co.uk/ (“Website”), visit our office or receive calls, correspondence by post or email messages from us (jointly called “Services”). 

When interacting with Luxfin Capital Ltd, for the purposes of this Privacy Policy, Luxfin Capital Ltd is the data controller and is registered with the UK Data Protection Authority: Information Commissioner's Officer (ICO), Registration reference: ZB582760.

Luxfin Capital Ltd will value your privacy and strive to protect your personal information. The term “personal information” refers to any information from which your identity could be reasonably ascertained. In this Privacy Policy, personal information is also known as ‘personal data’ for data subjects in the United Kingdom (UK). We will only collect and use your personal information in accordance with this Privacy Policy and the terms of your agreement with Luxfin Capital Ltd (Terms of Services). For further information contact privacy@luxfincapital.co.uk.  

By visiting, accessing, or using Luxfin Capital Ltd, you have confirmed that you are 18 years old or older, have the legal capacity to consent to this Privacy Policy, and agree to be bound by this Privacy Policy. 

The personal information we collect 

The personal information we collect enables us to deal with your enquiries, open and operate an account for you, or generally provide you with our products and services and comply with laws and regulations. We may need to and may be required to record, hold, use, disclose and store the following information: 

· Personal information used to establish your identity and background. 

· Personal information provided when you use the Luxfin Capital Ltd 

How we collect your personal information 

Luxfin Capital Ltd obtains personal information in various ways: 

· When you register an interest in Luxfin Capital Ltd services via email or phone with Luxfin Capital Ltd representatives 

· When you register an interest for an account with Luxfin Capital Ltd through the website.

· When you respond to marketing initiatives from Luxfin Capital Ltd or its independent marketing partners. 

· Through the information provided by you when using our products or services. 

· We analyse information based on your transactions. Luxfin Capital Ltd also analyses the payments which are made to/from your account. 

· We monitor calls, emails and letters when you call our help desk or send queries. 

· We may collect data and information from third parties like credit reference agencies, regulatory and enforcement agencies or from other sources for which you have given consent to disclose information relating to you and/or where information is not otherwise restricted. 

How we use your personal information 

Personal information is used for the following purposes: 

· To verify your account in accordance with Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations. 

· To assess your application for our services. 

· To manage and maintain our business and your relationship with us and execute transactions.

· To update, consolidate and improve the accuracy of our records. 

· To conduct anti-money laundering checks, for crime detection, fraud prevention and prosecution. 

· For any other purpose that is required or permitted by any law, or relevant regulatory authorities. 

· To respond to your enquiries and complaints and to generally resolve disputes. To administer offers, competitions and promotions. 

· To improve or develop new products and services, and to notify you.

· To produce data, reports, and statistics, which have been anonymous or aggregated in a 

manner that does not identify you as an individual. 

· To conduct research for analytical purposes including but not limited to data mining and 

analysis of your transactions with us. 

· To meet the disclosure requirements of any law binding on Luxfin Capital Ltd. 

· For audit, compliance, and risk management purposes. 

· To assess financial and insurance risks. 

· To enable your referrer to understand your information. 

· Please be assured that we will ask for your consent before using your personal information for purposes other than those set out in this Privacy Policy and the Terms of Services. 

Automated processing of your personal information 

In some situations, we may use your personal information to help us make automated decisions to further improve our business or provide you with marketing that we think is relevant to you. For example, we might segment you based on elements of your profile (age, location, gender, transaction history), your answers to our surveys or your behaviour on our site and personalise our correspondence to you. 

You have the right to request information or object to a decision at any time. Unless a specific legal process prevents us from doing so, we will share that information with you explaining our reasons whenever possible and review the decision manually, if necessary.

Disclosure of your personal information 

To comply with legal and regulatory requirements we may be required to disclose information about you and/or your account details to the following third parties: 

· Banks, payment service providers and KYC partners 

· Organisations and companies that act as our agents, affiliates and/or professional advisors. 

· Organisations and companies that assist us in processing or otherwise fulfilling transactions 

that have been requested. 

· Law enforcement, regulatory and government agencies. 

· Affiliates who introduce you to Luxfin Capital Ltd may receive limited information about your account and Transactions. The aforementioned third parties may in some instances be located outside your registered country. Otherwise, we will treat your personal information as confidential and private and will not disclose your information to anyone outside Luxfin Capital Ltd. 

We may share your personal information in circumstances such as: 

· Where you have given permission. 

· Where we are required or permitted to do so by law. 

· Where required or authorised by any order of court or tribunal with jurisdiction over Luxfin Capital Ltd. 

· Where we may transfer rights and obligations pursuant to our agreement with you. 

· Where we are required to meet our obligations to any relevant regulatory authority. 

Transferring your information 

Luxfin Capital Ltd is registered and operates in the United Kingdom (UK), but as we provide an international money transfer service, we may sometimes need to transfer your data outside the UK and European Economic Area (EEA). When we send your payments to banks or payment providers around the world, we might also send your data along with them. We do this to follow global legal and regulatory requirements, and to provide ongoing support services. We may share your personal data with fraud prevention agencies across and outside the UK and EEA.  Accordingly, your personal data may be stored, transferred, and processed in countries outside of the country of your residence. 

