1.1. These terms and conditions (together with the documents referred to in it) tells you how you may make use of our platform and website [ /] (our site). Use of our site includes accessing, browsing, or registering to use our site. 1.2. Please read these terms and conditions carefully before you start to use our site, if you decide to become a registered user of our site, you must comply with these terms and conditions. These terms and conditions should be read alongside, and are in addition to, our privacy policy (accessible online at ). We recommend that you print a copy of these for future reference. 1.3. These terms and conditions continue to apply to you however you decide to access our site (including through our site or through any mobile platform). 1.4. If you do not agree to these terms and conditions, you must not use our site.


2.1. These terms and conditions refer to the following additional terms, which also apply to your use of our site: a. Our Privacy Policy and Cookie Policy , which sets out the terms on which we process any personal data we collect from you, or that you provide to us. By using our site, you consent to such processing and you warrant that all data provided by you is accurate. b. The Loan Agreement as can be viewed in the My Accounts Welendus internet Page. 2.2. If you are using our site, agreeing to these terms and conditions or entering into a Loan Agreement on behalf of an LLP, limited company, partnership or other separate entity you warrant that you are duly authorised to act on its behalf. 2.3. You are responsible for all costs incurred by you in accessing our site. 2.4. You agree not to use our site or any information accessible on or obtained from it for the purpose of canvassing or soliciting any person or enticing any person away from us. 2.5. If any provision or part-provision of these terms and conditions is or becomes invalid, illegal or unenforceable, it shall be deemed modified to the minimum extent necessary to make it valid, legal and enforceable. If such modification is not possible, the relevant provision or part-provision shall be deemed deleted. Any modification to or deletion of a provision or part-provision under this paragraph shall not affect the validity and enforceability of the rest of these terms and conditions. 2.6. At times we may neeed to modify the terms and conditions. In such instances we will seek to notify you. 2.7. All disclaimers, indemnities and exclusions in these terms and conditions shall survive termination of these terms and conditions between us for any reason. 2.8. No single or partial exercise, or failure or delay in exercising any right, power or remedy by us shall constitute a waiver by us of, or impair or preclude any further exercise of, that or any right, power or remedy arising under these terms and conditions or otherwise. 2.9. These terms and conditions constitute the entire agreement between us and supersedes and extinguishes all previous agreements, promises, assurances, warranties, representations and understandings between them, whether written or oral, relating to its subject matter.


3.1. [ /] is a site operated by PTP Funding Limited (“We”) incorporated and registered in England and Wales with company number 09550128 whose registered office is at Level39, 1 Canada Square, Canary Wharf, London, England E14 5AB, any of our affiliates and any other entity which may, from time to time. 3.2. We are registered with the Information Commissioner (ZA284582) 3.3. We are regulated by the Financial Conduct Authority (“FCA”) (Permission No. 729328). 3.4. We are not covered by the Financial Services Compensation Scheme. 3.5. References to “You” and “Your” mean a registered user of our site and the services provided through our systems, whether as an individual or an entity which fulfils the criteria set out in paragraph 8.


4.1. The content on our site is provided for general information only. It is not intended to amount to advice on which you should rely. You must obtain professional or specialist advice before taking, or refraining from, any action on the basis of the content on our site. 4.2. Although we make reasonable efforts to update the information on our site, we make no representations, warranties or guarantees, whether express or implied, that the content on our site is accurate, complete or up-to-date. 4.3. We may revise these terms and conditions at any time by amending this page. These terms and conditions were lasted updated on . 4.4. Please check this page from time to time to take notice of any changes we made, as they are binding on you.


5.1. We may update our site from time to time, and may change the content at any time. However, please note that any of the content on our site may be out of date at any given time, and we are under no obligation to update it. 5.2. We do not guarantee that our site, or any content on it, will be free from errors or omissions.


