Customer Privacy Notice – TFC Commercial Ltd

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PRIVACY NOTICE – TFC COMMERCIAL LTD

Effective Date: 8 December 2025 (supersedes any previous versions)

ICO Registration Reference: ZB985008

This Privacy Notice explains how TFC Commercial Ltd (“we” / “our”) uses your personal data, why we collect it, and your rights under UK data protection law.

Who We Are

TFC Commercial Ltd is a commercial finance broker (Company No. 16667149), registered at 7 Eden Park, Effingham Road, Copthorne, Crawley, West Sussex, RH10 3HZ. We are not FCA authorised and do not offer regulated financial advice. You can contact us at compliance@tfccommercial.co.uk or on +44 7359 658043.

Why We Process Your Data

We process personal data to provide commercial finance services, respond to enquiries, and meet legal obligations. Our lawful bases include:

• Contractual necessity – to deliver our services to you (Article 6(1)(b) UK GDPR)

• Legal obligation – for anti-money laundering and compliance checks (Article 6(1)(c))

• Legitimate interests – for service improvement, communications, call recording, and debt recovery (Article 6(1)(f))

• Consent – for marketing and optional communications (Article 6(1)(a))

How We Collect Your Data

We collect personal data in the following ways:

• Directly from you – when you contact us, complete forms, provide documents, or communicate with us by phone, email, or in person

• From third parties – such as introducers, lenders, credit reference agencies, or publicly available sources (e.g. Companies House) where relevant to your enquiry or application

What We Collect

We may collect:

• Your name, address, email, phone number, date of birth, nationality

• Financial details (e.g. income, bank statements, credit history)

• Identification documents for compliance

• Communications with us (including emails, messages, and telephone calls, which may be recorded and transcribed for training, monitoring, and compliance purposes)

• Website usage data via cookies (see below)

Call Recording & Transcription

We may record telephone calls and use transcription software to create written records of conversations. This is done for training, quality assurance, and compliance monitoring purposes. The lawful basis for this processing is our legitimate interests (Article 6(1)(f) UK GDPR) in improving our service and ensuring accurate records. You will be informed at the start of any call that may be recorded. Transcripts are stored securely and retained in line with our data retention policy.

Sharing Your Data

We share your data only when necessary:

• With lenders to arrange finance (Article 6(1)(b))

• With compliance and IT service providers under contract (Article 28 UK GDPR)

• With law enforcement or regulators if legally required (Article 6(1)(c))

• With debt recovery agents if invoices remain unpaid (Article 6(1)(f))

We do not sell or trade your data.

International Transfers

Some data may be stored or processed outside the UK. Where this occurs, we ensure appropriate safeguards are in place under Article 46 UK GDPR (e.g. adequacy decisions or standard contractual clauses).

Retention

We retain personal data for up to 5 years after our relationship ends, or longer if required by law. Enquiry data is kept for up to 2 years. Call recordings and transcripts are retained for up to 12 months unless required longer for compliance or dispute resolution purposes. You may request deletion sooner, subject to legal exceptions.

Security

We use secure systems, encrypted communications, and access controls to protect your data. Our staff are trained in data protection and confidentiality.

Your Rights

You have the right to:

• Access your data

• Request correction or deletion

• Restrict or object to processing

• Withdraw consent (where applicable)

• Withdraw from marketing communications at any time

• Lodge a complaint with the Information Commissioner’s Office (ICO)

To exercise your rights, contact us at compliance@tfccommercial.co.uk.

If you are dissatisfied with how we handle your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO):

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Telephone: 0303 123 1113

Website: www.ico.org.uk

Cookies

Our website uses essential and analytics cookies. You can manage preferences via your browser. We do not use advertising or tracking cookies.

TFC Commercial Ltd, 7 Eden Park, Effingham Road, Copthorne, Crawley, West Sussex, RH10 3HZ

Company Number: 16667149 – TFC Commercial Ltd is a broker, not a lender.