PRIVACY NOTICE
CLEAR ASSET FINANCE LTD AND CLEAR BUSINESS FINANCE LTD
Effective date: 1 September 2026
At a glance
This notice explains how the Clear group companies collect and use personal information when arranging, providing or administering business finance and related services. It also explains who we share information with, how long we keep it, and the rights available to individuals under UK data protection law.
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Who we are
The following companies are data controllers for the personal information described in this notice:
A data controller decides why and how personal information is used. In this notice, “Clear”, “we”, “us” and “our” refer to one or both of the companies above, depending on which company provides or arranges the relevant product or service.
- Clear Asset Finance Ltd, Suite 6, Ripon House, Station Lane, Hornchurch, RM12 6JL.
- Clear Business Finance Ltd, Suite 6, Ripon House, Station Lane, Hornchurch, RM12 6JL
This notice applies to customers, prospective customers, guarantors, directors, shareholders, beneficial owners, suppliers, introducers, business contacts and other individuals whose personal information we process in connection with our activities.
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The Information we collect
Depending on the circumstances, we may collect and use:
- Identity information, including name, previous names, date of birth, nationality, signature and copies of identity documents.
- Contact information, including current and previous addresses, email addresses and telephone numbers.
- Business and employment information, including role, employer, company ownership, directorships, trading history and professional background.
- Financial information, including income, assets, liabilities, bank details, payment history, financial statements and information relevant to affordability and creditworthiness.
- Credit and public-record information, including credit commitments, repayment history, county court judgments, insolvency information, electoral-roll information and search footprints.
- Financial Crime-related information, such as fraud-prevention, sanctions, politically exposed person and identity-verification information.
- Finance applications, including agreements, assets, suppliers, transactions and correspondence with us.
- Technical and online information, including internet protocol address, device and browser information, website usage information and cookie identifiers.
- Some information may be obtained from publicly available sources, including Companies House, insolvency records, websites, news sources and professional or social-media profiles where relevant and proportionate.
- Special-category or criminal-offence information only where necessary, lawful and relevant, for example where health information is volunteered in connection with vulnerability or forbearance.
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Where we obtain information
We may obtain personal information:
- Directly from you, including through applications, forms, telephone calls, emails, meetings and our website.
- From the business or individual on whose behalf you act, or from another applicant, director, shareholder, guarantor or authorised representative.
- From introducers, suppliers, lenders, funders, brokers, professional advisers and service providers.
- From credit reference agencies, fraud-prevention agencies, identity-verification providers, sanctions and politically exposed person screening services.
- From public registers and publicly available sources, including Companies House and The Gazette.
Where another person gives us information about you, they should make you aware of this notice. Where you provide information about another person, you should ensure that you are authorised to do so and that the information is accurate.
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Why we use personal information and our lawful bases
We use personal information only where we have a lawful basis. The principal purposes and lawful bases are set out below.
Purpose
Examples
Principal lawful basis
Provide and administer services
Assess credit applications; source or provide finance; manage agreements; process payments; communicate about accounts.
Contract; legitimate interests
Assess credit and risk
Creditworthiness, affordability, underwriting, guarantees, asset and supplier checks.
Legitimate interests; contract
Prevent financial crime
Identity verification; anti-money laundering; sanctions; fraud prevention; security.
Legal obligation; legitimate interests
Meet legal and regulatory duties
Respond to regulators, courts, law enforcement and tax or accounting requirements.
Legal obligation
Manage and fund our business
Portfolio funding, assignment of contract rights, security, audit, insurance, professional advice and business administration.
Legitimate interests; contract
Improve and protect services
Quality assurance, systems security, analytics, complaints, training and service improvement.
Legitimate interests
Marketing
Send relevant information about products and services, subject to applicable marketing rules and your right to object.
