Whenever you provide personal information to FW Capital, or we collect information about you, we will only use it in accordance with this privacy notice. Please read this carefully.
This privacy notice applies to FW Capital Ltd., a subsidiary company of the Development Bank of Wales plc (collectively known as the DBW Group). Whenever the terms 'FW Capital’, ‘we', ‘us’ or ‘our’ are used in this notice, it means FW Capital or any other company in the DBW Group that holds your personal information.
For the full list of our privacy documentation click here.
For more information on our corporate structure, click here.
Our privacy principles
We take your privacy seriously and are committed to protecting your personal information. This means:
We will only ask you to provide us with your personal information that helps us to help you.
We will hold your personal information securely and responsibly. We use safeguards, including encryption, to prevent unauthorised access to your personal information.
We will only share your personal information with other companies in the DBW Group, with suppliers who perform services on our behalf, and as otherwise set out in this notice.
We will never sell your personal information
Who we are
This section gives you the legal name of the company who holds your personal information – known as the ‘legal entity’ – and tells you how you can get in touch with us.
Development Bank of Wales Plc (Banc Datblygu Cymru ccc) is the holding company of a Group that trades as ‘Development Bank of Wales’. The Group is made up of a number of subsidiaries which are registered with names including the initials DBW.
Development Bank of Wales Group Plc is a development finance company wholly owned by the Welsh Ministers, it is neither authorised nor regulated by the Prudential Regulation Authority (PRA) or the Financial Conduct Authority (FCA).
Development Bank of Wales Group Plc has three subsidiaries which are authorised and regulated by the FCA. Please note that neither the Development Bank of Wales Plc nor any of its subsidiaries are banking institutions or operate as such. This means that none of the group entities are able to accept deposits from the public.
FW Capital Ltd is a subsidiary of Development Bank of Wales Plc that is authorised and regulated by the Financial Conduct Authority for investment related activities.
In summary, Development Bank of Wales is made up of a mix of companies, set up via different legal entities. We’ll let you know which of these you have a relationship with when you take out a product or service with us.
Why we collect and use your personal information
We may collect and use personal information about you for the following reasons:
In connection with an application for, and the on-going management of, one of our investment products;
Because you would like us to contact you in response to a specific query;
So that we can keep you informed about our investment products and services;
In connection with the services that you provide to us.
More information about how we use your information in connection with each of these purposes can be found below. This website also uses cookies, more details of which can be found in our cookies policy.
Your data protection rights
The personal information you provide to us will be held in accordance with our responsibilities under data protection legislation. This includes the Data Protection Act 2018 and the UK General Data Protection Regulation. These laws contain specific rights for you, including:
the right to request access to personal information held about you (this is known as the right of subject access);
the right to have inaccurate personal information about you corrected and, in some circumstances, the right for that information to be erased;
the right to object to processing of your personal information in some circumstances (for instance if you think the information we hold about you is inaccurate, or if it is being used for direct marketing purposes);
the right to object to your personal information being used for any automated decision-making, including profiling; and
the right to complain to the regulator, the Information Commissioner's Office, if you are unhappy about how your personal information is being used. The ICO can be contacted at ico.org.uk/make-a-complaint/
If you would like to exercise any of the rights set out above, including requesting details of the personal information we hold about you, please e-mail us at [email protected] or write to us at:
DATA PROTECTION OFFICER,
Development Bank of Wales,
1 Capital Quarter,
Tyndall Street,
Cardiff,
CF10 4BZ.
1. Using your personal information in connection with our investments
Why does FW Capital need to use my personal information?
If you apply to us for one of our investments, you will need to provide us with information about you. This is so we can decide whether you are eligible for the investment, and whether it is suitable for you. If your application is successful, we will continue to use your information as part of our on-going management of our investments.
We may also use personal information about you which is provided by others to inform our investment decisions. For instance, if you are financially associated with an applicant or are a director or owner of an applicant company, then we will need to collect personal information about you.
What information do I need to provide to FW Capital?
The exact information that we require will be different in each case and will be set out on the application form itself. It will include basic information about you, such as your name, address, previous addresses, and date of birth. If you are making an application as an individual, a sole trader or a partnership, we will ask you to provide information about your financial standing. We may also ask you to provide information about 'associated persons', which are people financially linked to you.
Where an application is made on behalf of a company [or limited liability partnership], we will ask for information about the directors and beneficial owners (or partners) of the company (or LLP), including information about their financial standing. We may use this information to carry out credit and other relevant checks on those individuals.
If we decide to make an offer of investment, we may ask you to complete a diversity monitoring form. Any information you provide us on this form will only be used to help us monitor if we are achieving real equality of opportunity in delivering our services. It will not be used to make decisions affecting you.
