Privacy Policy

1. Who We Are

Aldwych European Capital ("Aldwych", "we", "us", or "our") is the data controller for personal data collected through our lending platform and services. We are committed to protecting your personal data in accordance with the EU General Data Protection Regulation (GDPR) and applicable national data protection laws.

2. Information We Collect

We collect and process the following categories of personal data:

• Identity data: name, date of birth, nationality, identification document details
• Contact data: email address, telephone number, residential address
• Financial data: income, employment, existing debt, business financials, bank statements
• Application data: loan purpose, requested amount, documents uploaded
• Technical data: IP address, browser type, device identifiers, session logs
• Communication data: messages exchanged through our secure messaging platform

3. Legal Basis for Processing

We process your data on the following legal bases:

• Contract performance: processing your loan application and servicing your facility
• Legal obligation: KYC and AML checks required by financial regulation
• Legitimate interests: fraud prevention, risk management, platform security
• Consent: for marketing communications, which you can withdraw at any time

4. How We Use Your Data

Your personal data is used to:

• Verify your identity and conduct KYC/AML checks
• Assess your creditworthiness and underwrite your application
• Administer your loan facility and process repayments
• Communicate with you regarding your application and account
• Comply with legal, regulatory, and tax reporting obligations
• Detect and prevent fraud, money laundering, and other unlawful activity
• Improve our services through aggregated analytics

5. Data Sharing

We share your data only where necessary and with the following categories of recipients:

• Credit reference agencies: for credit assessment and reporting
• Fraud prevention agencies: for identity verification and fraud detection
• Regulators and authorities: when required by law
• Service providers: cloud hosting, secure document storage, payment processing
• Professional advisors: auditors, lawyers, consultants under confidentiality

We do not sell your personal data. We do not share your data with third parties for their own marketing purposes.

6. International Transfers

Where personal data is transferred outside the European Economic Area, we ensure appropriate safeguards are in place, including Standard Contractual Clauses approved by the European Commission and, where required, supplementary measures.

7. Data Retention

We retain personal data for as long as necessary to fulfil the purposes for which it was collected, including:

• Application data: 7 years from the date of application or facility closure
• KYC documents: 5 years from the end of the business relationship (regulatory requirement)
• Financial records: 7 years (statutory retention)
• Marketing data: until you withdraw consent

8. Your Rights Under GDPR

You have the right to:

• Access the personal data we hold about you
• Rectify inaccurate or incomplete data
• Erase your data where legal requirements allow
• Restrict processing in certain circumstances
• Object to processing based on legitimate interests
• Data portability for data you provided to us
• Withdraw consent at any time for consent-based processing
• Lodge a complaint with your national supervisory authority

To exercise any of these rights, contact us at support@aldwycheuropeancapital.com.

9. Security

We implement technical and organisational security measures to protect your data, including:

• TLS 1.3 encryption for all data in transit
• AES-256 encryption for data at rest
• Role-based access controls and audit logging
• Regular security testing and vulnerability management
• Staff training on data protection and confidentiality
• Multi-factor authentication for system access

10. Cookies

Our platform uses cookies and similar technologies to operate essential functions, remember your preferences, and analyse platform usage. Essential cookies are always active; optional cookies require your consent. You can manage cookie preferences through your browser settings at any time.

11. Automated Decision-Making

Some elements of our credit assessment may involve automated processing, including automated scoring. You have the right to request human review of any decision that significantly affects you. Final lending decisions are always reviewed by our underwriting team.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be notified to you by email or via prominent notice on the platform. Where required, we will obtain your fresh consent for new uses of your data.

13. Contact Us

For any privacy-related queries or to exercise your rights, please contact our Data Protection team at support@aldwycheuropeancapital.com or via our Support Centre.