Legitimate interests or consent
Where we rely on legitimate interests, we consider whether our interests are necessary and proportionate and whether they are overridden by your rights and interests. Where we rely on consent, you may withdraw it at any time; withdrawal does not affect processing that took place before consent was withdrawn. -
If you do not provide information
Some information is needed to assess a credit application, enter into or perform a contract, verify identity, prevent fraud, or meet legal and regulatory obligations. If you do not provide information we reasonably require, we may be unable to consider an application, arrange or provide finance, make a payment, administer an agreement or continue to provide a service. Information requested solely for optional marketing is not mandatory.
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Credit reference and financial crime-prevention checks
We will search credit reference agencies and financial crime-prevention services and identity-verification services when assessing a credit application, managing an agreement, tracing and recovering debts, and preventing financial crime. Searches may leave a footprint on your credit file and information may be linked with financial associates where the relevant agency’s rules permit this.
We obtain this information via Creditsafe, which uses its data partner TransUnion to supply consumer credit and identity data.
- Creditsafe Business Solutions Limited is authorised and regulated by the Financial Conduct Authority
FCA Firm Reference Number: 742313 - TransUnion International UK Limited is authorised and regulated by the Financial Conduct Authority
FCA Firm Reference Number: 737740
The information we receive may include data relating to your identity, credit commitments, payment history, and public record information. This data is used solely for legitimate business purposes, including creditworthiness assessment, identity verification, and fraud prevention, in accordance with applicable data protection laws.
Further information about how Creditsafe and TransUnion process your personal data can be found in their respective privacy notices:
- Creditsafe Privacy / Transparency Notice:
Transparency Notice | Customers & Suppliers - TransUnion CRAIN (Credit Reference Agency Information Notice):
https://www.transunion.co.uk/legal/privacy-centre/pc-credit-reference
Where we introduce an application to another lender or other finance provider, those organisations will carry out their own credit and fraud checks and will act as separate data controllers under their own privacy notices.
- Creditsafe Business Solutions Limited is authorised and regulated by the Financial Conduct Authority
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Automated tools and human decision-making
We may use automated tools to support identity verification, fraud prevention, credit assessment, affordability analysis, risk scoring, case prioritisation and record management. These tools may generate indicators, scores or recommendations using predefined criteria.
Unless we tell you otherwise, we do not make decisions that produce legal or similarly significant effects solely by automated means. A suitably authorised person reviews relevant information and can reconsider or change the outcome. You may contact us to ask for further information about the role of automated tools in a decision concerning you.
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Use of Artificial Intelligence
We may use artificial intelligence (“AI”) and AI-enabled technology to assist us in processing your personal data for the following purposes:
- Assessing your credit application.
- Affordability Checks
- Fraud Signals
- Identity Verification
This may include using AI to support administrative tasks, review or summaries information, identify patterns, produce draft content or otherwise assist our employees in providing our services. Where appropriate, the output produced by AI will be subject to human review.
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Who we share information with
Where necessary and lawful, we may share personal information with:
- Lenders, funders, banks, investors, assignees, security trustees and organisations involved in funding, purchasing or taking security over finance agreements.
- Credit reference agencies, fraud-prevention agencies, identity-verification providers, sanctions-screening services and payment-service providers.
- Suppliers, introducers, brokers, agents and other parties involved in the proposed or completed transaction.
- Our information technology, hosting, document-management, communications, analytics and professional-service providers.
- Accountants, auditors, lawyers, insurers, valuers, repossession agents, collection agents and other advisers.
- Government bodies, regulators, courts, law-enforcement agencies and other authorities where disclosure is required or permitted by law.
- Potential buyers, sellers, funders or advisers to Clear in connection with a corporate transaction, restructuring or transfer of assets, subject to appropriate confidentiality arrangements.
Recipients may act as our processors, joint controllers or separate controllers, depending on their role. Separate controllers are responsible for their own use of personal information and may provide their own privacy notices.