What does FW Capital do with my information?
When you provide your information to us or it is provided by others as part of an application, we will use it to assess the application and to make a decision on whether or not to provide the relevant investment. We will then use your information to manage our investment. Our uses of your information may include:
Making searches about you at credit reference agencies. These agencies will provide us with credit information as well as information from the electoral register and will record details of any searches whether or not your application proceeds. You can find out more information about how your information is used by credit reference agencies and fraud prevention agencies by reading the Credit Reference Agency Information Notice (“CRAIN”). This document describes how the three main credit reference agencies each use and share personal data. The CRAIN can be accessed here..
Credit searching, for debt tracing and the on-going management of any funding we may provide to you.
Credit-scoring, to determine your suitability for the relevant product or service.
Carrying out identity checks and verifying the accuracy of the information you provide to us.
Fraud detection and prevention. We may share your information with fraud prevention agencies such as the National Crime Agency, for this purpose.
Carrying out any of the above actions in respect of your business or any other applicants named on your application form.
Carrying out surveys on customers and their businesses, in order to evaluate the impacts of our investments and identify trends in the funding that we provide to businesses of the activities listed above.
As part of the activities listed above, we will share your information with third parties such as credit reference agencies, fraud prevention agencies and survey companies.
. For Investments made by FW Capital, we will share information with the British Business Bank, North of Tyne Combined Authority, North East Local Enterprise Partnership, Sunderland City Council, Tees Valley Combined Authority, Clwyd Pension Fund, and NPF 2016 Ltd..
We may also share information with the Secretary of State for Business and Trade , HM Treasury, the National Audit Office and the Government Internal Audit Office and their respective representatives and advisers for auditing and reporting purposes.
You acknowledge and agree that your personal data may be processed outside the European Economic Area (“EEA“). We will take precautions (in accordance with relevant guidance by regulatory bodies) to ensure that any transfer of your data outside the EEA will be subject to safeguards that protect your privacy rights, and your data will be kept secure at all times.
Please refer to the specific application forms for exact details of how we will use your personal information in relation to each of our investment products.
What is the legal basis for using my information?
Under data protection law, we must have a valid legal basis for collecting and using your personal information. When you apply for one of our investments, the following legal bases may apply:
Your application is a request for us to enter into a contract with you. We are permitted to use your personal information where it is necessary for us to do so in order to enter into a contract with you and for the performance of that contract.
We are subject to various legal obligations whenever we consider applications for investment, including anti-money laundering legislation and the requirements of the Financial Conduct Authority. We are permitted to use your personal information where it is necessary in order for us to comply with our legal obligations.
We believe that conducting appropriate checks on potential customers, and then monitoring the performance of our investments during the term of our relationship, are in our legitimate interests as a responsible lender. We are permitted to use your personal information where it is necessary for our legitimate interests, provided that our interests are not overridden by your own interests.
In the event that any additional information you provide to us comprises of special category personal information, we are permitted to process this when:
you have provided your explicit consent for us to do so,
for reasons of substantial public interest,
to establish, exercise, or defend legal claims.
How long does FW Capital retain my information?
If your application is successful, we will keep your personal information for at least the duration of your contract with us, and after that for a period of seven years. This is to ensure that we have a full record of the contract between us, if there should be any dispute about the contract.
If your application is unsuccessful, we will normally delete your information after 12 months.
We may hold your information for longer where it is necessary to comply with our legal obligations, to exercise legal rights or to defend legal claims.
What happens if I do not provide my information to FW Capital?
In order for us to consider your application, you must provide information about you to us. If you do not provide all of the details we request on the application form, we will be unable to assess your application and it may result in you not being able to access our investments.
2. Using your personal information to respond to your enquiry
Why does FW Capital need to use my personal information?
If you contact us for more information about a particular investment product, or if you make a general enquiry, we will need to process your personal information in order to respond to you.
What information do I need to provide to FW Capital?
That will depend on the nature of your query. The ‘contact us’ page on our website sets out the minimum information we will need about you in order to respond to your query.
What does FW Capital do with my information?
We will use the information to respond to your query and, if you agree, to contact you again to provide you with information about our products and services (see part 3, below).
What is the legal basis for using my information?
Under data protection law, we must have a valid legal basis for collecting and using your personal information. When you contact us for more information about our products or services, we believe that we have a legitimate interest in being able to respond fully to your enquiry. We are permitted to use your personal information where it is necessary for our legitimate interests, provided that our interests are not overridden by your own interests. In this case, we believe that using your personal data to respond to your query is in both your and our interests.
