Privacy Policy

1. Who we are

Breeze Capital is a privately funded short term lender. We provide residential and commercial bridging finance, refurbishment finance and ground up property development finance, secured against residential, commercial and semi-commercial property in England and Wales, and bridging finance in Scotland. We lend on investment property only.

Two companies are involved in our lending, and both are “data controllers” of your personal data. This means they decide together what personal data is collected about you, why it is used, and how it is looked after.

How the two companies work together

Because Breeze Capital Limited and Breeze Finance 1 Limited decide together how your personal data is used, they are “joint controllers” under Article 26 of the UK GDPR. The law requires us to tell you the essence of the arrangement between them, which is this:

• You can contact either company. You may exercise any of your rights, or make a complaint, against either one. You do not need to work out which company holds your data, and you will not be redirected.
• There is a single point of contact for both. Our Data Protection Officer handles rights requests and complaints on behalf of both companies — see section 2.
• Breeze Capital Limited takes the lead on providing this Privacy Policy, handling your requests and complaints, keeping your data secure, and applying our retention periods. Breeze Finance 1 Limited approves the lending decision and the terms and holds the security.
• Both companies remain responsible. This division of work does not limit your rights, and either company may be held accountable.
• You may complain to the Information Commissioner’s Office, or seek a remedy in the courts, against either company at any time.

Where this Privacy Policy says “we”, “us” or “Breeze Capital”, it means both companies unless we say otherwise.

Both companies are registered in England and Wales, with their registered office at Cumberland Court, 80 Mount Street, Nottingham NG1 6HH. Our contact details are:

• Address: Studio 11, Stuart House, St John’s Street, Peterborough PE1 5DD
• Email: hello@breezecapital.co.uk
• Telephone: 01244 565095

Breeze Capital is not regulated by the Financial Conduct Authority. The loans we provide are unregulated loans and unregulated mortgage contracts.

This Privacy Policy explains what personal data we collect, why we collect it, what we do with it, how long we keep it, and the rights you have in relation to it. It applies to visitors to our website, to applicants and borrowers, to guarantors, directors, shareholders and beneficial owners of applicant companies, and to our professional contacts, introducers, suppliers and their staff.

2. Data Protection Officer

If you have any questions about this Privacy Policy, about how we handle your personal data, or if you wish to exercise any of your rights, please contact our Data Protection Officer:

• Data Protection Officer: Mike Williams
• Email: mike@breezecapital.co.uk
• Address: Data Protection Officer, Breeze Capital, Studio 11, Stuart House, St John’s Street, Peterborough PE1 5DD

3. The categories of personal data we process

We may collect and process the following categories of personal data, as necessary to provide our services and meet our legal, contractual and security obligations:

• Identity data – including name, date of birth, title, username, or other identifiers.
• Contact data – including postal address, email address, telephone number.
• Account and access data – including user IDs, login details, access permissions, and authentication information.
• Professional or employment data – including job title, employer name, and business contact details.
• Financial and transactional data – including payment details, billing information, and transaction records (where applicable).
• Technical and usage data – including IP address, device information, browser type, operating system, access logs, and usage activity.
• Security and audit data – including system logs, monitoring records, access records, and incident-related information.
• Communications data – including correspondence, emails, and records of interactions with us.
• Compliance and risk data – including records required for regulatory, audit, or due diligence purposes.

In addition, where you apply for finance, we may process credit and affordability data (including credit commitments, payment history, adverse credit information and public record information), property and security data, and identity verification, anti-money laundering, sanctions and fraud prevention data.

We do not routinely seek special category data (such as health data). Where it is provided to us — for example where a health condition is relevant to an application or to a vulnerability assessment — we process it only where we have a lawful basis to do so, and we limit access to it.

4. How we collect your personal data

We collect personal data:

• directly from you, when you enquire, apply, correspond with us, or complete the enquiry form on our website at breezecapital.co.uk/contact-us;
• from brokers, introducers and other intermediaries acting on your behalf;
• from your professional advisers, such as solicitors, valuers, accountants and surveyors;
• from credit reference agencies, fraud prevention agencies and identity verification providers (see section 7);
• from publicly available sources, including Companies House, HM Land Registry, the electoral roll, insolvency registers and sanctions lists;
• automatically from your device when you use our website, through cookies and similar technologies (see section 12).

5. Why we use your personal data and our lawful bases

We only use your personal data where the law allows us to. The lawful bases we rely on are set out below.

If you do not provide the information we request, we may be unable to assist you in obtaining finance. We only collect the data we need.

