1.2. All your Personal Data shall be held and used in accordance with the EU General Data Protection Regulation 2016/679 (GDPR) and UK national laws implementing GDPR (including the The Data Protection Bill) and any legislation that replaces it in whole or in part and any other legislation relating to the protection of personal data (collectively referred to as Data Protection Legislation).
1.4. The Company ensures on an ongoing basis that all of its suppliers and third parties operate in compliance with GDPR.
1.5. For any Data Protection or GDPR-related enquiries in connection with our business, please contact us:
B&G Finance Limited
43 Manchester Street,
W1U 7LP, UK
2.1. The Company is the controller and responsible for your personally identifiable information (Personal Data) as listed in clause 3 below.
3.1. We use automated technologies and interactions to collect data from and about you. With regard to each of your visits to our Site we may automatically collect the following information:
A) Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website;
B) Usage Data includes information about how you use our website, products and services;
C) Site Specific Information includes information about your visit to our website including:
i. the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time);
ii. Products, services or other pages you viewed or searched for;
iii. page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
3.2. We collect technical data through analytics providers, advertising networks and search information providers. A list of these third parties can be provided to you on request.
3.3. We will use this information to:
a) administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
b) improve our site to ensure that content is presented in the most effective manner for you and for your computer;
c) allow you to participate in interactive features of our service, when you choose to do so;
d) to keep our site safe and secure;
e) measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
f) make suggestions and recommendations to you and other users of our site about products or services that may interest you or them.
4.1. You may give us information about you (i.e. Personal Data) by filling in forms on our site Our Site or by corresponding with us by phone, e-mail, mail or otherwise. This includes information you provide to us when you register to use our site, subscribe to our service, search for a product, place an order on our site and when you report a problem with our site.
The information you give us may include:
a) Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender;
b) Contact Data includes billing address, delivery address, email address and telephone numbers;
c) Financial Data includes bank account and payment card details;
d) Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us;
e) Profile Data includesyour username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses;
f) Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences; and
4.2. We will use this information to:
a) carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
b) to provide you with information about other products and services we offer that are similar to those that you have already purchased or enquired about;
c) to provide you, or permit selected third parties to provide you, with information about products or services we feel may interest you. If you are an existing customer, we may contact you by telephone, mail or electronic means (e-mail or SMS) with information about products and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data (the registration form);
d) to notify you about changes to our service;
e) to ensure that content from our site is presented in the most effective manner for you and for your computer;
5.1. We may receive information about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on this site. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them. A list of these third parties can be provided to you on request.
5.2. We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
6.1. We may from time to time share your Personal Data with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006. A list of any other group companies holding your Personal Data can be provided to you on request.
6.2. We may share your information with selected third parties including:
a) Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
b) Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others.
c) Analytics and search engine providers that assist us in the improvement and optimization of our site.
d) Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
e) Professional advisors, such as Solicitors.
6.3. We may disclose your Personal Data to third parties if:
a) we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
b) the Company or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
c) we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and Conditions for Clients of any of our products and other agreements; or to protect the rights, property or safety of the Company, our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
7.1. The Company will only process Personal Data where there is a lawful basis as per Data Protection Legislation. This lawful basis shall be one or more of the following:
a) Express consent from you;
b) In order to perform and/or complete a contract with a third party;
c) To comply with a legal obligation;
d) To protect your vital interest;
e) It is in the public interest; and
f) There is a legitimate interest.
7.2. Legitimate interests are a flexible basis upon which the law permits the processing of an individual's personal data. To determine whether we have a legitimate interest in processing your data, we balance the needs and benefits to us against the risks and benefits for you of us processing your data. This balancing is performed as objectively as possible by our Data Protection Manager. You are able to object to our processing and we shall consider the extent to which this affects whether we have a legitimate interest.
8.2. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
8.3. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
8.4. As a result of increased risk posed by cyber fraud please do not send any funds until you have received confirmation from your relevant contact and are certain as to the correct account details. Unfortunately, we do have to warn you that we cannot accept responsibility if you transfer money into an incorrect account.
