Privacy Policy

Please note: We are currently in a Resolution Event (please refer to our Investor Terms for more information). At the conclusion of the Resolution Event, Growth Street will aim to cease business activities and wind down its operations. We will not be conducting any further lending activities, or accepting any new investors or deposits from existing investors. If you are an investor, please contact us on Live Chat or by calling 0808 123 1231 (Option 3) if you have any questions. If you are an existing Growth Street borrower, please contact your Relationship Manager if you have any questions.

INVESTOR RISK WARNING
Your capital is at risk when you invest through Growth Street. Our investment products are not covered by the Financial Services Compensation Scheme. Read about our Loan Loss Provision here.

Last Update: 20th September 2019


  1. Overview
    1. Growth Street is committed to protecting and respecting your privacy. This policy describes how we collect, use, process and share your information, including personal information.
    2. In this policy, ‘Growth Street’, ‘we’, ‘us’ or ‘our’ means the members of our group. You can find out more information about our group companies in our Terms of Use. If you see an undefined term in this policy, it will have the same meaning as our Terms of Use.
    3. ‘You’ or ‘Your’ refers to anyone accessing and or using our website, products and services, as well as those we contact with promotional materials about our business. Where you sign up to or use any of our products or services on behalf of a business, ‘You’ or ‘Your’ also refers to directors, shareholders, beneficial owners and other controlling officials of the business, as well as anyone who has provided information to us in relation to the products and services provided to you by us.
    4. When we collect and use your personal information, we do so in compliance with the Data Protection Act 1998 and, from the 25th of May 2018, the General Data Protection Regulation (GDPR). We are responsible as a ‘controller’ of that personal data.
    5. If you have any questions about our policy or how we use your data, you can get in touch by email at privacy@growthstreet.co.uk or by calling one of our team on 0808 123 1231. You can also write to us at Irongate House, 22-30 Dukes Place, London EC3A 7LP.
  2. The information we collect and process
    1. The information we collect and process will depend on whether you are applying to be an investor or borrower on the Growth Street Marketplace, using any of our tools such as the Cash Flow Forecast,  are part of our marketing campaigns or simply just browsing our websites.
    2. We may collect the following information about you:
      1. If you are an individual, information about you which includes personal data such as your name, date of birth, phone number, email address, residential address, financial information, employment details and your source of funds.
      2. If you are a business, information about your business, such as your business name and activities, financial information (which in most instances will not include any personal data), as well as information about all of your directors, shareholders, business partners and persons of significant control (which includes personal data such as names, dates of birth, phone numbers, email addresses and residential addresses).
      3. Information about your use of our services, including your IP address, passwords and security questions and answers used to access the Growth Street websites.
  3. How we collect the information
    1. We collect most personal information from you directly, through our websites as well as by email, telephone and post. We may also collect information in the following ways:
      1. directly from third parties such as companies that introduce you to us, credit reference agencies and fraud prevention agencies; and/or
      2. from publicly available sources such as Companies House, public directories or your own website either directly, through an API (application programming interface), by searching the internet or through a third party provider; and/or
      3. from companies we use to deliver our products and services to you, such as payment service providers and IFISA provider; and/or
      4. from your accounting services or online banking provider where you have linked your platform to us through an API; and/or
      5. from other third parties where we have your consent; and/or
      6. from cookies on our website (for more information, please see the Cookies section below).
    2. Where you are applying to be a borrower or investor, we will collect this information when you first apply and then continuously for as long as you remain a borrower or investor on the Growth Street Marketplace. This enables us to continue to provide you with the products and services, as well as ensuring that we are complying with our relevant legal and regulatory obligations. It's your responsibility to ensure the information we hold on you is correct and up-to-date at all times so please keep us informed of any changes.
  4. How we use your information
    1. Under data protection law, we cannot use your personal information unless we have a proper reason to do so. The lawful bases for processing information are:
      1. for the performance of/to fulfil a contract we have with you; or
      2. when it is our legal duty; or
      3. when it is in our legitimate interest (which means we have a business or commercial reason of our own to use your information) or we believe it's in your own legitimate interest; or
      4. when you consent to it.
    2. We (or third party data processors, agents and contractors acting on our behalf) will collect, store and use your personal information for the following reasons:
      WhoWhat we use your data forWhy we use your data
      AllTo provide our products and services to you and to manage our relationship with you.For the performance of our contract with you or to take steps at your request before entering into a contract.
      AllTo update and enhance our customer records.For the performance of our contract with you and to comply with legal requirements to keep our records up-to-date and accurate.
      AllStatistical analysis to help us manage and promote our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures.For our legitimate interests or those of a third party, ie to promote our business and be as efficient as we can so we can deliver the best service to our customers.
      AllWhere you sign up to one of our products or provide your details on our website, to contact you about any of our products and services which we believe may interest you.We have a legitimate interest in sending information to our direct customers to keep you up-to-date on our products, services and offers that relate. You can opt out of such messages at any time by contacting us on privacy@growthstreet.co.uk or clicking the opt-out link at the bottom of every email.
      AllTo market our products and/or services to you.For our legitimate interest, i.e. to promote our products to businesses where we believe they will benefit from our products. 'You can opt out of such messages at any time by contacting us on privacy@growthstreet.co.uk or clicking the opt-out link at the bottom of every email.
      AllInformation about how you use our website.This information will be anonymised and used to produce aggregate statistics or for reporting purposes and to calculate referral fees, where applicable.
      Applying and existing borrowers and investorsTo carry out regulatory checks and report to the Financial Conduct Authority, HM Revenue & Customs or any other relevant authority.To comply with our legal and regulatory obligations.
      Applying and existing borrowers and investorsTo complete checks for the purposes of preventing fraud and money laundering, and to verify your identity. We and fraud prevention agencies may enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime. Such checks will be completed when you first apply and then periodically during the time you are an active borrower or investor.We have a legitimate interest in preventing fraud and money laundering, and to verify your identity, in order to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the services you have requested.
      Borrowers and investorsTo operate and administer accounts with our chosen payment service providers to allow you to make use of your Growth Street account.To comply with our contract with you and to enable you to make or receive payments to and from other customers on the Growth Street Marketplace.
      BorrowersTo assess your application for credit and manage your account if your application is successful, including by using scoring methods and to check the accuracy of details on applications for credit.For our legitimate interests or those of a third party, i.e. to ensure our customers are likely to be able to pay for our products and services.
      BorrowersTo trace your whereabouts to recover debts or enforce the terms of your agreement including by exercise of security.For the performance of our contract with you and your contract with us and with investors on the Growth Street Marketplace.
      BorrowersTo disclose your personal information to other credit providers or brokers who we believe may be able to help you obtain credit that we have been unable to provide.We will only use your information in this way where you have specifically consented to us doing so.
  5. Direct Marketing
    1. We use various channels (email, telephone and post) to share promotional materials about our products and services. When we do this in a business to business capacity, we often rely on our legitimate interest in processing your information for promotional purposes, which means we do not usually need your consent. If we are relying on our legitimate interest to contact you (rather than consent), this will be clearly stated in the communication.
    2. You have the right to opt out of receiving promotional communications at any time by contacting us at privacy@growthstreet.co.uk or by using the ‘unsubscribe’ link included in the bottom of our marketing emails.
  6. Who we share information with
    1. We may share your information with the following categories of companies as an essential part of being able to provide our services to you:
      1. companies within the Growth Street group; and/or
      2. companies we use to deliver our products and services to you, such as payment service providers and IFISA provider; and/or
      3. professional service providers we use to help us run our business, such as our accountants, auditors, marketing and advertising agencies or website hosts; and/or
      4. credit reference agencies, law enforcement and fraud prevention agencies, regulatory and governmental bodies; and/or
      5. organisations that introduced you or your business to us; and/or
      6. anyone else with your permission, including companies you ask us to share your data with.
    2. Where you are a borrowing customer and your business was referred to us by another organisation (for example, a finance broker), we may share information about your business’s financial performance and details of your facility with them during the term of your facility.
    3. We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information and we will only share the information necessary for them to provide their service. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you.
  7. Transferring your personal information out of the EEA
    1. It is sometimes necessary for us to share your personal information outside the European Economic Area (EEA) , for example, to a trusted service provider. Transfers of data outside of the EEA are subject to special rules under European and UK data protection law.
    2. In order to comply with these rules and to ensure that your data is always protected, we will only transfer personal information to countries outside of the EEA where that country has been assessed by the European Commission (the ‘EC’) as providing an adequate level of protection for personal information or where we have complied with the recommendations of the EC to provide enhanced protection, for example, by ensuring any US based service providers are registered with a Privacy Shield certification or by using EC approved data protection contract clauses.
  8. Credit reference agencies and fraud prevention agencies