6.1. Our site is made available free of charge. 6.2. We do not guarantee that our site, or any content on it, will always be available or be uninterrupted. Access to our site is permitted on a temporary basis. We may suspend, withdraw, discontinue or change all or any part of our site without notice. We will not be liable to you if for any reason our site is unavailable at any time or for any period. 6.3. You are responsible for making all arrangements necessary for you to have access to our site. 6.4. You are also responsible for ensuring that all persons who access our site through your internet connection are aware of these terms and conditions and other applicable terms and conditions, and that they comply with them. 6.5. The content and material available on our site is for informational purposes only and should not be regarded as an offer, solicitation, invitation, advice or recommendation to buy or sell investments, securities, entering into loans or any other financial services or banking product. If you are unsure about whether a product is suitable you should contact an independent financial adviser.


7.1. Upon registration you must provide us with a username, email address, password or any other piece of information as part of our security procedures, you must treat such information as confidential. You must not disclose it to any third party and so you must keep them secure at all times. 7.2. You agree not to adapt or circumvent our security systems, nor access our site other than through normal use of it. 7.3. Each time you access your account with us, you will need to enter your details to fulfil our security procedures. Your username, password and any other pieces of information that are part of our security procedures are not transferrable without our prior written consent. 7.4. We have the right to disable any username or password, whether chosen by you or allocated by us, at any time, if in our reasonable opinion you have failed to comply with any of the provisions of these terms and conditions. 7.5. If you know or suspect that anyone other than you knows your user identification code or password, you must promptly notify us at 7.6. You are responsible for all information and activity on our site by anyone using your username and password whether or not authorised by you. If you authorise an agent (including but not limited to a family, friend, employee or a subcontractor) to use your account, you will be responsible for their activity on our site. Any breach of security, loss, theft or unauthorised use of a username, password or other security information must be notified to us immediately using the contact details given at paragraph 7.5 above. 7.7. We reserve the right not to act on your instructions where we suspect that the person logged into your account is not you or we suspect illegal or fraudulent activity or unauthorised use.


8.1. To be an investor on our site you must meet the following criteria: a. you must be an individual, LLP, limited company or public body; b. if you are lending in your capacity as an individual you must be over 18 years old; c. if you are lending in your capacity as an individual you must be a permanent resident of the UK (excluding the Channel Islands and the Isle of Man); d. if you are a limited company, you must be registered with Companies House and be incorporated within the United Kingdom (excluding the Channel Islands and the Isle of Man); e. if you are an LLP, you must have a permanent place of business in the UK (excluding the Channel Islands and the Isle of Man) and be registered with Companies House; f. if you are a public body, you must be registered or formed with the relevant authority in the UK (excluding the Channel Islands and Isle of Man); g. you must have, and maintain, a valid UK bank or building society account; and h. you must register your full details as required by us from time to time on our site. 8.2. Where a prospective investor does not meet the criteria listed above, the investor may be otherwise permitted to become an investor on our site by written confirmation from us. 8.3. You warrant to us that all information provided to us in the course of the registration and lending process is true and accurate in all respects. You will promptly update us if any of the information you provide to us changes. 8.4. As part of the registration process we will carry out identity, fraud and anti-money laundering checks on you and you as a proprietor, member or director, your business and other members, or directors of the business using credit reference agencies such as Callcredit. As part of the process we will share your information with the credit reference agencies and any suspicious activities will be reported to the relevant authorities. We may require you to send us copies of the relevant passports or other identification documents and anything else that we may need. If you do not provide all appropriate identification documents, you will not be able to register you as an investor on our site. 8.5. We use our own internal guidelines and policies when assessing applications but have complete discretion as to whether to allow you to be an investor on our site. If we cannot get adequate information from the credit reference agency then we will ask you to send us copies of the relevant passports or other identification documents plus a utility bill and anything else that we may require. If you do not provide all appropriate identification documents you will not be able to lend on our site. We may suspend or place limitations on trading in your account at any time if we believe it is appropriate in order to comply with our legal obligations. For more details about how we use your information, please refer to our privacy policy . 8.6. Once you have an account with us, you can then transfer money into your personal investor account by debit card through our site or bank transfer. Cash deposits are not accepted. We have complete discretion to specify the method by which you may transfer money into and out of your personal investor account depending on the outcome of the checks set out at paragraphs 8.5 and 8.6. It is important that you quote your investor account number in the narrative box if you transfer money using a bank transfer. In the case of transfers by debit cards, a transfer will be deemed to be complete as soon as funds are credited to your personal investor account. We require you to use an account (or a debit card linked to an account) held with a UK bank or building society in the name of the named investor account holder (or, in the case of an individual member, in joint names one of which is the named investors account holder). 8.7. As soon as we acknowledge receipt of funds into the allocated investor account, we will be able to activate the Auto-Match™ facility as set out in paragraph 9 below. There are no fees payable to set up an investor account.


