Blencathra Finance Ltd is registered in England and Wales under company registration number 11202918 and has its registered office at 21-27 Lambs Conduit Street, London, England, WC1N 3GS.

FCA non-regulated status

Blencathra Finance Ltd and its trading subsidiaries are not regulated by the FCA. Any connections to sources of capital are executed on an “introduction only” basis. Blencathra Finance is not involved in “arranging finance” as defined by the FCA and the company’s clients must form their own view of the appropriateness of any transaction and where necessary seek advice from regulated finance, tax, legal and accounting experts. Blencathra Finance cannot be held responsible for any consequential loss, damage or risk associated with any transaction where it may have provided the initial funding preparation services or the introduction to capital.

Terms of Use

The term Blencathra Finance or Blencathra refers to the owner of the website. The term ‘you’ refers to the user or viewer of our website.

If you continue to browse and use this website, you are agreeing to comply with and be bound by the following terms and conditions of use, which together with Blencathra Finance’s privacy policy govern Blencathra Finance’s relationship with you in relation to this website. If you disagree with any part of these terms and conditions, please do not use Blencathra Finance’s website.

The use of this website is subject to the following terms of use:

• The content of the pages of this website is for your general information and use only. It is subject to change without notice.
• Neither Blencathra Finance nor any third parties provide any warranty or guarantee as to the accuracy, timeliness, performance, completeness or suitability of the information and materials found or offered on this website for any particular purpose. You acknowledge that such information and materials may contain inaccuracies or errors and we expressly exclude liability for any such inaccuracies or errors to the fullest extent permitted by law.
• Your use of any information or materials on this website is entirely at your own risk, for which Blencathra Finance shall not be liable. It shall be your own responsibility to ensure that any products, services or information available through this website meet your specific requirements.
• This website contains material which is owned by or licensed to Blencathra Finance. This material includes, but is not limited to, the design, layout, look, appearance and graphics. Reproduction is prohibited other than in accordance with the copyright notice, which forms part of these terms and conditions.
• All trademarks reproduced in this website, which are not the property of, or licensed to the operator, are acknowledged on the website.
• Unauthorised use of this website may give rise to a claim for damages and/or be a criminal offence.
• From time to time, this website may also include links to other websites. These links are provided for your convenience to provide further information. They do not signify that we endorse the website(s). Blencathra Finance has no responsibility for the content of the linked website(s).
• Your use of this website and any dispute arising out of such use of the website is subject to the laws of England, Northern Ireland, Scotland and Wales.

Privacy and Disclosure

This privacy policy sets out how Blencathra Finance uses and protects any information that you give Blencathra Finance about you (Personal Information) when you use this website or when you communicate by other means with Blencathra Finance.

Blencathra Finance is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, you can be assured that it will only be used in accordance with this privacy statement.

Blencathra Finance may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 04 June 2017.

What Information We May Collect

• Name and job title
• Contact information including email address
• Demographic information such as postcode, preferences and interests
• Other information relevant to customer surveys and/or offers

We aim to be transparent about why and how we process Personal Information. For further information on our processing activities please review the “Business Contacts” and “Collection” sections below:

We process Personal Information about contacts using a client relationship management tool. Personal Information is collected and added to our CRM by a Blencathra Member of staff and includes; name, email address, job title, telephone number, area of business, job role, jurisdiction, language, seniority and other business contact information. The Personal Information may also be collected by virtue of us providing our services to you or at a networking event. In addition, Personal Information may also be collected via the Blencathra Finance website, http://www.blencathrafinance.com.

Use

• For contact and communication purposes: we may use your contact information to send you updates that we may circulate from time to time, news about any events we are organising or participating in, and/or other information about us and the services that we provide that we believe may be of interest to you. You can specify your contact preferences when registering online to receive communications from us (for example, through the Blencathra website, http://www.blencathrafinance.com) or by subsequently advising us of your contact preferences using options provided on all of our marketing emails or the contact details as set out in the “Data Controller contact information” section below.
• Making contact details available to Blencathra Finance staff.
• Performing analytics – such as trends, sales intelligence, marketing effectiveness (such as click and open rates) uptake and progress.

