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Why does this Policy exist?

Intelligent Funding Ltd is committed to protecting your personal data and privacy rights.

For the purposes of applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, Your company name acts as both a Data Controller and a Data Processor, depending on the nature of the activity:

• As a Data Controller, we determine the purposes and means of processing your personal data.

• As a Data Processor, we may process data on behalf of third-party organisations, such as finance providers, in line with their instructions and applicable agreements.

This Privacy Notice explains how we collect, use, disclose, and safeguard your personal information in both roles.

This notice should be read together with any other privacy or fair processing notices we provide on specific occasions. It supplements but does not override those other notices.

What does this Policy cover?

This policy outlines our handling of personal information that we collect from you directly or indirectly (such as through our website, over the phone, in person, or from third parties), including:

What personal data we collect;
How and why we collect it;
How we use it;
Your rights and how to exercise them.

If you have any questions, please contact us at compliance@thembn.co.uk or via the details on our Contact Us page.

When We May Update This Policy

We may update this policy to reflect:

Improvements to our services or systems;
Changes in applicable law or regulation;
Clarifications to existing wording;
The need to correct outdated or inaccurate information.

How is your personal data collected?

We collect personal data through:

Forms and applications;
Telephone and email communication;
Our website and cookies;
Credit reference and fraud prevention agencies;
Public sources (e.g., Companies House, Electoral Register);
Third parties acting on your behalf.

Providing Personal Data About Others

You must not provide us with personal data about someone else without first obtaining their clear and informed consent.

If you do provide such information, you confirm that the individual has:

Authorised you to act on their behalf;
Consented to the provision of their data to the Company;
Consented to the processing of their data;
Agreed to receive data protection notices through you;
Consented to any potential transfer of their data outside the UK/EEA, if required.

Information about others—such as financial associates—may be considered alongside your own personal data when assessing applications or eligibility for services.

Call Recording

We may record telephone calls for the following reasons:

To enhance security;
To resolve complaints;
For staff training and quality assurance purposes;
To improve our service standards.

Our website uses cookies and tracking technologies to understand usage and improve performance.

You can manage or delete cookies via your browser settings. For more information, visit www.allaboutcookies.org

Please note that restricting cookies may impact your browsing experience.

What type of personal information do we collect?

Depending on the context, we may collect:

Name, title, gender, and contact information;
Date of birth and National Insurance number;
Marital and residential status;
Employment and income details;
Financial, banking, and credit information;
Insurance, mortgage, and investment history;
Medical or health information (special category data);
Marketing and communication preferences;
Data from credit reference and fraud prevention agencies;
Information you provide in surveys or social media interactions.

We may also collect publicly available data (e.g. court judgments, bankruptcy records).

Special Category Personal Data

Where relevant (e.g., in relation to insurance), we may collect sensitive health information. We only process such data where necessary and with your explicit consent, in accordance with UK GDPR.

Information on Special Category Data and Criminal Disclosures must be capable of being exchanged freely between intermediaries such as finance providers, to enable customers to secure the important protection cover that their needs require.

If you fail to provide personal data

If you do not provide required personal data, we may be unable to provide the services you request. We will notify you at the time if this is the case.

How we use your personal data

We use your personal data under the following lawful bases:

Consent – where you have given clear permission.
Contract – to fulfil a contract with you or take steps before entering one.
Legal obligation – to comply with legal or regulatory duties.
Legitimate interests – to pursue our business interests, provided they do not override your rights.

We may use your data to:

Assess your application and creditworthiness;
Provide or arrange financial products and services;
Communicate with you;
Carry out compliance and regulatory checks;
Improve our services;
Provide support, training, and audits;
Carry out marketing, with your consent;
Analyse customer usage trends;
Visit your premises (as needed for our services).

This list is not intended to be exhaustive and may be updated from time to time as business needs and legal requirements dictate. Some of the personal information that we maintain will be kept in

paper files, while other personal information will be included in computerised files and electronic databases.

Credit Reference Agencies (CRAs)

To assess finance applications, we may share your data with CRAs. They may return public and private data about your credit history, which funders may use to:

Assess affordability and creditworthiness;
Confirm your identity;
Prevent fraud and money laundering;
Recover debts;
Manage your account(s).