9.1. There is only one way to lend money on our site, by selecting an interest rate for each portion of loan you have asked us to Auto-Match™. 9.2. Auto-Match™ is where you select an interest rate for a portion of your loan that you wish to lend. You are then (together with the loan portion and allocated interest rate preference) is placed in a queue waiting to be automatically matched (using our credit analysis) to a borrower who has requested funds (Borrower’s Request). 9.3. The interest rate you select as an investor will determine where you fall in our investor queue. You will only be able to invest up to 10% of your total personal investor account against each available loan. 9.4. Should you wish to approach us as a professional investor, you can contact us at 9.5. Our principal role is to perform introductory functions on behalf of borrowers and investors in order to bring together prospective borrowers and investors, to provide a stream-lined process for entering into loans (including the development of standard form loan agreements) and to facilitate the payment and collection of sums due under or in connection with those loans (including taking certain actions on behalf of investors upon a borrower's default or if the borrower becomes, or is likely to become, insolvent as set out in these terms and conditions). You authorise us to enter into any relevant loan agreement that meets you criteria under our Auto-Match™ function. 9.6. We give each borrower a risk band classification at the time a Borrower Request is processed, which is based on information included in the borrower's application and the results of an online check made against records held by credit reference agencies such as Callcredit. We do not edit the information submitted or uploaded by a borrower. 9.7. While we add value to the credit analysis as part of our service, the provision of a risk band classification is intended to be informative only and an investor must form its own opinion regarding the interest rate he wishes to select and undertake its own research, analysis and assessment of each available interest rate for each loan and, where appropriate, seek its own independent financial advice. Where necessary pre-contractual disclosures may be made 9.8. We accept no responsibility and disclaim all liability for any information about each borrower and the risk band made available to prospective investors through our site or in respect of risk band classifications. We may from time to time, but accepts no obligation to, update or amend at any time the risk band classification (including between when the loan request is first made and when it is entered into, and during the term of any loan). 9.9. Money in your personal investor account will be held by us in a segregated client account until or unless it is lent to a borrower at which time it will be transferred to the relevant borrower's account. 9.10. You warrant that once Auto-Match™ has allocated your money at a Borrower’s Request from your personal investor account you authorise us to enter into the Loan Agreement on your behalf. 9.11. Subject to paragraph 16, you may only withdraw money from your personal investor account if: a. you have not lent it through our site; and b. money is only paid into a UK bank or building society account in the name of the named personal investor account holder (or, in the case of an individual member, in joint names one of which is the named personal investor account holder).


10.1. The interest rate will include all of our following charges and fees (Loan Interest Rate), and is set out in full under the Loan Agreement. The Loan Interest Rate includes: a. Investors Return fee; b. Provision Investors' Fund fee; c. Operational Fee; and d. Expenses Costs. 10.2. The charges and fees set out in paragraph 10.1 are included in each instalment of the repayment depending on the term and the risk grade assigned by us. 10.3. We may choose to waive or reduce the above stated charges or fees from time to time. Investors Return 10.4. The Investors Return fee is included in the Loan Interest Rate. This will form part of the Loan Interest Rate and will be used to pay the investors a base return rate and, at our sole discretion, a bonus interest rate (payable on full satisfaction of the loan amount). Provision Investors' Fund Fee 10.5. The Provision Investors' Fund fee is included in the Loan Interest Rate. This will form a part of the Loan Interest Rate and will be used to run, maintain and operate an account for cases of bad debt. Operational Fee 10.6. The Operational Fee is included in the Loan Interest Rate. This will form a part of the Loan Interest Rate and will be used to cover our operational expenses of the Site. Expenses Cost 10.7. The Expenses Costs (including but not limited to the banking charges and credit searches) are included in the Loan Interest Rate. This will form part of the Loan Interest Rate and will be used to cover costs in relation to (but not limited to) credit searches, banking charges, banking fees and other relevant checks that will be required from time to time.


