Privacy policy.
This Privacy Policy explains how we may collect, use, and store information you provide, and outlines your rights regarding your data. We encourage you to read it to understand how we handle information and the steps we take to protect it.
If you have any questions about this Privacy Policy or would like additional information, you are welcome to contact us.
1. Important information and who we are
Caply Group Ltd, a company registered in England and Wales (company number 17030689) whose registered office is at 119-121 Brent Street, London, England, NW4 2DX is the data controller and responsible for your personal data (hereafter referred to as "we", "us" or "our").
This Privacy Policy (“Policy”) sets out how we collect, use and protect personal data of individuals (“you”, “your”), including any personal data you may provide when you visit https://www.caply.co.uk/ (our “Platform”), engage us to provide our services or sign up for our marketing.
Our Platform and services are not intended for minors and we do not knowingly collect personal data relating to minors or children.
If you have any questions about this Policy, including any requests to exercise your legal rights, please contact us using the information set out in the contact details section (section 12).
2. The types of personal data we collect about you
Personal data means any information about an individual from which that person can be identified.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data: includes first name, last name and position or job title.
Contact Data: includes email address and telephone and or mobile numbers.
Transaction Data: includes reports from Credit Reference Agencies (CRAs) and Fraud Prevention Agencies (FPAs), details about services we have provided you.
Banking Data: includes information about you contained within bank statements provided by your company.
Communications Data: includes details we collect when you contact us (including when you submit enquiries), records of our correspondence with you (including in relation to our services and or any requests, queries or complaints you may have).
Technical Data: may include internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access our Platform.
Usage Data: includes information about how you interact with and use our Platform and services.
Marketing Data: includes your interests, feedback, survey responses, preferences in receiving marketing from us and our third parties and your communication preferences in relation to marketing.
We may also collect personal data through monitoring and recording of phone calls.
We may also collect, use and share aggregated data such as statistical data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific feature of our Platform in order to analyse general trends in how users are interacting with our Platform to help improve the Platform and our service offering.
3. How we collect your personal data
We use different methods to collect personal data from and about you including through:
(a)
Your interactions with us. You may give us your personal data by:
filling in online forms;
inputting your personal data on our Platform; and or
corresponding with us by post, phone, email or otherwise.
(b)
Third parties. We may receive personal data about you from various third parties including:
your employer or organisation. Disclosure by your employer or organisation will be subject to their privacy policies. If you have concerns regarding their disclosure of your personal data to us, you should contact your employer or organisation;
search information providers such as CRAs, FPAs, Companies House;
analytics providers such as Google;
advertising networks such as Facebook and Instagram.
(c)
Automated technologies or interactions. As you interact with our Platform, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, tracking pixels, server logs, and other similar technologies. This includes technologies provided by third-party advertising and analytics partners such as Google Ads and Meta (Facebook). These tools allow us to analyse website traffic, measure advertising performance, and deliver relevant advertising to users who have previously visited our Platform.
4. How we use your personal data
4.1. Legal basis
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
Performance of a contract with you or others involving you: where we need to perform the contract we are about to enter into or have entered into with your organisation in relation to our services.
Legitimate interests: we may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Legal obligation: we may use your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Consent: we rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to our marketing.
4.2. Purposes for which we will use your personal data
We have set out below, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate:
(a)
Purpose and use: to register you as a new client or when you submit an enquiry for our services.
Types of personal data:
Identity Data
Contact Data
Communications Data
Legal basis
Performance of a contract with youor others involving you
Legitimate interests i.e. the proper administration of our business.
(b)
Purpose and use: to provide our services to you.
Types of personal data:
Identity Data
Contact Data
Transaction Data
Banking Data
Communications Data
Legal basis
Performance of a contract with you or others involving you
Necessary for our legitimate interests i.e. proper administration of our business
Necessary to comply with a legal obligation e.g. to verify information you provide us, to prevent fraud and financial crime
Consent – we rely on consent provided by an authorised person within your organisation to share your Banking Data with credit introducers, services or lenders.
(c)
Purpose and use: recording and monitoring calls.
Types of personal data
Identity Data
Contact Data
Communications Data
Legal basis
Necessary for our legitimate interests i.e. to properly administer our business, improve the quality of our services and resolve issues.
(d)
Purpose and use: to manage our relationship with you which will include:
Notifying you about changes to our terms and conditions or this Policy
Dealing with your requests, complaints and queries.
Types of personal data
Identity Data
Contact Data
Communications Data
Legal basis
Performance of a contract with you or others involving you
Necessary to comply with a legal obligation
Necessary for our legitimate interests i.e. to keep our records updated and manage our relationship with you.