6. Our legitimate interests

Where we rely on legitimate interests as our lawful basis, our legitimate interests include operating our business, fulfilling contractual obligations, ensuring system and data security, preventing fraud, supporting audit and compliance activities, and protecting TransUnion data. These interests are balanced against the rights and freedoms of individuals, with appropriate safeguards in place.

You have the right to object to processing carried out on the basis of our legitimate interests. See section 13.

7. Credit reference and affordability checks

To help us assess applications, prevent fraud, and meet our legal and regulatory obligations, we may obtain information about you from credit reference agencies (CRAs).

We obtain this information via Creditsafe, which uses its data partner TransUnion to supply consumer credit and identity data.

• Creditsafe Business Solutions Limited is authorised and regulated by the Financial Conduct Authority. FCA Firm Reference Number: 742313
• TransUnion International UK Limited is authorised and regulated by the Financial Conduct Authority. FCA Firm Reference Number: 737740

The information we receive may include data relating to your identity, credit commitments, payment history, and public record information. This data is used solely for legitimate business purposes, including creditworthiness assessment, identity verification, and fraud prevention, in accordance with applicable data protection laws.

Further information about how Creditsafe and TransUnion process your personal data can be found in their respective privacy notices:

• Creditsafe Privacy / Transparency Notice: https://www.creditsafe.com/gb/en/legal/transparency-notice-customer-supplier.html
• TransUnion CRAIN (Credit Reference Agency Information Notice): https://www.transunion.co.uk/legal/privacy-centre/pc-credit-reference

We will tell you at all stages about the searches we carry out. Some searches may leave a record on your credit file which is visible to other lenders.

8. Non-automated decision making and profiling

We may use automated systems and tools to support certain business processes, such as risk assessment, fraud prevention, affordability checks, identity verification, or record management.

These tools may analyse personal data using predefined criteria or rules to generate indicators, scores, or recommendations. However, we do not make decisions that have a legal or similarly significant effect on individuals based solely on automated processing. Any such decisions are subject to meaningful human review.

The use of these tools may influence the speed or level of review applied to an application or request, but individuals will not be subject to automatic rejection or adverse decisions without human involvement.

9. Who we share your personal data with

We may share your personal data with:

• credit reference agencies and their data partners, including Creditsafe and TransUnion;
• fraud prevention agencies and identity verification providers;
• brokers, introducers and intermediaries involved in your application;
• solicitors, valuers, surveyors, quantity surveyors, accountants and other professional advisers acting for us or for you;
• the provider of our funding facility, and its auditors and advisers — see below;
• banks, insurers and, where relevant, prospective purchasers of a loan book;
• IT, hosting, communications and document management providers who process data on our behalf under written contracts;
• regulators, law enforcement, HM Revenue & Customs, courts and other authorities where we are required or permitted to disclose;
• any party in connection with the sale, transfer or reorganisation of our business.

We require all third parties who process personal data on our behalf to act only on our instructions and to keep your data secure. We do not sell your personal data.

Our funding arrangements

Our lending is funded through a facility provided by a third-party funder. As a condition of that funding, we share information about the loans we make, including personal data relating to borrowers and the security given, with our funder and with auditors and advisers appointed by it. This is limited to what the funding arrangements require.

Our funder is a separate data controller of the information it receives. It is not acting on our behalf, and it uses that information for its own purposes in accordance with its own privacy notice. If you would like to know who currently provides our funding facility, please contact our Data Protection Officer using the details in section 2.

10. What other organisations may do

Where we transfer your data to a third party with your permission, or where a third party otherwise receives your data lawfully, that organisation will use your personal data in accordance with its own privacy policy and will be responsible for it as controller. We are not responsible for the way another organisation uses your data once it is outside our control, and we recommend you read that organisation’s privacy notice.

11. Storage, security and how long we keep your data

Where your data is held

Your personal data is processed by our staff in the United Kingdom. Information may be stored on cloud systems with servers located in the UK or the European Economic Area. Where any personal data is transferred outside the UK, we ensure an appropriate safeguard is in place, such as UK adequacy regulations or the ICO’s International Data Transfer Agreement or UK Addendum.

Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect. These include access controls, encryption in transit, system logging and monitoring, staff training, and incident response arrangements.

How long we keep your data

We keep your personal data only for as long as we need it for the purposes set out in this Privacy Policy, and to meet our legal, regulatory, accounting and reporting obligations. As a general rule:

• where you apply for finance and the application does not proceed, we keep your data for 6 years from the date the application closes;
• where a loan is entered into, we keep your data for 6 years from the date the relationship ends or the loan is fully redeemed, whichever is later;
• anti-money laundering and identity verification records are kept for 5 years from the end of the business relationship or the completion of the transaction, as required by law;
• website and marketing data is kept for up to 2 years from your last interaction with us.