For more information, visit:

https://www.experian.co.uk/legal/crain/

https://www.equifax.co.uk/crain/

Automated Processing / Automated Decision-Making

Some funders use automated scoring to make decisions. You will not be subject to decisions with legal effects solely based on automated processing unless:

It is necessary to perform a contract;
You have given explicit consent;
We have taken steps to safeguard your rights.

Does the Company share my personal information with third parties?

We may share your data with:

Members of our corporate group;
Financial institutions or funders;
Professional advisers or legal representatives;
IT, compliance, data storage, or call centre service providers;
Regulators or law enforcement where legally required.

We do not sell your personal data. In the event of a sale or restructure of our business, your data may be shared with prospective buyers or advisors.

International Data Transfers

We do not transfer your personal data outside the UK or EEA unless required and lawful safeguards are in place.

How long do we keep your personal information for?

We retain your data only as long as necessary for:

Legal and contractual obligations;
Handling enquiries or complaints;
Establishing, exercising, or defending legal claims.

Typical retention periods:

Enquiries – up to 3 years after contact.
Contracts – minimum 6 years post-termination.
Regulatory obligations – as required by law.

Managing your marketing preferences

With your consent, we may send you marketing communications about products, offers, or services by phone, email, post, or SMS.

You can opt out at any time by:

Clicking “unsubscribe” in marketing emails
Emailing Enquiries@intelligent-funding.co.uk
Calling 01937 413888

We may still contact you with important information about services you’ve requested or signed up for.

Your rights to access your personal information

You have the right to:

Be informed about the use of your personal data;
Request a copy of your personal data;
Request correction of inaccurate data;
Request erasure of data (in certain circumstances);
Restrict or object to processing;
Request data portability;
Object to direct marketing;
Not be subject to automated decisions without meaningful human involvement.

To exercise your rights, contact us at:

Intelligent Funding Ltd, Audby House, Audby Lane, Wetherby LS22 7FD 01937 418 333

Enquiries@intelligent-funding.co.uk

We may need to verify your identity before fulfilling your request.

Your right to complain to the data privacy supervisory authority

If you are dissatisfied with how we handle your personal data, you have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO), our ICO registration number ICO number ZB920836

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline: 0303 123 1113

Email: casework@ico.org.uk

Website: https://ico.org.uk/global/contact-us/

Terms of Business

By asking Us to quote for, apply or arrange Broker Services you acknowledge and agree they will be processed by Us in accordance with these terms.

1. SCOPE

Intelligent Funding Ltd is an Appointed Representative of Moorgate Finance Limited T/A MBN®, which is Authorised and Regulated by the Financial Conduct Authority, firm reference number 662419. Our firm reference number is 1037532. Intelligent Funding Ltd is an authorised Credit Broker and not a Lender. If you require any further information about the extent of our authorisation or regulation by the FCA you can check via https://register.fca.org.uk/s/.

We can introduce you to a panel of lenders.

Whichever lender you choose we receive commission from them (either a fixed fee or fixed % of the amount you borrow) and different lenders pay different rates.

For certain lenders, we do have influence over the interest rate, and this can impact the amount you pay under the agreement.

Whichever lender you choose we receive commission from them, and this is included in the amount you pay. We do not charge a fee to you for our brokering service.

The commission is only payable by the Lender to us if you decide to accept the Finance Offer and proceed to enter into a Finance Agreement.

Where such an agreement exists via an introduction, the introducer (who may or may not be the supplier of the related assets) of the introduction will be paid an introductory commission.

Further details regarding the nature of Commission, existence, calculation and amount of commission will be provided to you throughout your customer journey, this information will include any fees from the lender that we the broker may benefit from.

We agree to submit Lending Proposals to Lenders on behalf of you in order to procure so far as it can do so from such Lenders an offer of finance to you (“Broker Services”).

We offer a wide range of commercial financial products including: Leasing and Asset, Commercial Mortgages, Property Development finance, Cashflow Finance, etc.

We will source finance from the market that are suitable to the requirements you disclose to us.

We will advise and make a recommendation for you after we have assessed your needs.

We are not an independent financial advisor. We may advise you on the most suitable products, subject to your personal circumstances, though this may not be the full range available. You are not obliged to take our advice or recommendation and you should investigate other options before deciding whether to enter into a finance agreement.

