Privacy Policy

This Privacy Policy explains how Alternative Commercial Finance Limited and its group companies, Room Twelve Limited and 12th Gen Limited (together the "ACF group", "we", "us"), collect, use and protect your personal data when you use the website alternativecf.co.uk (the "Site") or interact with us. We are committed to protecting your privacy and handling your data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

1. Who we are

Alternative Commercial Finance Limited (company no. 08547499) is the data controller for personal data collected through the Site. Our registered office is 1 Marine Studios, Burton Lane End, Burton Waters, Lincoln LN1 2UA. For any data protection enquiry, contact us at [email protected] or by post at the address above, marked "Data Protection".

2. Personal data we collect

• Information you give us: name, organisation, email address, telephone number and the contents of any message you send via our contact forms, email or telephone.
• Information collected automatically: technical data such as IP address, browser type and version, device information, and information about how you use the Site (see our Cookie Policy).
• Business relationship data: where you are a customer, supplier, broker, adviser or investor (or act for one), information reasonably required to establish and manage that relationship, including identity verification and anti-money laundering checks where required by law.

3. How we use your data

We process personal data where we have a lawful basis to do so, namely:

• To respond to enquiries and provide our services (performance of a contract or steps prior to a contract);
• To manage business relationships, administer agreements and maintain records (legitimate interests);
• To comply with legal and regulatory obligations, including financial crime prevention, sanctions screening and anti-money laundering requirements (legal obligation);
• To send you information about our services where you have requested it or where we are otherwise permitted to do so. You may opt out at any time (consent / legitimate interests).

4. Sharing your data

We do not sell your personal data. We may share it with: other companies within the ACF group; our professional advisers (legal, accounting, audit); service providers who support our operations (IT, hosting, CRM) under appropriate contractual safeguards; funders and credit reference agencies where relevant to a financing arrangement; the fund manager and administrators connected with the 12th Gen Planning Service where relevant to an investment; and regulators, law enforcement or other authorities where required by law.

5. International transfers

Where personal data is transferred outside the UK, we ensure an adequate level of protection through UK adequacy regulations, the International Data Transfer Agreement (IDTA) or other lawful safeguards.

6. Data retention

We retain personal data only for as long as necessary for the purposes for which it was collected, including to satisfy legal, accounting, regulatory or reporting requirements. Records connected with financing agreements and investments are typically retained for at least six years after the relationship ends.

7. Your rights

Under UK data protection law, you have rights including the right to: access your personal data; have inaccurate data rectified; request erasure; object to or restrict processing; data portability; and withdraw consent where processing is based on consent. To exercise any of these rights, contact us at [email protected]. You also have the right to complain to the Information Commissioner's Office (ICO) at ico.org.uk or on 0303 123 1113.

8. Security

We apply appropriate technical and organisational measures to protect personal data against unauthorised access, loss or misuse, and require the same of our service providers.

9. Changes to this policy

We may update this policy from time to time. The latest version will always be available on this page with the date of the most recent revision shown above.