11.1. We are the owner or the licensee of all intellectual property rights in our site, and in the material published on it. Those works are protected by copyright laws and treaties around the world. All such rights are reserved. 11.2. You may print off one copy, and may download extracts, of any page(s) from our site for your personal use and in connection with the Loan Agreement. 11.3. You must not modify the paper or digital copies of any materials you have printed off or downloaded in any way, and you must not use any illustrations, photographs, video or audio sequences or any graphics separately from any accompanying text. 11.4. Our status (and that of any identified contributors) as the authors of content on our site must always be acknowledged. 11.5. You must not use any part of the content on our site for commercial purposes without obtaining a licence to do so from us or our licensors. 11.6. If you print off, copy or download any part of our site in breach of these terms and conditions, your right to use our site will cease immediately and you must, at our option, return or destroy any copies of the materials you have made.


12.1. Nothing in these terms and conditions excludes or limits our liability for death or personal injury arising from our negligence, or our fraud or fraudulent misrepresentation, or any other liability that cannot be excluded or limited by English law. 12.2. To the extent permitted by law, we exclude all conditions, warranties, representations or other terms which may apply to our site or any content on it, whether express or implied. 12.3. We will not be liable to any user for any loss or damage, whether in contract, tort (including negligence), breach of statutory duty, or otherwise, even if foreseeable, arising under or in connection with: a. use of, or inability to use, our site; or b. use of or reliance on any content displayed on our site. 12.4. Please note that in particular, we will not be liable for: a. loss of profits, sales, business, or revenue; b. business interruption; c. loss of anticipated savings; d. loss of business opportunity, goodwill or reputation; or e. any indirect or consequential loss or damage. 12.5. Please note that we only provide our site for domestic and private use. You agree not to use our site for any commercial or business purposes, and we have no liability to you for any loss of profit, loss of business, business interruption, or loss of business opportunity. 12.6. We will not be liable for any loss or damage caused by a virus, distributed denial-of-service attack, or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of our site or to your downloading of any content on it, or on any website linked to it. 12.7. We assume no responsibility for the content of websites linked on our site. Such links should not be interpreted as endorsement by us of those linked websites. We will not be liable for any loss or damage that may arise from your use of them. 12.8. Different limitations and exclusions of liability will apply to liability arising as a result of the supply of any services through our site to you. 12.9. You shall be liable to us for any loss or damage suffered by us as a result of any breach of these terms and conditions or any Loan Agreement by you, or any fraudulent use of our site.


13.1. If our site were to fail or we become insolvent, we would transfer our member loan servicing obligations to a third party back-up servicer, (Microsoft), with whom we have entered into a back-up service arrangement. We reserve the right to use a back-up servicer prior to insolvency where such action is in the best interests of all of the investors. If this happens: a. you would not be able to sell any loan parts; b. you would receive distributions of funds to your external bank or building society account on a quarterly basis; c. the your account page on the site and the rest of the platform would not be available for access by you; and d. you would receive quarterly statements of repayments and continue to receive annual statements (for tax purposes).


14.1. Whenever you make use of a feature that allows you to upload content or files to our site, or to make contact with other users of our site, you must comply with our content standards. 14.2. You warrant that any such contribution does comply with those standards, and you will be liable to us and indemnify us for any breach of that warranty. If you are a consumer user, this means you will be responsible for any loss or damage we suffer as a result of your breach of warranty. 14.3. You retain all of your ownership rights in your content, but you are required to grant us a limited licence to use, store and copy that content and to distribute and make it available to third parties. 14.4. We will not be responsible, or liable to any third party, for the content or accuracy of any content posted by you or any other user of our site.


