Privacy Policy

Privacy Notice

Who we are

We are Aspire Commercial Finance Limited trading as South West Business Finance (“SWBF”, “we”, “us” or “our”). We are a commercial finance broker and can be contacted using the following details:

Telephone number: 01225 800849

Address: The Hayloft, Pickwick Workshops, Park Lane, Corsham, SN13 0HN

Email address: hello@swbf.co.uk

Data protection contact: Dan Smith, Data Protection Officer

ICO registration number: ZA180330

Aspire Commercial Finance Limited is registered in England and Wales under company number 09076273. Its registered office is The Old Post Office, 41-43 Market Place, Chippenham, SN15 3HR. It is authorised and regulated by the Financial Conduct Authority under firm reference number 690089 and is an authorised credit broker, not a lender.

Our legal grounds for holding your data

The UK’s data protection laws allow us to use your personal data provided we have a lawful basis to do so. This includes sharing it in certain circumstances, as described below.

We consider that we have the following reasons, or legal bases, to use your personal data:

  • Performance of a contract with you, or steps at your request before entering into a contract: we need to use your personal data to understand your finance requirements, provide our brokerage services and administer our relationship with you.
  • Compliance with our legal obligations: we need to use personal data to comply with requirements relating to financial crime, identity verification, regulatory reporting, complaints and record-keeping.
  • Legitimate interests: these are our business and commercial reasons for using personal data, balanced against your interests, rights and freedoms. They include operating and improving our brokerage, preventing and detecting fraud and money laundering, supporting responsible lending, communicating with you, protecting our systems, maintaining records and establishing, exercising or defending legal claims.
  • Your consent: where consent is required, you can withdraw it at any time. We will stop the consent-based processing unless another lawful basis permits or requires us to continue.

 

The lawful basis will depend upon the purpose and circumstances of the processing. Further information about our uses of personal data is set out below.

What data do we collect?

Data provided by you

  • Finance application and enquiry details, including your name, date of birth, National Insurance number where required, addresses, email address, telephone numbers, occupation, ownership and directorship details, bank details, source and purpose of funds, finance requirements, assets and liabilities, financial commitments, business interests, identification and address evidence, available equity, collateral and security.
  • Business and financial documents, including accounts, bank statements, management information, forecasts, tax information, business plans, asset details, property information, valuation information, tenancy information, planning information and details of the proposed transaction.
  • Information you give us when speaking to us by telephone, video call or in person, including call notes, meeting records and voice messages. We may monitor or record calls with you to check we have carried out your instructions, to resolve queries or disputes, to improve the quality of our service or for regulatory or fraud prevention purposes.
  • Information provided in letters, emails, text messages, forms, electronic signatures and other electronic communications.
  • Information submitted through our website, online forms or event-registration pages.
  • Information provided during reviews, renewals, complaints, surveys, feedback or customer-support discussions.
  • We may also collect information about communication preferences, accessibility requirements and vulnerability or support needs where relevant to delivering appropriate service and good customer outcomes.

Data we collect when you use our services

  • Transaction and application data, including the type and amount of finance sought, proposed term, product type, business sector, geographic location, assets or property involved, security, lenders approached and progress or outcome of an application.
  • Payment and fee data, where relevant, including the amount, source, frequency, history and method of your payments.
  • Communications and service-use data, including enquiries, correspondence, documents issued or signed, actions taken, complaints, support records and marketing preferences.
  • Website and technical data, where collected, including IP address, browser, device and cookie or similar technology information.
  • Information you voluntarily provide through customer surveys, feedback, events or other engagement.

Data we receive indirectly

  • Introducers, brokers, accountants, solicitors, valuers, surveyors, agents, professional advisers, directors, shareholders, partners, guarantors and other people connected with an enquiry or transaction.
  • Lenders, funders, packagers, master brokers, finance providers and product suppliers.
  • Creditsafe and other approved identity verification, credit reference, anti-money laundering, sanctions and fraud prevention providers.
  • Companies House, HM Land Registry, the electoral register, insolvency and court records, sanctions lists, public registers, websites, media and other publicly available sources.
  • Service providers and technology systems used during our relationship, where records or activity information are generated as part of providing the service.

Data provided to and by third parties

We may receive personal data from people who introduce you to us, credit reference and fraud prevention agencies, your authorised representatives, employers where relevant, and legal, financial or other professional advisers. We may also receive publicly available information from official registers and online sources.

We may request information from an independent qualified accountant or other professional adviser about your financial position, including assets, liabilities, net worth, available collateral or security, where relevant to the proposed finance.

Special Category Data

During your interactions with SWBF you may share information that is classified as special-category data. This includes information about race, ethnic origin, political opinions, religion or philosophical beliefs, trade union membership, genetics, biometrics used for unique identification, health, sex life or sexual orientation.

In practice, the special-category information most likely to be relevant to us is health or disability information, including a characteristic of vulnerability or a communication or support need. We will explain why the information is relevant and will limit our record to what is necessary.