9.1. When reading this notice, it might be helpful to understand that your rights arising under Data Protection Legislation include:
a) The right to be informed of how your Personal Data is used (through this notice);
b) The right to access any personal data held about you;
c) The right to withdraw consent at any time, by emailing firstname.lastname@example.org;
d) The right to rectify any inaccurate or incomplete personal data held about you;
e) The right to erasure where it cannot be justified that the information held satisfies any of the criteria outlined in this policy, or where you have withdrawn consent;
f) The right to prevent processing for direct marketing purposes, scientific/historical research or in any such way that is likely to cause substantial damage to you or another, including through profile building; and
g) The right to object to processing that results in decisions being made about you by automated processes and prevent those decisions being enacted.
9.2. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at email@example.com.
9.3. Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
10.1. The Company will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
10.2. The Company retains your Personal Data in line with the requirements set out in the Financial Conduct Authority (FCA) Handbook (May 2018) and will adjust its Data Retention policy from time to time in accordance therewith.
10.3. Your right to erasure will be subject to the record-keeping requirements as set out by the FCA. Where we receive a request to delete Personal Data this will be undertaking in line with our usual Data Retention policy.
11.1. Similar to other commercial websites, our Website uses a technology called "cookies" and web server logs to collect information about how our Website is used. Cookies are small text files that are placed on your computer's hard drive through your web browser when you visit any web site. They are widely used to make web sites work, or work more efficiently, as well as to provide information to the owners of the site.
11.2. Like all other users of cookies, we may request the return of information from your computer when your browser requests a web page from our server. Cookies enable our web server to identify you to us, and to track your actions and the pages you visit while you use our website. The cookies we use may last for a single visit to our site (they are deleted from your computer when you close your browser), or may remain on your computer until you delete them or until a defined period of time has passed.
b) allow essential parts of our web site to operate for you.
c) operate our content management system.
d) operate the online notification form - the form that you use to contact us for any reason. This cookie is set on your arrival at our web site and deleted when you close your browser.
e) enhance security on our contact form. It is set for use only through the contact form. This cookie is deleted when you close your browser.
f) collect information about how visitors use our site. We use the information to improve your experience of our site and enable us to increase sales. This cookie collects information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from, and the pages they visited.
g) record that a user has viewed a webcast. It collects information in an anonymous form. This cookie expires when you close your browser.
h) record your activity during a web cast. For example, as to whether you have asked a question or provided an opinion by ticking a box. This information is retained so that we can serve your information to you when you return to the site. This cookie will record an anonymous ID for each user, but it will not use the information for any other purpose. This cookie will last for a period of time after which it will delete automatically.
i) store your Personal Data so that you do not have to provide it afresh when you visit the site next time. This cookie will last for a period of time after which it will delete automatically.
12.1. You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time at firstname.lastname@example.org.
12.2. Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us.
13.1. Data Protection Legislation gives you the right to access information held about you. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
The information about you that we have collected for the performance of our contracts is required in order for us to successfully fulfil our obligations to you. If you choose not to provide the personal data requested, we will not be able to enter into a contract with you to provide the benefits we offer. If we are already processing your Personal Data under a contract, you must end our contractual relationship (as/where permitted) in order to exercise some of your rights.
If you are unhappy about our use of your Information, you can contact us at the address or email address above. You are also entitled to lodge a complaint with the UK Information Commissioner’s Office using any of the below contact methods.
Telephone: 0303 123 11113
Post: Information Commissioner's Office
B&G Finance Ltd (hereinafter referred to as "Basset & Gold", “Firm”, “Our”, “We”, “Us”) has a policy on the management of potential conflicts of interest to ensure that all appropriate steps are taken to identify and to prevent or manage conflicts that may arise which might result in a material risk to the interests of our clients.
Under the FCA’s Principles for Businesses, Principle 8 requires a firm to “manage conflicts of interest fairly, both between itself and its customers and between a customer and another client.”
Basset & Gold takes all appropriate steps to identify and to prevent or manage conflicts of interest between:
that arise or may arise in the course of the Firm providing services to its clients in relation to its regulated activities, including those caused by the receipt of inducements from third parties or by the Firm’s own remuneration and other incentive structures.
Our approach is to identify those aspects of our service, including how we interact with the Basset & Gold group of companies and third-party suppliers, which could result in a conflict between your interests and ours or between the interests of different clients.
