Privacy Policy & Disclosure Statement

1. Regulatory Status Disclosure

Aberdeen Corporate Finance Limited (“ACFL”):

• Operates as a commercial financier and introducer
• Is not authorised or regulated by the Financial Conduct Authority (FCA)
• Does not provide regulated financial advice

Some business is conducted:

• On an introduction-only basis
• Via a network of UK and international funding partners

Such activities may constitute unregulated business.

2. Whole of Market Statement

ACFL sources investment property and commercial finance solutions from a broad panel of lenders across the market.

3. Data Controller

ACFL is the Data Controller under:

• UK General Data Protection Regulation (UK GDPR)
• Data Protection Act 2018

ICO Registration Number: ZB795163

You can verify this at: https://ico.org.uk

4. Definitions

“Personal Data”, “Processing”, “Controller” and “Processor” have the meanings set out in UK GDPR.

5. Data We Collect

We collect and process:

6. Purpose of Processing

We process Personal Data to:

• Introduce Clients to appropriate lenders
• Facilitate funding applications
• Conduct due diligence and verification
• Meet legal obligations (including AML/KYC)
• Improve our services

7. Lawful Basis

Processing is undertaken under:

• Article 6 (1)(b) — Contractual necessity
• Article 6 (1)(c) — Legal obligation
• Article 6 (1)(f) — Legitimate interests

8. Data Sharing

We may disclose your data to:

• Lenders and funding partners on our panel
• Credit reference agencies (CRAs)
• Fraud prevention agencies (including CIFAS and similar bodies)
• Professional advisers (legal, accounting, due diligence)
• Regulatory or law enforcement bodies

All disclosures are limited to what is reasonably necessary for the purposes set out in this notice.

8a. Online Applications & Lender APIs

When you use our online “Quick Apply” service, your application is submitted electronically to our lender partner, Fleximize, and may also be shared with other lenders on our panel where appropriate. In particular:

• The business and personal information you provide (including details of directors, shareholders and any guarantors) is transmitted securely to the lender's API.
• The lender will perform searches with credit reference agencies and fraud-prevention agencies on the business and the individuals named. A footprint of these searches may be visible on personal credit files.
• Information provided may be used by the lender and such agencies to prevent fraud and money laundering in accordance with their published privacy notices.
• Any supporting documents you upload (such as bank statements or accounts) are stored in a secure cloud storage service and forwarded to the lender only where required to assess the application.
• We retain a copy of your application and the lender's response for record-keeping, regulatory and service-follow-up purposes in line with section 11 below.
• You provide your explicit consent to each of these uses by ticking the consent boxes on the application form. You may withdraw consent at any time by contacting us (see section 20), though doing so after submission will not undo searches already performed by the lender.

For the lender's own privacy notice and CRA list, please see fleximize.com/privacy-policy.

9. International Transfers

Where data is transferred outside the UK:

• Appropriate safeguards under Chapter V UK GDPR are applied
• Including Standard Contractual Clauses where required

10. Data Storage & Security

Your data may be stored:

• Electronically (secure systems)
• In physical records

We implement:

• Encryption
• Access controls
• Secure storage protocols

11. Data Retention

We retain data:

• For a minimum of 5 years (MLR 2017 compliance)
• Longer where legally required

12. Your Rights

You have the right to:

• Access your data
• Request correction
• Request deletion (where applicable)
• Restrict processing
• Object to processing

You may contact us to exercise these rights.

13. Consent

By engaging ACFL, you consent to collection and use of your data for stated purposes. Consent may be:

• Written
• Verbal
• Electronic

You may withdraw consent at any time, subject to legal limitations.

14. Marketing & Unsubscribe

You may opt out of communications:

• Via email link
• By contacting: [email protected]

15. Disclosure Control

We will only disclose Personal Data:

• Where authorised
• Where legally required
• Upon verification of identity

16. Case Studies

Case studies published on this website:

• Are anonymised
• May represent illustrative scenarios
• Do not guarantee outcomes

17. Complaints

Complaints may be made:

18. Complaint Escalation

Where a complaint relates to a regulated activity conducted by a third-party lender, you may have the right to escalate the matter to the Financial Ombudsman Service. ACFL itself, as a non-regulated entity, is not directly subject to the jurisdiction of the FOS.

19. Data Protection Complaints

You may also lodge a complaint with the Information Commissioner's Office:
https://ico.org.uk

20. Contact