When the preferred option has been agreed, we will provide you with information about the Finance Offer and the Lender to ensure you understand your responsibilities and commitments, before proceeding.

You wish to engage us for such Broker Services and are willing for the Lender to pay to us commission in relation to the provision of such Broker Services.

We conduct ourselves in line with the relevant Financial Conduct Authority (FCA) guidelines at the time of provision of services. We do not accept liability for retrospective changes to law or regulation.

2. DEFINITIONS

Advance Amount: The amount to be advanced to you by way of credit under a Finance Agreement following your acceptance of a Finance Offer and in relation to a Finance Agreement which is a hire agreement the total amount of the rentals due from you to the Lender under the Finance Agreement

Agreement: This document together with a Confirmation of Instructions and any other schedules and any other documents specifically referred to herein as being incorporated within this agreement between the Parties and as may be updated or amended from time to time in accordance with the terms of this agreement.

Broker Services: Our agreement to submit Lending Proposals to Lenders on behalf of you in order to procure so far as it can do so from such Lenders an offer of finance to you

Code of Practice: The Code of Practice of the regulators as may be amended or updated from time to time

Commission: A sum of money that is paid upon completion of a task from a Lender

Completion: The date of your Finance Agreement with a Lender

Credit Search: Search carried out on your credit report to understand your financial behaviour.

Credit History: Record of your responsible repayment of debts.

Credit File: List of credit arrangements including bank and credit card accounts, loan agreements and/or utility company payment records.

Data Protection: The UK Data Protection Legislation relating to personal data and all other legislation and regulatory requirements in force from time to time which apply to a party relating to the use of personal data (including, without limitation, the privacy of electronic communications and the guidance and codes of practice issued by the relevant data protection or supervisory authority and applicable to a party

FCA: Financial Conduct Authority – the conduct regulator for financial services firms and financial markets in the UK

Fees: Appraisal, Broker Arrangement Fee or Renewal Fee as the case may be

Finance Agreement: A loan, credit or hire agreement of any type which is entered by you with a Lender following the provision by us of the Broker Services

Finance Offer: An offer by the Lender to enter into a Finance Agreement with you including where such an offer is conditional or unconditional or a replacement of any Finance Offer previously made

Lender: Any creditor or owner to whom we have presented a Lending Proposal

Lending Proposal: A proposal presented by us to the Lender containing details of you and your finance needs

ML Regulations: Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 as may be updated or amended from time to time and any other relevant Directives, legislation or regulations which may be in place from time to time to prevent financial crime including the Bribery Act 2010.

Parties: Us the Broker and You the Client

Permitted Recipients: The Parties to this Agreement

Privacy Notice: A notice to you as required by UK Data Protection Legislation informing you how your Personal Data will be dealt with and informing you of their rights under UK Data Protection Legislation as may be amended or updated from time to time

Regulated Agreement: Agreement between two parties, one of whom (the debtor) is an individual, and the other of whom (the creditor) is "any other person", in which the creditor provides the debtor with credit not exceeding £25,000

UK Data Protection: All applicable data protection and privacy legislation in force from time to time in the UK including the UK General Data Protection Regulation; the Data Protection Act 2018; the Privacy and Electronic Communications Directive (2002/58/EC) (as updated by Directive 2009/136/EC) and the Privacy and Electronic Communications Regulations 2003 (SI 2003/2426) as amended)

We, Our, Us: Intelligent Funding Ltd registered in England and Wales (Company No. 16417253)

You, Your: The Client

3. INTERPRETATION

3.1. A person includes a natural person, corporate or unincorporated body (whether or not having separate legal personality).

3.2. A reference to a Party includes third parties to which it has outsourced activities, agents, successors and permitted assigns.

3.3. A reference to a statute or statutory provision is a reference to it as amended or re-enacted or updated. A reference to a statute or statutory provision includes all subordinate legislation made under that statute or statutory provision.

3.4. Any words following the terms ‘including, include, in particular, for example’ or any similar expression shall be construed as illustrative and shall not limit the sense of the words, description, definition, phrase or term preceding those terms.

3.5. A reference to writing or written includes fax and email.

3.6. References to clauses, schedules, appendices are, unless specified otherwise, references to clauses found in, schedules attached to or appendices attached to a Finance Agreement.