We may keep data for longer where it is needed for an ongoing claim, dispute, complaint, investigation or regulatory enquiry, or where a longer period is required by law. We review our records periodically and securely delete or anonymise personal data that we no longer need.

12. Cookies and similar technologies

Cookies are small files placed on your device when you visit our website. Similar technologies, such as pixels, tags and local storage, work in comparable ways. We refer to all of these as “cookies” in this section.

We use the following categories of cookie:

• Strictly necessary cookies – necessary for the website to function, for example to manage security, load balancing and your cookie preferences. These do not require your consent because the website cannot work without them.
• Functional cookies – remember choices you make, such as your preferences, so we can provide a more personalised experience.

Your consent

You can block or delete cookies through your browser settings, and most browsers explain how to do this in their help section. Please note that browser settings alone do not withdraw the consent you have given us. Blocking cookies may prevent you from taking full advantage of the website.

13. Your rights

Under UK data protection law you have the following rights:

• The right to be informed about how we use your personal data — which is the purpose of this Privacy Policy.
• The right of access — you can ask for a copy of the personal data we hold about you.
• The right to rectification — you can ask us to correct personal data that is inaccurate or incomplete.
• The right to erasure — you can ask us to delete your personal data in certain circumstances.
• The right to restrict processing — you can ask us to limit how we use your personal data in certain circumstances.
• The right to data portability — you can ask us to provide certain data in a structured, commonly used, machine readable format.
• The right to object — you can object to processing carried out on the basis of our legitimate interests, and you can object to direct marketing at any time.
• Rights relating to automated decision making and profiling — including the right not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects. As explained in section 8, we do not make such decisions without meaningful human involvement. You may also request human intervention, express your point of view, and challenge any decision.
• The right to withdraw consent — where we rely on your consent, you can withdraw it at any time.

To exercise any of these rights, please contact our Data Protection Officer using the details in section 2. We will respond within one month. There is normally no charge. We may ask you for proof of identity before we act on a request.

Some rights are not absolute and may not apply in every case — for example, we may be required by law to keep certain records even if you ask us to delete them.

14. Complaints about how we use your personal data

If you are unhappy with how we have collected, used, shared or protected your personal data, you have the right to complain to us directly. We would encourage you to do this first, so that we have the opportunity to look into it and put things right. This right is provided under the Data (Use and Access) Act 2025. You may complain to either Breeze Capital Limited or Breeze Finance 1 Limited — the contact below covers both.

How to make a complaint

You can complain to us in any of the following ways:

• Email: mike@breezecapital.co.uk, using “Data protection complaint” as the subject line
• Online form: co.uk/contact-us
• Post: Data Protection Officer, Breeze Capital, Studio 11, Stuart House, St John’s Street, Peterborough PE1 5DD
• Telephone: 01244 565095

To help us deal with your complaint quickly, please tell us your name and contact details, what has happened and when, and what you would like us to do to put it right. You do not need to use any particular form of words, and you will not be charged for making a complaint.

If you need this information in an alternative format, or need support to make a complaint, please tell us and we will help.

What happens next

• We will acknowledge your complaint in writing within 30 days of receiving it.
• We will investigate what has happened and take any appropriate steps to resolve it.
• We will respond to you without undue delay. If our investigation is going to take longer than we expected, we will tell you why and keep you updated on our progress.
• We will explain the outcome, what we have done as a result, and what you can do if you remain unhappy.

Complaining to the Information Commissioner’s Office

You can also complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection. You are not required to complain to us first, although the ICO will usually expect you to have given us the opportunity to resolve the matter. Complaining to us does not affect your right to complain to the ICO, or your right to seek a remedy through the courts.

• Website: ico.org.uk
• Helpline: 0303 123 1113
• Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

Please note that this section covers complaints about how we handle your personal data. Complaints about our lending products or service are handled separately — please contact us using the details in section 17.

15. Links to other websites

Our website may contain links to other websites of interest. Once you have used these links to leave our site, you should note that we do not have any control over that other website. We are not responsible for the protection and privacy of any information which you provide whilst visiting such sites, and such sites are not governed by this Privacy Policy. You should exercise caution and look at the privacy statement applicable to the website in question.

16. Changes to this Privacy Policy

We keep this Privacy Policy under review and may update it from time to time to reflect changes in our practices or in the law. The date at the top of this policy shows when it was last updated. Where changes are significant, we will take reasonable steps to bring them to your attention.

17. Contact us

• Data Protection Officer: Mike Williams, mike@breezecapital.co.uk
• General enquiries: hello@breezecapital.co.uk
• Telephone: 01244 565095
• Address: Breeze Capital, Studio 11, Stuart House, St John’s Street, Peterborough PE1 5DD