Retention
Personal Information is retained on our CRM for as long as it is necessary for the purposes set out above (being the length of the business relationship). If a business contact requests to be forgotten, their contact details will be deleted from our database. If a business contact opts out of receiving marketing materials their details will still be retained (as we may still be in contact) but marketing materials will no longer be sent.

Clients and individuals associated with clients

Collection
We request that our clients only provide Personal Information which is necessary for us to carry out our services.

If we need Personal Information in respect of individuals associated with clients in order to provide our services, we ask our clients to provide this Policy to the data subjects.

In the majority of circumstances, we will collect Personal Information from our clients or from third parties acting on behalf of our clients.

Use

• • Providing our services: we will use and disclose Personal Information in such a manner as we believe is reasonably necessary to provide our services, to liaise with other professional service providers in relation to matters that we are handling.
  • Administration: to collect our fees or costs in connection with our services we will use Personal Information to agree payment arrangements and to collect our fees and costs owing to us.
  • Managing client relationships: providing clients with information on our services and updates that we consider may be relevant to them; arranging and hosting events; and identifying where we may make improvements in service delivery.
  • Client engagement: as part of our client onboarding process we carry out certain background searches to verify whether or not there are any potential issues that may mean we cannot work with a particular person (to identify criminal convictions, politically exposed persons, sanctions or other potential reputation issues).
  • Compliance with anti-money laundering regulation: we may use your Personal Information (e.g. evidence of your identity) in order to fulfil our obligations to check the identity of our clients in compliance with anti-money laundering law and regulations.

Retention
Our general retention period for documentation created for the purpose of providing our services is 12 years. In some instances, there are legal and regulatory exceptions which may require documentation to be held for longer or shorter periods. If you require further information, please contact us using the details as set out in the “Data Controller contact information” section below.

Suppliers (including individual contractors)

Collection
Personal Information, including name, email address, telephone number and other business contact information, is collected to receive services from suppliers, to manage the relationship with the supplier, and for the provision of services to our clients.

Use

• To receive services from our suppliers: please note that we will use and disclose their Personal Information in such manner as we believe is reasonably necessary to receive and to review the provision of those services from suppliers.
• Services to clients: if a supplier is assisting us in delivering services to our clients we will process Personal Information to manage that relationship.
• Administration: to agree payment arrangements with our suppliers, and to make payments to them.

Retention
A general retention period of 12 years will be applied unless there are any legal and or regulatory exceptions which may require documentation to be held for shorter or longer periods. If you require further information, please contact us using the details as set out in the “Data Controller contact information” section below.

Visitors to the Blencathra Finance website

Collection
Personal Information will be collected if you sign up to attend any of our events and/or to receive our marketing literature.

Use

• Business contacts: if you have signed up to attend one of our events or to receive our marketing literature please see the paragraph above headed ‘Business contacts’.

Your rights in relation to Personal Information and how to exercise them

Under certain circumstances you have the following rights:

• the right to ask us to provide you, or a third party, with copies of the Personal Information we hold about you at any time and to be informed of the contents and origin, verify its accuracy, or else request that such information be supplemented, updated or rectified according to the provisions of local law;
• the right to request erasure, anonymisation or blocking of your Personal Information that is processed in breach of the law;
• the right to object on legitimate grounds to the processing of your Personal Information. In certain circumstances we may not be able to stop using your Personal Information, if that is the case, we’ll let you know why; and
• withdrawal of consent – while we do not generally process Personal Information on the basis of consent when Personal Information is processed on the basis of consent an individual may withdraw consent at any time (this may apply to processing of special categories of Personal Information where you have instructed us to act on your behalf and includes the following: racial/ethnic origin, political opinions, religious or philosophical beliefs and trade union membership). In the event that you no longer want to receive any marketing material from us, please use the unsubscribe option (which is in all of our marketing emails to you), or contact the relevant member of staff as set out below.

To exercise such rights (bar withdrawing from marketing emails – as described above) and if you have any questions about how we collect, store and use Personal Information, then please contact us using the details as set out in the “Data Controller contact information” section below.

What basis do we have for processing your Personal Information?