    Credit reference agencies (CRAs)

    1. Where you apply for credit, as a borrower, we’ll perform identity checks on your company, directors, shareholders and, where required, on guarantors in order to process your application. 
    2. To do this, we will share your personal and business information with CRAs and they will give us information about the business and you. The information we exchange can include:
      1. information about your business or company, such as previous applications for credit and the conduct of the accounts and also similar personal credit information in your name and of your business partners;
      2. public information such as County Court Judgments (CCJs), company voluntary arrangements (CVAs), individual voluntary arrangements (IVAs) and bankruptcies; and
      3. electoral register information on you and your business partners.
    3. We'll use this information to assess the creditworthiness of your business and you, to verify the accuracy of the data you've provided to us and to prevent criminal activity, fraud and money laundering.
    4. We'll also make periodic checks with CRAs while you're using our services to help us manage your account and will continue to exchange information about you and your business with CRAs while you have a relationship with us and this information may be supplied to other organisations by CRAs.
    5. When credit reference agencies receive a search from us they will place a credit search "footprint" on your company credit file and on the personal credit files of any director/owner or partner that has been searched and this may be seen by other lenders.
    6. If you tell us that you have a spouse or financial associate, we will link your records together, so you should make sure you discuss with them, and share this information before you submit your application. CRAs will also link your records together and these links will remain on your and their files until such time as you or your partner successfully files a disassociation with the CRAs to break that link.
    7. Credit reference agencies will keep records of outstanding debts on file for six years after they are closed, whether settled by you or defaulted.
    8. We use Experian Limited to carry out business credit references and TransUnion to carry out personal credit references. You should read a copy of the Credit Reference Agency Information Notice (CRAIN) which is available here and sets out how your data will be used by them . We also use Moody’s Analytics, Inc. and its affiliates to carry out additional checks on businesses.
    9. Fraud Prevention Agencies