15.1. If you no longer want to be a registered user of our site and provided you have no active loan agreements, you can let us know and we will end these terms and conditions between us. 15.2. If you do have active loan agreements and want to get access to the money you have lent before it has been repaid, you may sell your loan parts to other investors through our site. Please note that you cannot sell loan parts: a. there are no other investors in the interest rate queue that matches the Investor Return interest rate of the relevant Loan Agreement; or b. that the borrower is in arrears (have currently missed a repayment) or are in default (that have missed consecutive repayments). 15.3. The sale price for loan parts will be the outstanding principal amount, less any relocation costs and plus any interest accrued during the month. The accrued interest will be updated automatically at the end of each day. 15.4. If you sell loan parts, the sale proceeds will be transferred to your personal investor account from the buying investor's personal account after deduction of our loan part sale fee. 15.5. We may end these terms and conditions between us at any time, including but not limited to if: a. you breach these terms and conditions or are in breach of any regulatory requirements relating to your activity as an investor on the platform; b. you breach the terms and conditions of any Loan Agreement; c. we suspect that you have committed fraud, been involved in money laundering or other criminal activities; d. you use our site or any information accessible on or obtained from it for the purpose of canvassing or soliciting any person or enticing any person away from our site; e. you use our site in any of the following ways: f. in any way that causes, or is likely to cause, the site or access to it to be interrupted or damaged in any way; ii. for fraudulent purposes, or in connection with a criminal offence; iii. to send, use or reuse any material that is illegal, offensive, abusive, indecent, defamatory, obscene or menacing; or in breach of copyright, trademark, confidence, privacy or any other right; or is otherwise injurious to third parties; or objectionable; or which consists of or contains software viruses, political campaigning, commercial solicitation, chain letters, mass mailings or any spam; iv. to cause annoyance, inconvenience or needless anxiety or in a way that restricts or inhibits anyone else’s use and enjoyment of our site; v. for a purpose for which our site is not intended or other than as a marketplace for lending to SMEs; or g. there is no activity in your personal investor account within a 12 month period. 15.6. Termination of your registered user access to our site will not necessarily result in a termination of any Loan Agreement to which you are a party at that time. 15.7. On termination we will credit your bank or building society account with any funds left in your personal investor account (less any of our reasonable administration cost) or send a cheque to the address last provided by you.


16.1. We do not guarantee that our site will be secure or free from bugs or viruses. 16.2. You are responsible for configuring your information technology, computer programmes and platform in order to access our site. You should use your own virus protection software. 16.3. You must not misuse our site by knowingly introducing viruses, trojans, worms, logic bombs or other material which is malicious or technologically harmful. You must not attempt to gain unauthorised access to our site, the server on which our site is stored or any server, computer or database connected to our site. You must not attack our site via a denial-of-service attack or a distributed denial-of service attack. By breaching this provision, you would commit a criminal offence under the Computer Misuse Act 1990. We will report any such breach to the relevant law enforcement authorities and we will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use our site will cease immediately.


17.1. You may link to our home page, provided you do so in a way that is fair and legal and does not damage our reputation or take advantage of it. 17.2. You must not establish a link in such a way as to suggest any form of association, approval or endorsement on our part where none exists. 17.3. You must not establish a link to our site in any website that is not owned by you. 17.4. Our site must not be framed on any other site, nor may you create a link to any part of our site other than the home page. 17.5. We reserve the right to withdraw linking permission without notice. 17.6. If you wish to make any use of content on our site other than that set out above, please contact


18.1. Where our site contains links to other sites and resources provided by third parties, these links are provided for your information only. 18.2. We have no control over the contents of those sites or resources.


19.1. If you are a consumer, please note that these terms and conditions, its subject matter and its formation, are governed by English law. You and we both agree to that the courts of England and Wales will have non-exclusive jurisdiction. However, if you are a resident of Northern Ireland you may also bring proceedings in Northern Ireland, and if you are resident of Scotland, you may also bring proceedings in Scotland. 19.2. If you are a business, these terms conditions, its subject matter and its formation (and any non-contractual disputes or claims) are governed by English law. We both agree to the exclusive jurisdiction of the courts of England and Wales.