3.7. Data Controller, Data Processor, Data Subject, European Economic Area, Personal Data, Sensitive Personal Data and Processing shall have the same meanings as in the Data Protection Legislation and Processed and Process shall be construed in accordance with the definition of Processing in such Data Protection Legislation.

4. DOCUMENTATION FEES

4.1. Document and Option to Purchase Fees are charged by all finance companies but vary from Lender to Lender, details will be disclosed within your Finance Offer.

5. EARLY SETTLEMENT

5.1. All agreements are subject to early settlement charges, these differ depending on whether the agreement is regulated or non-regulated. Full details can be found within each lenders Terms & Conditions.

6. YOUR REPRESENTATIONS AND ACKNOWLEDGEMENTS

6.1. You represent and acknowledge that: 6.1.1. you have been advised by us to seek independent advice before signing any Financial Agreement;

6.1.2. we source Lending Proposals from a panel of lenders who will be supplied upon request

6.1.3. you are aware that Lenders will undertake a credit search to assess your credit history and that any search may appear on your credit file.

6.1.4. you have the authorisation to give consent to search, automate processing and marketing of all parties both individual and corporate associated in relation to the finance application and that the authorisation supersedes any previous permissions.

6.1.5. you are aware we will receive commission from a Lender for introducing you to them and you have no objections to us receiving this amount.

6.1.6. if you wish to receive further information concerning commission paid to us by the lender you can submit your request in writing;

6.1.7. you have read the terms and conditions of this Agreement and confirm that you wish to proceed to engage the Broker Services.

6.1.8. you testify that any email address or mobile number provided for the signatory on any documentation is accessible only by the signatory.

6.2. You agree to act with the utmost good faith in the provision of information to us to enable us to accurately complete the Lending Proposal. In addition, you acknowledge that: 6.2.1. the Lender is likely to make a Finance Offer relying on the information which is submitted to the Lender in the Lending Proposal by us, such information being given to us by you;

6.2.2. should such information be false, it may render any Finance Offer void and any Finance Agreement entered terminated;

6.2.3. you will not withhold any information from us which you know, or ought reasonably to know, would affect the Lender’s view of the Lending Proposal or of you themselves.

6.3. The duty set out in clause 8.1 is continuous and applies to all the information you provide, whether we have asked for it or whether you have provided it voluntarily.

6.4. You agree to take all reasonable steps and use all reasonable endeavours to comply with and satisfy any condition imposed by the Lender.

6.5. You agree to notify us at any time you intend to appoint an additional or alternative broker or intermediary to obtain an offer of finance for you whereupon we will be entitled, but not obliged, to terminate this Agreement forthwith.

7. RENEWAL OF THIS AGREEMENT

7.1. This Agreement will remain ongoing throughout your relationship with us or until such point we receive notice of termination.

8. TERMINATION OF THIS AGREEMENT

8.1. The Parties may terminate this Agreement by giving 30 days written notice to the other Party.

8.2. We may terminate this Agreement immediately at its reasonable discretion if you: 8.2.1. have provided false, fraudulent or misleading information to us either in the Confirmation of Instructions or at any other point in your communications with us or any Lender;

8.2.2. have breached any of the material terms of this Agreement;

8.2.3. have committed a minor breach of this Agreement but have failed to remedy such breach within 10 days of it occurring;

8.2.4. have been made bankrupt or entered into any arrangements with your creditors;

8.2.5. died;

8.2.6. refuse to accept on three or more occasions any reasonable Finance Offers which satisfy the Confirmation of Instructions;

8.2.7. breach the ML Regulations or any other financial crime legislation or regulation.

9. DATA PROTECTION

00.PL.01_13_0725

9.1. We will comply with all applicable requirements of the Data Protection Legislation. This clause is in addition to and does not relieve, remove or replace our obligations or rights under the Data Protection Legislation.

9.2. We acknowledge that for the purposes of the UK Data Protection Legislation when we are carrying out the Broker Services we are doing so as a Controller of your Personal Data and will act accordingly.

9.3. We agree that when sharing any Personal Data with a Lender we will ensure that the Lender has in place all appropriate technical and organisational measures to protect against unauthorised or unlawful handling of your Personal Data.

9.4. We will ensure that all our personnel who have access to and/or handle Personal Data keep the Personal Data confidential save to the extent that it is necessary to share such Personal Data in order to perform the Broker Services.