In the event that any additional information you provide to us comprises of special category personal information, we are permitted to process this when:
you have provided your explicit consent for us to do so,
for reasons of substantial public interest,
to establish, exercise, or defend legal claims.
How long does FW Capital retain my information?
We will hold your information for the time it takes to deal with your query. We will normally delete your information after 12 months, unless you would like us to retain your contact details to keep you informed of our products and services (see section 3, below).
What happens if I do not provide my information to FW Capital?
You do not need to provide us with your personal information. However, if you do not provide sufficient information, we may not be able to respond accurately to your query. If you contact us via our website, we ask that you provide certain mandatory information so that we can deal with your query.
3. Using your personal information to keep you informed of our products and services
Why does the FW Capital need to use my personal information?
If you would like to be kept informed of our range of investment products and services, we will use your personal information to send you direct marketing communications (such as emails). We will only do this when we believe we have a legitimate interest in doing so, or if you have agreed to us using your personal information for this purpose.
What information do I need to provide to FW Capital?
You may provide us with your name and contact details via the ‘email sign-up' page on our website, our application form, at events or meetings.
We may collect your contact information from third-party sources such as the, British Business Bank, Tees Valley Combined Authority, Sunderland City Council, North of Tyne Combined Authority, NPF 2016 Ltd, Nations & Regions Investments Ltd, Northern Powerhouse Investments Ltd., NPIF NW, NPIF TVC, NE Property Fund, NE Commercial Property Investment Fund, SWIF, and North East Local Enterprise Partnership. We will use your information to send you marketing mail that we think you would be interested in receiving.
What does FW Capital do with my information?
We will use your contact details and details related to your role or job title to provide you with information about our products and services.
What is the legal basis for using my information?
Under data protection law, we must have a valid legal basis for collecting and using your personal information. When we use your information for marketing purposes, the following legal bases apply:
We believe that we have a legitimate interest in sending you information about our products and services. We are permitted to use your personal information where it is necessary for our legitimate interests, provided that our interests are not overridden by your own interests. In this case, we believe that telling you about our products and services is in both your and our interests. We will always give you the opportunity to opt out of receiving these communications.
In some circumstances we will ask for your consent before we send you information about our products and services.
How long does FW Capital retain my information?
We will hold your information until you choose to no longer receive marketing communications from us.
What happens if I do not provide my information to FW Capital?
If you do not wish to receive marketing information from us, please let us know. You have the right to opt out at any time by e-mailing us at [email protected] or clicking the 'unsubscribe' option in any of our marketing emails.
4. Using your personal information in connection with services you provide to us
Why does FW Capital need to use my personal information?
If you provide services to FW Capital, you will need to provide us with information about you. This is so we can decide whether you are the right person to deliver the required service. If you provide services to us, we will continue to use your information as part of our on-going management of the service you provide.
What information do I need to provide to FW Capital?
We require information such as your name, address, and contact details, including email address and telephone number.
What does the FW Capital do with my information?
When you provide your information to us, we will use it in order to assess your suitability for the service. We will then use your information to manage our ongoing relationship while you provide the service and will share that information with third parties as is required.
You acknowledge and agree that your personal data may be processed outside the European Economic Area (“EEA“). We will take precautions (in accordance with relevant guidance by regulatory bodies) to ensure that any transfer of your data outside the EEA will be subject to safeguards that protect your privacy rights, and your data will be kept secure at all times.
What is the legal basis for using my information?
Under data protection law, we must have a valid legal basis for collecting and using your personal information. When you apply to provide a service to us, the following legal bases may apply:
Your application is a request for us to enter into a contract with you. We are permitted to use your personal information where it is necessary for us to do so to enter into a contract with you and for the performance of that contract.
We are permitted to use your personal information where it is necessary for us to comply with our legal obligations.
We believe that conducting appropriate checks on potential service providers, and then monitoring the performance of our investments during the term of our relationship, is in our legitimate interests as a responsible lender. We are permitted to use your personal information where it is necessary for our legitimate interests, provided that our interests are not overridden by your own interests.
How long does FW Capital retain my information?
If your application is successful, we will keep your personal information for at least the duration of your contract with us, and after that for a period of seven years. This is to ensure that we have a full record of the contract between us, if there should be any dispute about the contract.
If your application is unsuccessful, we will normally delete your information after 12 months.
We may hold your information for longer where it is necessary to comply with our legal obligations, to exercise legal rights or to defend legal claims.
What happens if I do not provide my information to FW Capital?
For us to consider your application, you must provide information about you to us. If you do not provide all of the details we request on the application form, we will be unable to assess your application and it may result in you not being able to access our investments.