20.1. Welendus is UK registered trademarks of PTP Funding Limited.


21.1. Should you have any questions about these terms and conditions, or wish to contact us for any reason whatsoever, please contact us on or through our site at 21.2. If you wish to make a formal complaint, you may do so in person, in writing by post or email or by telephone. Please see our complaints procedure here.
PTP Funding Limited incorporated and registered in England and Wales with company number: 09550128 whose registered office is at Level39, 1 Canada Square, Canary Wharf, London, England E14 5AB. Any of our affiliates and any other entity which may, from time to time, accede to the Welendus Agreement (entered into between you and PTP Funding Limited ("we", "us")) may collect, use and store personal information about you as an individual. PTP Funding Limited is registered with the Information Commissioner's Office under registration reference ZA284582. The protection of your personal information is important to us. We will treat your personal information as private and confidential. However, in the circumstances we describe below we may use your personal information and share it with third parties. This privacy policy (“Policy”) explains: • the personal information we collect and how we collect it in Section 1; • how we use your personal information in Section 2; • when and why we share your personal information in Section 3; • your rights in Section 4; • what you can do to protect your personal information in Section 5; • how we protect the personal information we hold in Section 6; and • what you should be aware of when you click through to other websites from our website in section 7 We may need to update this Policy from time to time. An up-to-date version of this Policy will always be available on our website and if we make any material changes which we think you should be made aware of we will notify you, prominently posting a notice on our website / You will see this when you next log on with the updated version of this Policy and/or by email to the email address you register with us, which your consent will be deemed to be given by your continued use of our website. For information about cookies and how we use these please see our policy on cookies below.

1. Personal information we collect & how we collect it:

We collect certain personal information about you during the registration process and on an on-going basis once you start using our website. The types of personal information we collect during the registration process; This may include basic personal information such as your: • name; • email address; • date of birth; • home address, telephone number; and • identification documentation e.g. your passport or driving licence. As well as personal information: • that we reasonably require to carry out checks for anti-money laundering and anti-fraud purposes; to check your creditworthiness; • that we reasonably consider is helpful to assess your eligibility to invest We will obtain personal information about you from third parties such as credit reference agencies, fraud prevention agencies and identification verification agencies as part of the checks we carry out as described above. The types of personal information we collect once you start using our website This includes information about: • your computer and your visits to, and use of our website or third party websites such as your IP address, geographical location, browser type, referral source, length of visit, and page views through the use of log files; • your transactions and other use of our services; and • you, specifically your name and email address if you contact us through our website with questions about our company or our services and are not already a registered user. We collect this information for the sole purpose of responding to such enquiries and do not store this information for later use unless you instruct us to or give us consent to do so. If you refer someone to our website directly from our website or via a partner’s website, we will store and track information about your referral and the person you refer to us only long enough to determine the effectiveness of our marketing activities and for the purposes of those activities. You should only refer someone to us if you have their consent to do so. We will not add the people you have referred to us to any mailing list or contact them independently of the referral process.

2. How we use your personal information

We collect, use and store your personal information for the following purposes: • to register you and create an account for you so that you can start using our services; • to verify your identity, for fraud prevention and creditworthiness assessments and to implement automatic payments and fund transfers; • to contact you if there is any problem with completing a transaction you requested or your account; • to notify you about changes to or developments to the features and operation of the services or to our terms of service or this Policy; • to respond to your queries and any complaints you may have; • to update and improve the accuracy of the personal information we hold on you; • to effectively manage our relationship with you and better understand your needs; • to evaluate the effectiveness of marketing, and for market research and training; • for customer modelling, statistics and trends analysis for the purposes of developing and improving the services we provide to you; • to test new systems and check updates to existing systems; • to remain in regular contact with you as may be necessary to execute transactions you request; • to improve usability of our website and to evaluate the success of particular marketing/advertising campaigns, search engine optimisation strategies and other marketing activities; • to help us ensure that our website has all of the appropriate features and functionality for the services we offer you and to improve the user experience; • to send you service related notifications from time to time. You will receive notifications confirming your registration, the successful verification of contact details and bank accounts, and confirming successful submissions of orders. You will also receive progress updates on the status of orders you have submitted. These are transactional notifications that you cannot opt out of receiving, as they are in place to protect the security of your account and your personal information. We may also send you responses to any correspondence, if appropriate or applicable; • to send you user surveys, requests for user feedback regarding user experience and website operations or marketing offers from us or from us on behalf of our marketing partners. The completion of these surveys or requests for feedback or acceptance of any offer is strictly voluntary; and • as otherwise described in this Policy. We will not retain your personal information for longer than is necessary for the above purposes, or for legal or regulatory requirements.