9.5. We agree that we will not transfer any of your Personal Data outside of the UK Economic Area.

9.6. We will maintain complete and accurate records and information to ensure that we can demonstrate our compliance with the Data Protection Legislation.

9.7. On termination of this Agreement for any reason we shall as soon as reasonably practicably return or destroy all Personal Data which we hold in relation to you save where it is legally obliged otherwise to do so.

9.8. We will provide you with a Privacy Notice which complies with the UK Data Protection Legislation and which advises you of your rights in relation to your Personal Data.

9.9. Our Privacy & Data Protection policy can be located here Privacy Policy | Intelligent Vehicle

10. MONEY LAUNDERING

10.1. You agree to provide us with any documents we and/or a Lender requires in order to comply with the requirements of the ML Regulations including any identity documents.

10.2. You agree to comply with any other financial crime requirements that we, our finance partner or the Lender or any relevant authority or regulator may require from time to time.

11. AMENDMENTS & VARIATIONS TO THIS AGREEMENT

11.1. Any amendment or variation to this Agreement proposed by us shall take effect on the date specified unless in the meantime you notify us of any objection to the amendment or variation or requests an extension of time before such amendment or variation take effect. Thereafter any such amendment or variation will only take effect when the Parties have agreed it in writing.

11.2. Any amendment or variation to this Agreement proposed by you shall take effect only when accepted by us in writing.

12. ASSIGNMENT & THIRD-PARTY RIGHTS

12.1. Pursuant to the Contracts (Rights of Third Parties) Act 1999 no person shall be entitled to enforce the terms of this Agreement other than the Parties.

12.2. We may assign, sub-contract, novate, mortgage, declare a trust in or otherwise transfer or deal within any manner this Agreement or any of its rights or obligations under this Agreement and shall give reasonable notice to you upon any such occurrence. You may not make any assignment, sub-contract, novation, mortgage, trust or otherwise transfer your rights or obligations under this Agreement.

13. MISCELLANEOUS

13.1. The invalidity or unenforceability of any provision in this Agreement shall not affect the validity or enforceability of any other provision and any invalid or unenforceable provision will be deemed to be severed from this Agreement.

13.2. The release or the failure to enforce any of the provisions in this Agreement by us at any time or for any period will not release or exonerate or in any way affect the liability of you or constitute a waiver of any term of this Agreement.

13.3. Headings are inserted for reference only and shall not affect the construction of this Agreement.

13.4. This Agreement and any Schedules hereto constitute the entire agreement between the Parties.

13.5. We do not act as agent for you and nothing contained within this Agreement shall constitute, or be deemed to constitute, partnership or joint venture between the Parties hereto.

13.6. We will maintain professional indemnity insurance cover in respect of its business with and on standard terms offered by reputable insurers.

13.7. If we hold your money, it will be kept in a separate designated client account for the benefit of you.

13.8. You accept that we shall have no liability for any economic loss (whether direct, indirect or consequential) insofar as it relates in any way to loss of business, loss of Client data, interruption of business or loss of

profits or goodwill because of the manner of performance by us of the Broker Services or any obligations arising under this Agreement. This exclusion of liability will not, however, otherwise affect any statutory rights of yours.

13.9. The Agreement shall be construed in accordance with English Law and the Parties irrevocably agree to submit to the exclusive jurisdiction of the English Courts.

14. COMPLAINTS

If you’re not completely happy with our service at Intelligent Funding Ltd, we want to assure you that we take all complaints seriously., we always encourage our customers to tell us about a complaint, so that we can put matters right.

To make a complaint, you can:

• Call us on 01937 413 888. We are available from 9am to 5pm Monday to Friday (please note that we are closed on all UK public and bank holidays).

• Email us at enquiries@intelligent-funding.co.uk or directly to our Principal complaints@thembn.co.uk

• Write to: Intelligent Funding Ltd Audby House, Audby Lan, Wetherby LS22 7FD

We will notify our Principal Moorgate Finance Ltd who will aim to resolve your complaint.

If you cannot settle your complaint with us, you may be entitled to refer it to the Financial Ombudsman Service. Address:

Financial Ombudsman Service,

Exchange Tower,

London,

E14 9SR.

Contact: 0800 0234567, 0300 1239123.

Website: www.financial-ombudsman.org.uk