Privacy notice — So You Grow Capital

1. Who we are

So You Grow Capital Inc (“we”, “us”) is the controller of your personal information. We are a company incorporated in the British Virgin Islands, company number 2147342, registered on the UK Register of Overseas Entities under ID OE033788.

Registered office: OMC Chambers, Wickhams Cay 1, Road Town, Tortola, British Virgin Islands VG1110
Correspondence address: 15 Granville Road, Hayes, Middlesex UB3 4PL, United Kingdom
For any privacy question, or to exercise your rights: write to us at the correspondence address above, or email info@soyougrowcapital.com.

We lend for business purposes only. Most people we deal with are companies, but where an individual borrows for a property business, or acts as a director, shareholder or guarantor, this notice covers their personal information too.

2. The information we collect

When you make an enquiry, through the form on this website, we collect:

details of the borrower and the borrowing (company or individual, whether the property is let, whether it is held on trust, whether it is for a property business);
details of the proposed loan and security (the property address, its value, the amount, term and exit strategy);
where the borrower is a company, its name and registration number, and information about its directors, shareholders and structure;
your contact details (name, telephone number and email address).

If your enquiry proceeds towards a loan, we and our advisers will also collect and generate:

identity and verification information about borrowers, directors, shareholders, beneficial owners and any guarantors;
information from credit reference and fraud-prevention agencies about individuals connected to the borrowing;
information about the security property from HM Land Registry and property-data sources;
information about the borrowing company from Companies House;
correspondence and records of our dealings with you.

We do not ask for special category data (such as health or ethnicity). Please do not send it to us. We do not knowingly collect information about anyone under 18.

3. Where we get it from

Most information comes from you, or from a broker or professional acting for you. We also obtain information from:

Companies House — when you use the company-name lookup on the form, and when we verify a borrowing company;
HM Land Registry and property-data providers — about the security property;
credit reference and fraud-prevention agencies — about individuals connected to a loan that is proceeding;
publicly available sources and sanctions and politically-exposed-person screening providers — as part of our checks.

4. Why we use it, and our lawful basis

What we do	Our lawful basis under UK GDPR
Assess your enquiry and respond to it; take steps at your request before entering a loan	Performance of, or steps prior to, a contract; and our legitimate interest in assessing and responding to enquiries
Verify identity and carry out anti-money-laundering and sanctions checks	Compliance with a legal obligation where one applies to us; otherwise our legitimate interest in preventing fraud and financial crime
Assess credit risk and the security, and make a lending decision	Steps prior to a contract, and our legitimate interest in lending responsibly
Administer a loan, and enforce it if necessary	Performance of a contract, and our legitimate interest in recovering sums owed
Keep records for tax, accounting and legal purposes	Compliance with legal obligations, and our legitimate interest in keeping proper records

Where we rely on legitimate interests, we have considered your interests and rights and believe our use is proportionate. You can ask us for more detail, and you can object — see section 9.

5. Who we share it with

We share personal information only where we need to. Recipients include:

our form provider, Web3Forms, which receives an enquiry when you submit the form and passes it to us by email;
credit reference, fraud-prevention, identity-verification and sanctions-screening agencies;
valuers, solicitors and other professional advisers acting on a transaction;
our own professional advisers (for example accountants and lawyers);
regulators, law-enforcement and government bodies where we are required or permitted to disclose.

We do not sell your information, and we do not use it for advertising.

6. Sending information outside the UK

Some of the organisations we use are based outside the United Kingdom, and we ourselves are incorporated in the British Virgin Islands. This means your information may be transferred to, stored in, or accessed from countries outside the UK — including, when you submit the form, the United States (where our form provider operates).

Where we make such a transfer, we take steps intended to ensure your information receives a level of protection consistent with UK data protection law, using the safeguards that law recognises (such as an International Data Transfer Agreement). You can ask us for more detail about the safeguards that apply.

7. Automated decisions

The eligibility questions at the start of the form are checked automatically, and will tell you if we cannot lend on the basis you describe. That check does not, by itself, decide whether we will lend to you. Lending decisions are made by a person. We do not make decisions that produce legal or similarly significant effects about you based solely on automated processing.

8. How long we keep it

If your enquiry does not lead to a loan, we keep the information for up to 12 months and then delete it, unless we need it longer to deal with a query or a legal matter. If you take a loan, we keep the information for the life of the loan and for six years after our relationship ends, to meet our legal, tax, accounting and record-keeping obligations. We may keep some information longer where the law requires it.

9. Your rights

Under UK data protection law you have the right to:

ask for a copy of the information we hold about you;
ask us to correct information that is wrong or incomplete;
ask us to delete information, or to restrict how we use it, in certain circumstances;
object to our using your information where we rely on legitimate interests;
ask us to transfer certain information to you or another provider;
where we rely on your consent, withdraw it at any time.

To exercise any of these, contact us using the details in section 1. These rights are not absolute, and we will explain if an exception applies. We will not charge you, and we aim to respond within one month.

10. Cookies and this website

By default this website sets no cookies of its own and uses no analytics, advertising or tracking. We never set non-essential cookies without your consent.

If we run online advertising (for example Google Ads), we ask for your agreement through a banner before any advertising or measurement cookies are set. You can accept or reject: if you reject, none are set and the advertising service is not loaded at all. We keep a record of your choice on your device so we do not have to ask on every visit — that single record is strictly necessary to honour your decision, and it is the only thing stored if you reject. Where advertising is switched on, the provider (Google) acts as a recipient of the resulting data; see sections 5 and 6 on sharing and international transfers.

A few other things happen when you use the site that are worth knowing:

the page loads fonts from Google Fonts, which means Google receives your device’s IP address;
when you use the company-name lookup, your search is sent to Companies House;
when you use the address lookup, your search is sent to our address-data provider;
when you submit the form, its contents are sent to our form provider (section 5).

11. Complaints

If you are unhappy with how we have handled your information, please tell us first, using the details in section 1, so we can try to put it right. You also have the right to complain to the UK’s data protection regulator, the Information Commissioner’s Office, at ico.org.uk or on 0303 123 1113.

12. Changes to this notice

We may update this notice from time to time. The date at the top shows when it was last changed. If we make a significant change, we will make that clear on this page.

How we handle your information.