We will only process Personal Information where we have a lawful reason for doing so. The lawful basis for processing Personal Information by us will be one of the following:

• the processing is necessary for the performance of a contract you are party to or in order to take steps at your request prior to you entering into a contract;
• the processing is necessary in order for us to comply with our legal obligations (such as compliance with anti-money laundering legislation);
• the processing is necessary for the pursuit of our legitimate business interests (including that of the delivery and the promotion of our services); and
• processing is necessary for the establishment, exercise or defence of legal claims.

Who else may have access to your Personal Information?

On occasion, we may need to share your Personal Information with third parties. We will only share Personal Information where we are legally permitted to do so.

Where you supply us with Personal Information as a client, we will assume, unless you instruct us otherwise in writing, that we can disclose your Personal Information in such manner as we believe is reasonably necessary to provide our services (including as described in this Policy), or as is required under applicable law. This might be because, for example, we may pass your Personal Information to third parties such as:

• credit-checking agencies for credit control reasons;
• events: we may need to pass on your Personal Information (e.g. name, company, occupation) to a third party in connection with management of an event, in which case the details will only be used by the third party for that specific purpose;
• business partners, service providers and other affiliated third parties: to enable us to provide our services to you, we may need to share your Personal Information with our business partners (including other professional advisers such as accountants or auditors), external service providers and/or overseas counsel. Our arrangements with external service providers currently cover the provision of support services including IT, AML/CDD checks, events management, document production, business and legal research, marketing and business development and facilities management.
• disclosures required by law or regulation: in certain circumstances, please note that we may be required to disclose Personal Information under applicable law or regulation, including to law enforcement agencies or in connection with proposed or actual legal proceedings.

How we look after your Personal Information

We have in place appropriate technical and organisational security measures to protect your Personal Information against unauthorised or unlawful use, and against accidental loss, damage or destruction.

We put in place strict confidentiality agreements (including data protection obligations) with any third-party service providers.

Security

Blencathra Finance is committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, Blencathra Finance has put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

How We Use Cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives Blencathra Finance access to your computer or any information about you, other than the data you choose to share with Blencathra Finance.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

Links To Other Websites

The Blencathra Finance website, http://www.blencathrafinance.com, may link to other, unaffiliated third-party websites. Please note that Blencathra Finance is not, and cannot, control or be responsible for the content or privacy and confidentiality practices of any third-party websites. You must always carefully review the privacy and confidentiality policy of any third- party website that you may visit in order to understand how the operators of that website may collect, store and use your Personal Information.

Data Controller Contact Information

If you believe that any information Blencathra Finance is holding on you is incorrect or incomplete, you would like to request the information we have on our database of you, or you wish to be removed from our database, please email us as soon as possible, at the below addresses.

Rona Campbell – rona.campbell@blencathrafinance.com

Website Disclaimer

The information contained in this website is for general information purposes only. The information is provided by Blencathra Finance and while we endeavour to keep the information up to date and correct, we make no representations or warranties of any kind, express or implied, about the completeness, accuracy, reliability, suitability or availability with respect to the website or the information, products, services, or related graphics contained on the website for any purpose. Any reliance you place on such information is therefore strictly at your own risk.

In no event will we be liable for any loss or damage including without limitation, indirect or consequential loss or damage, or any loss or damage whatsoever arising from loss of data or profits arising out of, or in connection with, the use of this website.

Every effort is made to keep the website up and running smoothly. However, Blencathra Finance takes no responsibility for, and will not be liable for, the website being temporarily unavailable due to technical issues beyond our control.

Complaints

While we hope that you will not need to, if you want to complain about our use of Personal Information please send an email detailing your complaint to the relevant Privacy Officer.

rona.campbell@blencathrafinance.com

Updates to this Policy

This Policy was last updated in May 2018. Please check back regularly to keep informed of updates to this Policy.

Copyright

Copyright 2018 Blencathra Finance Ltd. All rights reserved.

Any redistribution or reproduction of part or all of the contents in any form is prohibited other than the following:

• you may print or download to a local hard disk extracts for your personal and non-commercial use only
• you may copy the content to individual third parties for their personal use, but only if you acknowledge the website as the source of the material
• You may not, except with express written permission, distribute or commercially exploit the content. Nor may you transmit it or store it in any other website or other form of electronic retrieval system.