3. When and why we share your personal information

We may share your information: • with third parties to help us provide you with services and meet other obligations to you and perform related activities, for example (including but not limited to), credit reference agencies, fraud prevention agencies, electronic verification service providers, collection agencies, electronic payment service providers, customer support call centres, external accounting and auditing firms and government regulators; • with law enforcement, regulatory bodies or other competent authorities (including but not limited to the UK Financial Conduct Authority) as required by law or for the purposes of limiting fraud; • when we believe that disclosure is reasonably necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process; • to prevent terrorism and other criminal activity; and • for other purposes provided for under this Policy or for which you give your express consent. Where we share your personal information to process your personal information on our behalf, we will require the third party to do so in accordance with our instructions and this Policy. Where we share your personal information for other purposes, we will ask the person with whom we share your personal information to process it in accordance with UK data protection standards. When we share your personal information with third parties, we may need to transfer it to countries outside of the European Economic Area (the “EEA”) (such as the USA or the British Virgin Islands) for our own purposes (including for storage) and to third parties located in such countries who provide services to us. All countries in the EEA, including the UK have similar standards around the protection of your personal information, however, countries outside of the EEA do not necessarily have similar data protection laws. We will ensure that where we transfer your personal information to a country outside the EEA, it will be protected to the same standard as it would be in the UK or the EEA and we will also ask any third party to whom we share your personal information to protect your personal information in line with UK standards. If someone is thinking of buying us or our business in whole or in part, we may disclose information about you in an anonymised form to them for that purpose. If we go on to sell our business in whole or in part, the new owner may use, share and hold your personal information as described in this Policy. We will notify you of any change in our ownership by posting a notice on our website and/or by email to the email address you register with us.

4. Your rights

You can access certain personal information we hold about you by visiting your profile in the My Account section of our website. This section of our website is password-protected to safeguard your personal information and as a registered user, you can, at any time, access the My Account section and update your password, email address, physical address, phone number and bank account information. If you need to change any other information in your profile you should contact us at This Policy may not constitute your entire set of privacy rights, as these may also vary from country to country. To be certain of your privacy rights, you can contact the appropriate agency in your country that is responsible for overseeing privacy rights of consumers. Certain local laws require us to maintain and report demographic information on the collective activities of our registered users. We may also be required to maintain your personal information for at least 7 years in accordance with applicable local laws regarding recordkeeping, reporting and audits. If you (i) have any questions about this Policy or in relation to your personal information (including what information we hold about you), or (ii) wish to opt out of certain marketing activities or notifications sent to you or (iii) want more information about how and with whom we share your personal information and from whom we obtain it, please email us at; or send us a letter at Welendus, for the attention of the Compliance Department, Level39, 1 Canada Square, Canary Wharf, London, England E14 5AB.

5. What you can do to protect your personal information

You can take several precautions to protect the security of your computer and your personal information. You can use a well-chosen password. When choosing a password, you should avoid using any information that others can easily learn about you, such as family member’s name or birthdays, you should also consider using special characters in place of letters. We recommend that you change your password frequently. You can install and regularly update antivirus and firewall software to protect your computer from external attacks by malicious users. When you are finished with a session on our website, be sure that you log out and close the browser window. If you use a computer that is accessed by other people, in places like a public library or Internet cafe, we recommend that you take special precautions to protect the security of your account and your personal information. When you are finished using our website, you should log out completely, close the browser window and clear the browser’s cache files. You should be aware of fraudulent attempts to gain access to your account information known as "phishing". Phishing is a tactic used by scammers in which unsuspecting people are directed to a website by a genuine-looking email that appears to be from a legitimate company. The phony or "spoof" email takes the person to a website that looks legitimate but is in fact not genuine. Either in the email itself or on a fake website, scammers will ask for login information to gain access to people’s accounts and withdraw their money. We will never ask you for your login information in any email. In general, you can protect yourself against phishing by never providing personal or login information via an email. You might also make it a habit to check the URL of a website to be sure that it begins with the correct domain. In the case of our website, you should always ensure the URL begins with, or