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International transfer
Some service providers or recipients may be located outside the United Kingdom, or may allow information to be accessed from outside the United Kingdom. Where this results in a restricted transfer, we will use a lawful transfer mechanism, such as UK adequacy regulations, an approved contractual safeguard, or a permitted exception. Where required, we will also assess whether the transfer provides an appropriate level of protection and apply additional safeguards.
We will only send your data outside the European Economic Area (“EEA”) to:
- Follow Your instructions
- Comply with legal duty
- Suppliers / Funders we deal with
If we do transfer your personal information outside the UK and EEA to our suppliers / funders, we will make sure that it is protected to the same extent as in the UK and EEA. We will use one of these safeguards:
- Transfer it to a non-EEA country with privacy laws that give the same protection as the UK and EEA.
- Put in place a contract with the recipient that means they must protect it to the same standards as the UK and EEA.
We protect your data using robust security and IT encryption measures as described in our Security policy.
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How we protect information
We use appropriate technical and organisational measures designed to protect personal information against accidental or unlawful loss, alteration, disclosure, destruction or access. Measures may include access controls, authentication, encryption, secure backups, staff training, supplier due diligence, contractual controls and incident-management procedures. No method of transmission or storage is completely secure, but we regularly review our controls in light of the nature and risk of the information we process.
Cyber Essentials Plus Certified
Our Cyber Essentials Plus certification demonstrates that our security controls have been independently assessed against common cyber threats.
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How long we keep Information
We keep personal information only for as long as reasonably necessary for the purposes for which it was collected, including to perform contracts, manage risk, resolve disputes and meet legal, regulatory, accounting and reporting requirements. Retention periods vary by record type and may continue after an application is declined, withdrawn or an agreement ends. We securely delete or anonymise information when it is no longer required. Further information about relevant retention periods is available on request.
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Marketing
We may contact business customers and business contacts about products or services that we believe may be relevant, where permitted by law. You may object to direct marketing at any time by using an unsubscribe facility or contacting us. We will retain sufficient information to record and respect an opt-out request.
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Cookies and website information
Our website may use essential cookies required for operation and, where you have made an appropriate choice, non-essential cookies for analytics, preferences or marketing. Non-essential cookies should not be set before the required consent has been obtained. You can change cookie preferences through the website cookie-control tool and may also adjust browser settings. Further details, including the cookies in use, their purposes, providers and duration, should be set out in the separate Cookie Policy or cookie-control panel.
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Your data protection rights
Depending on the circumstances, you may have the right to:
- be informed about how your personal information is used;
- ask for access to your personal information;
- ask us to correct inaccurate or incomplete information, or update information as the case may be;
- ask us to erase information where there is no continuing lawful reason to keep it;
- ask us to restrict processing in certain circumstances;
- receive certain information in a portable format where the right to data portability applies;
- object to processing based on legitimate interests and object at any time to direct marketing;
- withdraw consent where processing is based on consent; and
- raise concerns about qualifying automated decisions and request appropriate human involvement where applicable.
These rights are not absolute and may be subject to legal conditions or exemptions. We may need to verify your identity before acting on a request. We will normally respond within one month, although the period may be extended where permitted by law for a complex request or multiple requests.
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Contacting us and making a complaint
Clear’s data protection contact is:
Mark Haywood
Email: mark.haywood@clearaf.co.uk
Address: Suite 6, Ripon House, Station Lane, Hornchurch, RM12 6JLPlease contact us first if you have a question, wish to exercise a right or have a concern about our handling of personal information.
You also have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection. Current contact details and complaint routes are available from the ICO’s official website.
Clear Asset Finance Ltd – ICO registration number is Z2495520.
Clear Business Finance Ltd – ICO registration number is ZC210793.
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Changes to this notice
We may update this notice to reflect changes in law, regulatory guidance, our services or the way we use personal information. The current version will be published on our website with its effective date. Material changes may also be brought to your attention by other appropriate means.