Where you do share information relating to any of these categories e.g., when you may share information about your health or a characteristic of vulnerability SWBF will always seek explicit consent from you to store and process such information. 

Why is personal data collected by us?

SWBF collects personal data to respond to enquiries, understand your circumstances and objectives, assess and progress finance requirements, identify and communicate with finance providers, administer our brokerage service, communicate with you, manage our business relationship and maintain appropriate records.

We also collect and use personal data for identity verification, AML, sanctions and fraud checks, regulatory compliance, complaints, legal claims, information security, business administration, service improvement, customer support, Consumer Duty monitoring where applicable, and direct marketing where the relevant legal requirements are met.

From time to time, we may ask for consent to use personal data for another purpose. Personal data may also be used for other purposes where required or permitted by law.

When we and fraud prevention agencies process your personal data, we do so on the basis that we have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the services or financing you have requested. We, and fraud prevention agencies, may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime. Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.

In order to process your application, we may supply your personal information to credit reference agencies (CRAs) in which case they will give us information about you, such as about your financial history. We do this to assess your creditworthiness and product suitability, check your identity, manage your account, trace and recover debts and prevent criminal activity. When CRAs receive a search from us they may place a search footprint on your credit file that may be seen by other lenders and used to assess applications for finance from you and members of your household. The CRA may also share your personal information with other organisations. We may also continue to exchange information about you with CRAs on an ongoing basis, including about your settled accounts and any debts not fully repaid on time. CRAs will share your information with other organisations. Your data will also be linked to the data of your spouse, any joint applicants or other financial associates. We can provide you with the identities of the CRAs and the ways in which they use and share personal information upon your request. 

From time to time, we may provide your information to our partners, third parties and customer service agencies for research and analysis purposes so that we can monitor and improve the services (or as the case may be) we provide. We may contact you by post, e-mail or telephone (or as required) to ask you for your feedback and comments on our services (or as the case may be). We may also contact you about our other goods or services that may be of interest to you.

SWBF collects and uses personal data so that we can:

  • process your enquiry or application and manage your request;
  • understand your finance requirements and identify potentially suitable finance providers;
  • prepare and submit applications, communicate lender requirements and progress the transaction;
  • verify identity and carry out AML, sanctions, credit and fraud prevention checks;
  • meet FCA, legal, regulatory, complaints and record-keeping requirements;
  • provide appropriate support, including reasonable communication adjustments and vulnerability support;
  • monitor our service and customer outcomes, investigate complaints and improve our processes;
  • protect our systems, records, staff, customers and business from security incidents or unlawful activity;
  • manage events and send marketing communications where permitted; and
  • use approved technology, including AI-enabled tools, to assist authorised employees as explained below.

Lawful Basis for Processing Data

As a credit broker, we process your personal data where it is necessary to take steps at your request before entering into a contract or to perform our contractual obligations to you. This includes understanding your finance requirements, identifying suitable finance providers, submitting applications and administering our services.

We may also process your personal data to comply with our legal and regulatory obligations, including identity verification, financial crime prevention, regulatory reporting, complaint handling and record-keeping.

In certain circumstances, we may process your personal data where it is necessary for our legitimate interests, or those of a finance provider or another third party, including operating and improving our business, communicating with you, preventing fraud, assessing applications and establishing, exercising or defending legal claims, provided those interests do not override your rights and freedoms.

Where consent is required, we will ask for consent before processing. You may withdraw consent at any time, although this will not affect processing undertaken before withdrawal. Where we process special-category personal data or criminal-offence data, we will only do so where an additional condition under applicable data protection legislation is satisfied, and appropriate safeguards are in place.  The specific lawful basis relied upon will depend on the purpose and circumstances of the processing.

When Personal Data is shared

Your personal data may be shared, where lawful and necessary, with lenders, funders, packagers, master brokers, product providers, brokers, agents, introducers, accountants, solicitors, valuers, surveyors, insurers, compliance advisers and other professional advisers before, during and after a transaction facilitated by us.

We may also use organisations to perform tasks on our behalf, including IT support, cloud hosting, CRM, document creation, electronic signature, communications, marketing, events, identity verification, AML, sanctions, fraud prevention, cyber security, backup, business continuity, auditing and legal services.

We may share personal data with credit reference agencies, fraud prevention agencies, law enforcement agencies, regulators, courts, public authorities, an authorised representative, a person you ask us to communicate with, companies we introduce you to, and tracing, debt recovery or customer service providers where relevant and lawful.

Lenders and other finance providers normally act as separate data controllers for their underwriting, financial crime, lending and regulatory activities. Their own privacy information applies to their processing. We may approach more than one prospective lender where reasonably necessary to identify a potentially suitable arrangement.

If we sell, transfer, restructure or merge all or part of our business or assets, we may share data with relevant parties and advisers, subject to appropriate confidentiality, security and legal controls.

We do not sell personal data.

What are your data protection rights and choices?