6. How we protect the personal information we hold

Verification of Practices We periodically review our operations and business practices (including the controls and safeguards we have put in place to protect your personal information) for compliance with our policies and procedures governing the confidentiality of information. These reviews may be conducted by our own internal staff, external accounting and auditing firms, and government regulators. Standards and controls We take steps to safeguard your personal information through vigorous physical, electronic and operational systems and controls. We treat all of your personal information as confidential. Data can only be read or written through defined service access points, the use of which is password-protected. The physical security of your personal information is achieved through a combination of network firewalls (there is no direct communication allowed between the database server and the Internet) and servers with hardened operating systems, all housed in a secure facility. Access to the system, both physical and electronic, is controlled and sanctioned by a senior manager. We also equip our servers with Secure Socket Layer (SSL) certificate technology to ensure that when you connect to our website you are actually on our website. SSL also ensures that all data entered into our website is encrypted. To verify that SSL is being used, look for the key or padlock icon on your browser. For further encryption protection, we use a 128-bit secure browser for logins and transactions. Finally, we subject our systems to periodic security audits to ensure that your personal information is thoroughly protected and secure. Secure, off-site hosting Our payments processing providers store all sensitive financial information such as bank account information in a highly secure environment (Microsoft Azure, UK). Session time-outs We also employ session time-outs to protect your account. You will be logged out of our website automatically after a specified period of inactivity. This time-out feature reduces the risk of others being able to access your account if you leave your computer unattended. Protection of account numbers When we contact you about your account to confirm a funds transfer, we only reference the last four digits of your bank account number; this is done for your protection so that you will recognise the source or destination account as one which you own. We also employ strict access standards ensuring that only the senior-most employees have access to your account numbers and other sensitive information. This access is only granted in order to complete transactions which you request or to provide regular ongoing service to your account. ID theft policy We will work with law enforcement authorities to track down and prosecute anyone who has committed identity theft. Employee Conduct We are committed to the integrity of our business, and our corporate values and ethical standards and expect such commitment from all of our employees. Our employees are educated about our very specific guidelines concerning the safeguarding of confidential information, which includes your personal information. These guidelines limit employee access to confidential information and the use and disclosure of personal information. If it is determined that an employee has violated these guidelines, disciplinary corrective action may be taken, including immediate dismissal.

7. What you should be aware of when you click through to other websites from our website

We are not responsible for the information practices employed by third party websites linked to or accessed from our website. We may offer links to partners’ websites. We make the decision to provide these links based on the quality of information provided at the time the links are enabled or to facilitate your use of our website, and we take reasonable steps to monitor the continuing quality of content provided on these websites. However, these external sites are not subject to this Policy and may have different privacy policies or approaches to the handling of personal information. We have no control over the content of these websites. You should read the privacy policies on these websites before you provide them with any of your personal information. Our policy on cookies A cookie is a text file sent by a web server to a web browser, and stored by the browser. A cookie is a small text file, typically of letters and numbers, downloaded on to a device when the user accesses certain websites. Cookies allow a website to recognise a user’s device. We use cookies and other online tracking devices such as Google Analytics on this website to: a) recognise you whenever you visit this website (this speeds up your access to the site as you do not have to log on each time); b) obtain information about your preferences, online movements and use of the Internet; c) carry out research and statistical analysis to help improve our content, services and to help us better understand our customer requirements and interests; d) target our marketing and advertising campaigns and those of our partners more effectively by providing interest-based advertisements that are personalised to your interests; and e) make your online experience more efficient and enjoyable. The information we obtain from our use of cookies will not usually contain your personal data. Although we may obtain information about your computer or other electronic device such as your IP address, your browser and/or other internet log information, this will not usually identify you personally. In certain circumstances we may collect personal information about you – but only where you voluntarily provide it (e.g. by completing an online form). In most cases we will need your consent in order to use cookies on this website . The exception is where the cookie is essential in order for us to provide you with a service you have requested (e.g. to enable you to put items in your shopping basket and use our check-out process). Third-party cookies We work with third-party suppliers who may also set cookies on our website, for example Facebook, Google, Microsoft. These third-party suppliers are responsible for the cookies they set on our site. If you want further information please go to the website for the relevant third party. How to turn off cookies If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of this website. For further information about cookies and how to disable them please go to: or