A conflict of interest is a conflict that arises in any area of Basset & Gold’s business in the course of providing its clients with a service which may benefit Basset & Gold (or another client for whom Basset & Gold is acting) whilst potentially materially damaging another client where Basset & Gold owes a duty to the client. There may be a conflict where Basset & Gold (or anyone connected to Basset & Gold including another Basset & Gold affiliate or associate):
Basset & Gold adopted numerous internal policies and procedures in order to manage recognised conflicts of interests. These policies and procedures will be subject to Basset & Gold’s normal monitoring and review processes and include:
Basset & Gold insists that in its dealings with clients its staff must always use the highest standard of integrity in their actions. The induction programme, Training & Competency procedures and monitoring programme at Basset & Gold are designed to ensure that all relevant staff are familiar with and observe, inter alia, the FCA Principles for Businesses and the Statements of Principle and Code of Practice for Approved Persons.
Treating Customers Fairly
Basset & Gold must not knowingly deal in the exercise of discretion in relation to that transaction unless it takes all appropriate steps to ensure fair treatment for the client. “Appropriate steps” may be taken in one or more of the following ways:
Our organisational structure provides for segregation of duties and appropriately apportioned roles and responsibilities to prevent conflicts arising, ensuring that no single person can exercise inappropriate influence over a particular process. Procedures are in place to ensure that potential conflicts between Basset & Gold and our clients are managed fairly.
Contracts of employment prevent staff from accepting roles or directorships with other companies outside the Basset & Gold group unless prior approval has been received from the Board of Directors. We do not display preference to any client or group of clients over any others in the provision of our services.
Staff bonus and remuneration arrangements are carefully considered to ensure that conflicts do not inadvertently arise through inappropriately set targets. All relevant staff who are open to a conflict of interest are paid a basic salary including those in key support areas such as Compliance, Finance and Operations. This salary is not dependent on company performance. A bonus structure does exist which is linked to company performance, team performance or the individual’s performance. It is at the discretion of the senior management.
An internal whistleblowing policy is in place which affords staff a high level of protection should they report any wrongdoing by others.
Confidentiality and Information barriers
Basset & Gold has put in place procedures to control or prevent the flow of information between Basset & Gold group of companies where the interests of clients of one entity may conflict with the interests of clients of another entity or with Basset & Gold’s own interests. Furthermore, Basset & Gold insists on strict client confidentiality to ensure that information is disclosed only to those entitled to receive it or otherwise with the prior approval of the Compliance Department.
If and when Basset & Gold determines the methods it employs to prevent and mitigate conflicts of interest not to be adequate to guarantee, with reasonable assurance, that risk of harm to clients’ interests will be prevented, Basset & Gold shall disclose any such conflicts of interest to the client in order to avert a risk of damage to clients’ interests. Any actual or potential conflict of interest will be disclosed by Basset & Gold in sufficient time and in a durable manner prior to carrying out the transaction or providing an investment or an ancillary service to a client.
Where Basset & Gold considers it is not able to manage the conflict of interest in any other way it may decline to act for a client.
We prevent potential conflicts arising through the selection of suppliers by refusing to accept or provide fees, commissions and non-monetary benefits which do not directly enhance the service offered. Any personal relationships are disregarded in the selection of service providers, agents, third-party suppliers and distributors to prevent the possibility of inappropriate selection.
We will not charge our clients any fees in respect of our introduction service, but may receive fees from the Issuer. Our group of companies and associates will typically charge interest and fees to borrowers and investees to whom the Issuer provides funding.
We acknowledge that gifts and entertainment arrangements common in the industry may give rise to adverse influence. We address this by limiting the offer and receipt of gifts and/or entertainment to those (vice versa) where the value is not material.
The keeping of records regarding conflicts of interest
Basset & Gold keeps records, which are updated on a regular basis, of any kinds of activities or services carried out by Basset & Gold, or on its behalf, in which any conflict of interest involving a material threat of harm to the interests of our clients has been identified.
This Conflicts of Interest Policy details the procedures that are in place to ensure the fair treatment for all of our clients through the effective management of potential conflicts. We are not aware of any further material conflicts of interests.