We take the utmost care when we’re transferring your personal data, including ensuring that the third party receiving your personal information has proper safeguards for your information and will only process your personal information in the manner in which we stipulate. 

The secure storage of your personal information

Luxfin Capital Ltd places the greatest importance on providing strict security measures to protect your personal information. Luxfin Capital Ltd will review and implement up-to-date technical and organisational security measures when processing your personal information. All payment transactions carried out by us or our payment-processing providers are encrypted.

Employees of Luxfin Capital Ltd are trained to handle your personal information securely and with the utmost respect, failing which they may be subject to disciplinary action. 

The retention of your personal information Luxfin Capital Ltd will retain information in compliance with this Privacy Policy and the Terms of Services of your agreement with Luxfin Capital Ltd for the duration of your relationship with us, and afterwards for such period as may be necessary to protect the interests of Luxfin Capital Ltd and its customers, and as required by Luxfin Capital Ltd’s relevant policies, and as required by the law. 

How you can access and update your personal information 

You have a right to access your personal information. Please contact Luxfin Capital Ltd customer support to do this. Luxfin Capital Ltd will take steps to verify your identity before fulfilling the request. 

In the case of changes to your customer data or where it has not been updated, you will need to contact Luxfin Capital Ltd support to update your personal information. Luxfin Capital Ltd may use its discretion in allowing the corrections requested and/or may require further documentary evidence of the new information to avoid fraud and inaccuracy. 

Special provisions related to United Kingdom (UK) data subjects 

The UK General Data Protection Regulation (UK GDPR) sits alongside an amended version of the Data Protection Act 2018 (DPA 2018) and offers data subjects from the UK additional rights when it comes to their personal data. This next section outlines these additional rights, but please note, that this additional section for UK data subjects must still be read in conjunction with this Privacy Policy. 

Our relationship with you 

Luxfin Capital Ltd is a data controller for corporate finance transactions on the Luxfin Capital Ltd. As data controllers, we determine the purposes and means of processing personal data with respect to assets and account funding transactions. 

The legal basis for processing your personal data 

We process your personal data on the basis of consent, which you grant to us when you sign up for our service or access the website. We also process your personal data to perform our contractual obligations under the Terms of Services. Where we aggregate your personal data to improve our service, we’re doing so because of a legitimate interest in providing a better experience for you. 

Recipients or third-party processors of your personal data 

We use a number of third parties to provide the best possible service to you. This includes: 

Website browsers, like Google etc., which we use for analytics, remarketing and website tracking.

External KYC and screening provider, the company that verifies your identity, and screens against publicly available information; lets you register and use the services of Luxfin Capital Ltd. 

External customer communications, support and sales platforms.

Personalised and automated transaction email providers, for example, when one of your transactions is confirmed on the Luxfin Capital Ltd. 

External White-label software providers to register and access our services.

Financial institutions and payment service providers as part of the transaction processing chain.

A full list of the third-party processors is available upon request at any time by contacting us using the details at the bottom of this Privacy Policy.

Restricting, objecting or withdrawing your consent to the processing of your personal data 

You may withdraw your consent for us to process your personal data at any time. You may also request that we restrict the way we process your personal data. You can do this by contacting us using the details at the bottom of this Privacy Policy. 

How long we keep your personal data

We will store your personal data for as long as you have a relationship with us, or for as long as we are required to by law (up to 5 years after the relationship ends), or to comply with audit and financial obligations. 

Your rights under the UK GDPR 

You have a number of rights under the UK GDPR. These include the right to: 

· request access to your personal data from us; 

· request that we rectify your personal data; 

· withdraw your consent for us to use your personal data; 

· be forgotten by requesting that we delete the personal data that we hold for you; 

· object to the use of your personal data by us and request that we restrict our use of your personal data; 

· receive your personal data that we hold according to the Data Protection Act 2018 ‘Subject Access Request’, in a commonly used electronic or document format;

· give permission to us to transfer personal data to another service provider of your choosing; 

· lodge a complaint in relation to our processing of your personal data with a data protection supervisory authority under the UK GDPR; and 

· learn about and understand how we collect and use your personal data, including how we may need to process your personal data in ways other than those described in this Privacy Policy. 

Changes to this Privacy Policy 

This privacy policy may be revised from time to time. If there are any material changes, Luxfin Capital Ltd will notify you by email, letter or by the posting of a notice on the website. 

Contacting us about your information or this Privacy Policy 

If you have any questions, complaints or requests in relation to this Privacy Policy or how Luxfin Capital Ltd handles your personal information, please contact our Data Protection Officer at privacy@luxfincapital.co.uk  and state “Data Protection” in the subject line.

If you feel that we have not addressed your questions or concerns adequately, or you believe that your data protection or privacy rights have been infringed, you can complain to the supervisory authority with responsibility for enforcing privacy laws: Information Commissioner’s Office (ICO) (www.ico.org.uk)

Last updated 6th October 2023