Your personal data is protected by legal rights, which include: 

  • Right to be informed – Individuals have the right to be informed about the collection and use of their personal data
  • The right of access to your personal data – Individuals have the right to access and receive a copy of their personal data and other supplementary information.
  • The right to rectification- Individuals have the right to have inaccurate personal data rectified or completed if incomplete.
  • The right to erasure – Individuals have the right to have their personal data erased.
  • The right to restrict processing – Individuals have the right to request the restriction or suppression of their personal data.
  • The right to portability – This allows individuals to obtain and reuse their personal data for their own purposes across different services.
  • The right to object – this gives individuals the right to object to the processing of their personal data in certain circumstances, it also gives individuals the absolute right to stop their data being used for direct marketing
  • The right in relation to automated decision making and profiling – this allows individuals to object to their data being used in an automated individual decision-making process (making a decision solely by automated means without any human involvement) and profiling (automated processing of personal data to evaluate certain things about an individual). Profiling can be part of an automated decision-making process.

 

There may be reasons why we need to keep or use your data, but please tell us if you think we should not be processing your data.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email hello@swbf.co.uk

For further information on how your information is used, how we maintain the security of your information and your rights in relation to it, please contact us via email hello@swbf.co.uk or call us on 01225 800849.

How long is your data kept?

We will retain your personal data as long as you are a customer with us. We may retain your personal data beyond this date for the purposes mentioned above and will in any case at all times retain your personal data for the minimum period required by law. We may also retain your data to deal with any disputes, to maintain records and to show we have dealt with you fairly.

We may also retain your data for research and statistical purposes in which case we will ensure it is kept private and used only for these purposes.

Data about live and settled accounts is kept on credit files for six years from the date they’re settled or closed. If the account is recorded as defaulted, the data is kept for six years from the date of the default.

Marketing

SWBF understands that with the introduction of the Consumer Duty, it is likely the level of communications issued by our business will increase. This will be necessary to support customers to understand the products and services offered and to provide support to customer throughout the lifecycle of the relationship.

Our Company would like to send you information about products and services of ours that we think you might like, as well as those of our partner companies.

If you have agreed to receive marketing, you may always opt out at a later date.

You may opt out at any time by using an unsubscribe link or contacting hello@swbf.co.uk.  We will retain the minimum information required to record and respect your preference.

Cookies

SWBF’s website may use cookies and similar technologies to operate the site, remember preferences, understand use and support communications or marketing. Necessary cookies may be used without consent where permitted. Non-essential cookies will only be used where the required consent has been obtained.

Cookies are small text files placed on a device to collect standard internet log and visitor behaviour information. When you visit our website, information may be collected automatically through cookies or similar technologies.

How do we use cookies?

  • operating and securing the website;
  • remembering choices or preferences where functionality is enabled;
  • understanding how visitors use the website; and
  • measuring the performance of content or campaigns where consent has been obtained.

What types of cookies do we use?

There are a number of different types of cookies, however, our website uses:

Functionality – Our Company uses these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.

Advertising – Our Company uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address. 

You can use our cookie control where available and set your browser to refuse or remove cookies. Some website features may not function correctly if certain cookies are disabled.

Privacy notices of other websites

Our website may contain links to other websites. This privacy notice applies to SWBF. If you follow a link to another website, that organisation’s privacy notice will apply and you should review it to understand how it uses personal data.

Changes to our privacy notice

We keep this privacy notice under regular review and place the current version on our website. We may update it following changes in law, regulation, services, technology providers, AI use or other processing. Where a change is material, we will take reasonable steps to bring it to the attention of affected individuals.

This privacy notice was last updated on 1 September 2026.

Use of Artificial Intelligence

We use artificial intelligence (“AI”) and AI-enabled technology to assist authorised employees in processing personal data for business administration and the provision of our services.

Our approved AI use currently includes Microsoft 365 Copilot. It may assist with drafting and improving correspondence, reports, policies, client-facing documents and marketing content; summarising authorised documents, emails and meeting information; organising information and identifying actions; searching authorised Microsoft 365 information; and supporting analysis and administration.

AI may support administrative tasks, review or summarise information, identify patterns, produce draft content or otherwise assist employees. AI output can be incomplete or inaccurate and relevant output is subject to human review before it is relied upon for a customer, compliance or material business decision.

We only process personal data necessary for the stated purpose and apply appropriate contractual, technical and organisational safeguards. Staff must use approved business systems and must not enter confidential or personal information into unauthorised public AI services.

How to contact us

If you have any questions about Our Company’s Privacy Policy, the data we hold on you, or you would like to exercise one of your data protections rights, please do not hesitate to contact us.

Email: dansmith@swbf.co.uk

Telephone: 01225 800849

Address: South West Business Finance, The Hayloft, Pickwick Workshops, Park Lane, Corsham, SN13 0HN

How to make a complaint and contact the appropriate authority

If you are unhappy about how your personal data has been used, please contact us using the details above. We will register and investigate your complaint and explain the outcome.

You also have a right to complain to the Information Commissioner’s Office which regulates the processing of personal data. You can contact them at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, on 0303 123 1113 or by email to casework@ico.org.uk. See also https://ico.org.uk/global/contact-us/.



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