(e)
Purpose and use: to administer and protect our business and Platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
Types of personal data
Identity Data
Contact Data
Technical Data
Legal basis
Necessary for our legitimate interests i.e. to properly run our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise.
Necessary to comply with a legal obligation.
(f)
Purpose and use: to use data analytics to improve our Platform, products and services, client relationships and experiences and to measure the effectiveness of our communications and marketing.
Types of personal data
Technical Data
Usage Data
Legal basis
Necessary for our legitimate interests i.e. to define types of clients for our products and services, to keep our Platform updated and relevant, to develop our business and to inform our marketing strategy.
(g)
Purpose and use: to:
Collect feedback on our products and services;
send you relevant marketing communications;
make personalised suggestions and recommendations to you about products or services that may be of interest to you;
carry out market research through your voluntary participation in surveys.
Types of personal data
Identity Data
Contact Data
Technical Data
Usage Data
Marketing Data
Legal basis
Necessary for our legitimate interests to carry out direct marketing, develop our products and services and grow our business (please see section 4.4 to opt out of direct marketing).
4.3. Direct marketing to you
When you submit an enquiry or register an account on our Platform when your personal data is collected, you will be asked to indicate your preferences for receiving direct marketing communications from us via email or SMS or telephone or post. You may also receive marketing communications from us if you have requested information from us or engaged us to provide our products and services and you have not opted out of receiving the marketing.
Subject to (a) above, we may also analyse your Identity, Contact, Technical, and Usage Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.
4.4 Third-party marketing
We do not share your personal data with third parties for marketing. If we intend to do so, we will get your express consent before we share your personal data with any third party for their own direct marketing purposes.
4.5. Opting out of marketing
You can ask us to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us using the details set out in section 12.
If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to the products and services you have engaged us to provide, updates to our Terms and Conditions, checking that your contact details are correct.
5. Disclosures of your personal data
We may share your personal data where necessary with the parties set out below:
credit introducers, servicers and lenders;
CRAs and or FPAs;
our third-party services providers, agents, or sub-contractors for the purposes of providing parts of our services to you on our behalf (e.g. to host our Platform, our CRM software, to provide us with accounting services, social media channels to promote our content and services, to send you marketing communications);
in the event that we sell or buy any business or assets, in which case we may share your personal data to the prospective seller or buyer of such business or assets; or if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our clients and potential clients will be one of the transferred assets. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Policy;
if 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 or other agreements; and
to protect the rights, property or safety of Caply Group Ltd, the Platform, our users and any third party we have engaged to provide our Platform and services.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
CRAs and FPAs may use your personal data in ways we are not responsible. You should refer to the relevant agency’s privacy policy to understand how they will use and store your personal data.
Credit introducers and prospective lenders will act as data controllers of any personal data shared with them. You should refer to the relevant credit introducer or lender’s privacy policy to understand how they will use and store your personal data.
6. International transfers
We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.
Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that we enter into the appropriate contractual agreements including specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK. To obtain a copy of these contractual safeguards, please contact us using the contact details in section 12.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our clients (including Contact, Identity, and Transaction Data) for seven years after they cease being customers for legal, tax, regulatory purposes.
In some circumstances you can ask us to delete your data: see paragraph 9 below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
You have a number of rights under data protection laws in relation to your personal data.
9.1. You have the right to:
Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see section 4.5 for details of how to object to receiving direct marketing communications).
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 4.1 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
if you want us to establish the data's accuracy;
where our use of the data is unlawful but you do not want us to erase it;
where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
If you wish to exercise any of the rights set out above, please contact us using the details in section 12.
9.2. No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
9.3. What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
9.4. Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. Changes to this Policy and your duty to inform us of changes
We keep this Policy under regular review. Any changes we make to this Policy in the future will be notified to you and made available via our Platform. You should ensure you are happy with any changes to this Policy and your continued use of our Platform and services shall be deemed as your acceptance of the varied policy.
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 (for example a new address or email address) using the contact details below or by updating your personal details on our Platform.
11. Third-party links
Our Platform may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Platform, we encourage you to read the privacy policy of every website you visit.
12. Contact details
If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us by email at:
Email address: support@caply.co.uk
We are registered with the Information Commissioner’s Office (ICO), our registration number is ZC095981.
13. Complaints
We hope that we can resolve any query or concern you may wish to raise about our use of your personal data, and we would therefore request that you contact us in the first instance with your queries and concerns. However, if you are not satisfied with us or the manner in which we have handled your queries and or concerns or your personal data, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues whose details can be found at www.ico.org.uk.
This Privacy Policy was last updated on: March 2026
Thank you for taking the time to review our policies. You can read our Terms & Conditions to learn more about how we operate, or return to the homepage to continue exploring our services.