    10. Where you apply to become an investor or borrower on the Growth Street Marketplace, we undertake checks for the purposes of preventing fraud and money laundering, and to verify your identity before we provide services or financing to you. These checks require us to process personal data about you.
    11. Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.
    12. If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services or financing you have requested, or we may stop providing existing services to you.
    13. A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you. If you have any questions about this, please contact us on the details above.
    14. Whenever fraud prevention agencies transfer your personal data outside of the European Economic Area, they impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the European Economic Area. They may also require the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing.
  9. How long your information will be kept
    1. We will keep your information while you have an account with us or we are providing products and services to you. Thereafter, we will keep your information for as long as is necessary to respond to any questions, complaints or claims made by you or on your behalf; to show that we treated you fairly; and to keep records required by law.
    2. We will not retain your personal information for longer than necessary for the purposes set out in this policy.
    3. Where you make a request to us in line with your rights under the GDPR (set out in clause 11 below), such as a deletion request or to opt-out from marketing communications, we may retain some of your details to ensure your preferences are respected in the future. For example, we may retain your name and email address to ensure you are no longer sent any marketing emails. We will only retain the minimum information required and any information retained for this reason will not be used for any other purpose.
  10. Cookies
    1. The Growth Street websites uses cookies to collect information about you. Cookies are small data files which are placed on your computer when you use a website and which collect certain personal information about you.  Cookies enable us to tailor our service offering (including the websites) and to provide you with a better service.
    2. We use the following cookies:
      1. Strictly necessary cookies. These are cookies that are required for the operation of our website.  They include, for example, cookies that enable you to log into secure areas of our website. They do not gather information about you that could be used for marketing purposes or remembering where you have been on the Internet.
      2. Analytical/performance cookies. They allow us to collect information about how you use our website, such as, how you move around our website and if you experience any errors. These cookies do not collect any information that could identify you; all of the information collected is anonymous and is only used to help us improve the way our website works, understand what interests our users and measure how effective our advertising is.
      3. Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences and improve your visit.
      4. Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. They are linked to services provided by third parties, such as “Like” and “Share” buttons. The third party provides these services in return for recognising that you have visited our website.
    3. Generally, cookies which are strictly necessary for the operation of the website will expire when you leave the website. Other cookies may be more permanent or not expire unless you actively delete them.
    4. If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may be unable to use our services and may lose some of the functionality of our websites. For further information on cookies and how to disable them, you can visit the Information Commissioner's Office (ICO) website on  https://ico.org.uk/for-the-public/online/cookies.
  11. Your rights
    1. You have a number of rights in relation to your personal information:
      1. The right to request access to the personal information we hold about you.
      2. The right to request an update or correction to any out-of-date or incorrect personal information we hold about you.
      3. The right to request that we delete any personal information concerning you where you don’t think there is any justification for us holding it.
      4. The right to receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and to ask us to pass this information on to other organisations.
      5. The right to object to or restrict our processing of your personal information in certain circumstances.
      6. The right to opt out of any marketing communications that we (or any third party to whom we have disclosed your personal information with your consent) may send you.
    2. If you wish to exercise any of the above rights, please contact us by email at privacy@growthstreet.co.uk.  You must provide us with enough information to identify you, for example, your full name and address as well as proof of your identity, such as a copy of your passport or driving licence.
  12. Security
    1. We have appropriate security measures in place to prevent personal information from being accidentally lost, used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
    2. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
    3. Whilst we take appropriate technical and organisational measures to safeguard the personal information that you provide to us, we accept no liability if communications are intercepted by third parties or incorrectly delivered or not delivered.  Where possible, we recommend transferring information directly to us using the functionality provided on the website instead of by email.
    4. If we transfer your information to third parties we will take steps to ensure that such transfer and any on-going processing by such third parties is carried out securely and in accordance with applicable privacy laws.
  13. How to complain
    1. If you are unhappy about the way we use your information, you should contact us in the first instance using the information above. Under the GDPR, you can also lodge a complaint with the ICO. The ICO can be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113. You can find more information about our complaints procedure here.
  14. Changes to this privacy policy
    1. We may make changes to this policy to ensure it accurately reflects how we are processing your data. If we make any substantial changes, we’ll make sure you’re aware of these by posting a message on our websites or contacting you by email.
The Loan Loss Provision we offer does not give you a right to a payment so you may not receive a pay-out even if you suffer loss. The fund has absolute discretion as to the amount that may be paid, including making no payment at all. Therefore, investors should not rely on possible pay-outs from the Loan Loss Provision when considering whether or how much to invest. You can read our Loan Loss Provision Policy here.