Privacy Policy

Last updated: January 2026

Introduction Lending Capital Limited ("we", "our", "us") respects your privacy and is committed to protecting your personal data. This notice explains how we collect, use, and share your personal data in connection with loan applications, property finance facilities, and other dealings with us.

1. Who We Are Company Name: Lending Capital Limited

Registered Address: 20 North Audley Street, London, W1K 6WE

Company Number: 16851610

Data Protection Registration Lending Capital Limited is registered as a data controller with the UK Information Commissioner’s Office (ICO). Our registration number is ZC092145. You can verify our registration on the ICO website at ico.org.uk.

Data Protection Contact: Compliance/Data Privacy Contact Email: info@lendingcapital.co.uk

2. Personal Data We Collect We may collect the following types of personal data:

· Identification data (for example, name, date of birth, passport details, tax identification number).

· Contact details (for example, residential or business address, email address, telephone number).

· Financial information (for example, credit history, banking details, income and affordability information, source of funds, tax residency).

· Compliance data (for example, anti-money laundering and know-your-customer checks, sanctions screening, identity verification documents).

· Communications (for example, emails, letters, meeting notes, call logs).

· Monitoring data (for example, covenant reporting, call recordings, site visit notes, portfolio monitoring records).

· Litigation and enforcement data (for example, information arising from default, recovery, and enforcement action).

We usually collect personal data directly from you, your business, or your professional advisers, and from third-party compliance and credit information providers, including credit reference agencies and introducers/brokers.

3. How We Use Your Personal Data We process your personal data for the following purposes:

· Assessing loan applications, including creditworthiness, security, and suitability of facilities.

· Structuring, documenting, and managing loan agreements, drawdowns, repayments, and related obligations.

· Complying with legal and regulatory obligations, including tax, anti-money laundering, sanctions, and anti-fraud requirements.

· Communicating with borrowers, guarantors, security providers, and their representatives in relation to facilities and ongoing management.

· Sharing information with, and responding to requests from, regulators, current or potential funders, institutional partners, or service providers where necessary.

· Communicating with you about updates to our services, our business, or this privacy notice where appropriate.

· Ongoing monitoring of loan performance, collateral, and covenants, including reporting to funders or investors where relevant.

4. Use of Data in AI and Machine Learning We may use certain personal data, in anonymised or aggregated form where possible, to support the development, testing, and improvement of our systems, including machine learning models and generative AI tools. This supports our risk management, compliance, and operational efficiency. Where personal data is used, we apply appropriate safeguards to protect your rights and freedoms. You have the right to object to this type of processing at any time.

5. Lawful Basis for Processing We process personal data only where we have a lawful basis under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. The main purposes and corresponding lawful bases include:

· Performance of a contract – to take steps at your request before entering into a facility and to perform our obligations under loan and related agreements.

· Compliance with a legal obligation – to comply with laws and regulations that apply to us, including tax, anti-money laundering, sanctions, and anti-financial crime requirements.

· Legitimate interests – to protect and manage our business, including assessing and managing credit risk, enforcing loan obligations, maintaining accurate records, improving our services, and preventing fraud, provided our interests are not overridden by your rights.

· Consent (where required) – where none of the above bases apply and consent is legally required, we will ask for your explicit consent before collecting, using, or sharing personal data.

By providing personal data to us, you acknowledge that your data will be processed for the purposes described in this notice and any related documentation.

6. Sharing Your Data We may share your personal data with:

· Professional advisers (such as lawyers, accountants, auditors, valuers).

· Banks, lenders, co-lenders, and syndication or funding partners.

· Credit reference agencies, which may in turn hold and share this information with other lenders.

· Regulatory and tax authorities (for example, the Financial Conduct Authority and HM Revenue & Customs).

· Service providers (for example, banking and payment providers, loan servicers, cloud and IT providers, document storage providers, KYC/AML platforms).

· Potential future investors, funders, or acquirers in connection with due diligence.

· Our group companies, affiliates, and subsidiaries (if any) involved in the management or funding of facilities.

· Recovery and enforcement partners (for example, asset managers, receivers, collection agents) where a loan is in default.

We do not sell your personal data to third parties.

Additional note on Credit Reference Agencies:

To assess your application and manage your account, we will supply your personal information to credit reference agencies (CRAs). The CRAs will provide information about you, including your financial history, which we use to assess creditworthiness and product suitability, verify your identity, manage your account, trace and recover debts, and prevent criminal activity. We will continue to exchange information about you with CRAs on an ongoing basis, including information about settled accounts and any debts not fully repaid on time. CRAs share information with other organisations that use their services. Further details about CRAs and how they use personal data are available at: https://www.experian.co.uk/legal/crain/index.html.

7. International Transfers In limited circumstances, your personal data may be transferred to and stored in countries outside the UK (for example, where a service provider or cloud hosting provider is located overseas). Where such transfers occur, we will ensure that appropriate safeguards are in place, such as adequacy regulations or standard contractual clauses, so that your personal data remains protected in line with UK data protection law.

8. Data Retention We retain your personal data only for as long as is necessary for the purposes described in this notice and to comply with our legal and regulatory obligations. Typically, this means:

· Up to 7 years from the date on which the data was provided to us; or

· For the duration of a loan agreement and for 7 years after its termination or full repayment.

In some cases, we may need to retain data for longer where required by law, regulation, or in connection with actual or potential legal claims.

9. Your Rights Under UK data protection law, you have the right to:

· Access and obtain a copy of your personal data.

· Request correction of inaccurate or incomplete data.

· Request deletion of your data in certain circumstances.

· Object to or request restriction of processing in certain circumstances, including where we rely on legitimate interests.

· Request the transfer of your data to another controller (data portability), where technically feasible.

· Withdraw consent where we rely on consent (this will not affect processing carried out before consent was withdrawn).

· Lodge a complaint with the UK Information Commissioner’s Office (ICO) if you are unhappy with how we handle your data (www.ico.org.uk).

Note on automated processing: we use automated tools (including credit scoring, AML and sanctions screening) to assist our assessments. However, final lending decisions are made by our credit and risk teams and are not based solely on automated processing. You may request a review of any decision if you believe that automated tools have unfairly affected the outcome.

10. Exercising Your Data Protection Rights You can exercise your rights under the UK GDPR and the Data Protection Act 2018 by contacting us at info@lendingcapital.co.uk or by writing to our registered office. We may need to verify your identity before responding to your request. We aim to acknowledge your request promptly and respond within one month, or within up to three months for particularly complex requests, as permitted by law. If you are dissatisfied with our response, you may raise your concerns with the ICO at www.ico.org.uk.

11. Security We implement appropriate technical and organisational measures designed to protect personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures are kept under review and updated in line with legal and regulatory requirements and good industry practice.

12. Updates to This Notice We may update this privacy notice from time to time to reflect changes in law, regulation, guidance, or our internal processes and systems. Where changes are material, we will take reasonable steps to bring them to your attention, for example via our website or by direct communication.

Summary We collect and use personal data to assess, underwrite, and manage property finance facilities, comply with legal and regulatory obligations, and protect and manage our business interests. Personal data is processed in accordance with the UK GDPR, the Data Protection Act 2018, and other applicable laws.