Who are we?

2XL Commercial Finance Ltd (“2XL”) are Commercial Finance Brokers based throughout England. We act as
commercial finance brokers and advisers for our customers. 2XL Commercial Finance Ltd is Authorised and
Regulated by the Financial Conduct Authority.

What data do we collect?

2XL Commercial Finance collects data from you which may include any of the following:

• your name, date of birth, residential and email address, contact telephone numbers, national insurance
number, passport number/driving licence number, country of residence for tax purposes, nationality, bank
account details, details of your assets and liabilities, details of your income and expenditure, details of your
occupation;
• information about your contact with us e.g. meetings, phone calls, emails/letters;
• information that is automatically collected e.g. via cookies or IP addresses when you visit our website
• information classified as ‘sensitive’ personal information e.g. relating to your health, marital or civil
partnership status. This information will only be collected and used where it is needed to source appropriate
financing you have requested, or to comply with our legal obligations;
• information you may provide us about other people e.g. joint applicants, Powers of Attorney, trustees or
beneficiaries
• as well as any other information asked for in lender application forms and related documents

How do we collect your data?

You directly provide 2XL with most of the data we collect and we collect and process data from a variety of sources
including:

• meetings with one of our commercial brokers
• telephone conversations you have with us
• email or letters you send to us
• an application form for a lending product
• use of our website, via your browser’s cookies
• from your existing lenders
• from any other professional advisers e.g. your Accountant, your Solicitor, another financial services firm that
asks us to provide specialist advice (e.g. an independent financial adviser or a mortgage broker
• through your voluntary completion of a customer survey or provision of internet feedback, such as Google
reviews.

Special Category Data

In the course of your interactions with 2XL Commercial Finance you may share information that is classified as
‘Special Category Data’. This could include data about:

• Race
• Ethnic origin
• Politics
• Religion
• Trade union membership
• Genetics
• Biometrics
• Health
• Sex life
• Sexual orientation

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 2XL will always seek explicit consent from you to store and process
such information.

How will we use your data?

We take your privacy seriously and we will only ever collect and use information which is personal to you where it is
necessary, fair and lawful to do so. We will collect and use your information only where:

• you have given us your permission (consent) to send you any marketing information which we believe may
be of interest and benefit to you. You have the right to withdraw your consent at any time;
• it is necessary to provide our services to you, that is, the sourcing, application. or administration in
association with arranging commercial financing;
• it is necessary for us to meet our legal or regulatory obligations, such as for the detection and prevention of
fraud.
• it is in the legitimate interests of 2XL Commercial Finance Ltd, for example:

– to deliver information and guidance so you are aware of the options that will help you get the best
outcome from our dealings with you;
– where we need to process your information to better understand you and your needs so we can send you
relevant communications about product updates;
– to mitigate business and operational risks, complying with internal policies, investigating, detecting, and
preventing fraud and other crime, ensuring information security, purchasing services from third parties
which support us in complying with our regulatory and legal obligations, maintaining the relationship and
otherwise interacting with you, protecting 2XL’s interests including legal rights and claims;
– where it is in the legitimate interests of a third party e.g. sharing information with your Accountant,
Solicitor, or other financial services firms.

When evaluating whether legitimate interests can be relied on as a legal basis for the processing activities
described above, a balancing test is carried out to ensure that the use of your personal data will not be
overridden by your interests or fundamental rights and freedoms.

If you give us information about other people (such as dependents, joint account holders, fellow directors, or
guarantors), which we will use to provide our services, then you confirm that you know they agree to this or that you
are otherwise allowed to give us this information. We will send them a copy of this Privacy Notice to ensure they are
aware of how their personal information will be processed.

If you do not wish us to collect and use your personal information in these ways, it may mean that we will be unable
to provide you with an appropriate recommendation, information and guidance or indeed maintain our relationship
with you. If we ask you to provide us with your personal information to comply with a legal requirement, or to allow
us to enter, or perform a contract with you, then we may reject or delay dealing with you until the relevant
information is received to our satisfaction e.g. for Anti-Money Laundering, Know Your Customer, the source of your
wealth or tax purposes.

How do we store your data?

Your data is stored electronically on a cloud encrypted server which is based in the United Kingdom. 2XL ensures the
security of your data in this way at all times.
When your personal data is collected initially on paper, this will be shredded as soon as relevant information has
been transferred and secured electronically. No data will be stored on computer hard drives, removeable devices
such as CDs, DVDs or memory sticks.

We will keep your data whilst we are carrying out services for you, and for 6 years after financing has been arranged
for you. Once financing arrangements are in place, data we will be stored but not processed in any way, unless we
are required to do so for legal reasons. Deletion of data which is no longer required to be kept will be carried out in
conjunction with our IT support services company and third-party suppliers, such as our client management system.

Marketing

2XL Commercial Finance Ltd 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.
2XL would like to send you information about our services that we think you might like.
If you have agreed to receive marketing material, you may opt out of this at any point in the future.

What are your data protection rights?

We would like to make you fully aware of all your data protection rights. Every individual is entitled to the following:

• The right to access – You have the right to request from 2XL details of the personal data we hold about you.
• The right to rectification – You have the right to request 2XL corrects any information you believe is
inaccurate. You also have the right to request that we complete any information you believe is incomplete.
• The right to erasure – You have the right to request that 2XL erases your personal data, under certain
conditions.
• The right to restrict processing – You have the right to request that 2XL restricts the processing of your
personal data, under certain conditions.
• The right to object to processing – You have the right to object to 2XL processing your personal data, under
certain conditions.
• The right to data portability – You have the right to request that 2XL transfers the data that we have
collected to another organisation, under certain conditions.
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 by email at info @2xlcommercial.com, by telephone on 01625 421 976, or by writing to us at 45 Hubbard
Road, Burton on the Wolds, Loughborough, Leicestershire, LE12 5AX

Cookies

2XL Commercial Finance Ltd uses cookies on our website to collect anonymous information about how visitors use
our site. Cookies are text files placed on your computer to collect standard Internet log information and visitor
behaviour information. This information is then used to help improve the site and give you the best possible
experience.
2XL understands that under the Privacy and Electronic Communications Regulation (PECR) opt-in consent is required
when these types of cookies are used.
For further information, visit www.allaboutcookies.org.

How do we use cookies?

2XL uses cookies in a range of ways to improve your experience on our website, including:
• Keeping you signed in
• Understanding how you use our website

How to manage cookies

You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your
browser. However, in a few cases, some of our website features may not function as a result.

Changes to our privacy policy

2XL keeps its privacy policy under regular review and places any updates on its web page.

How to contact us

If you have any questions about 2XL’s Privacy Policy, the data we hold on you, or you would like to exercise one of
your data protection rights, please do not hesitate to contact us.
Email: info@2xlcommercial.com
Call: 01625 421 976
Write to: 45 Hubbard Road, Burton on the Wolds, Loughborough, Leicestershire, LE12 5AX

How to contact the appropriate authority

Should you wish to report a complaint or if you feel that Our Company has not addressed your concern in a
satisfactory manner, you may contact the Information Commissioner’s Office at www.ico.org.uk