Last Updated: 16 November 2023
Senior Capital Solutions, a company registered in London, UK, whose registered office is located at One Angel Court, London, UK, EC2R7HJ, (“Senior Capital,” “we,” “us,” or “our”) respects your privacy and is committed to protecting it through our compliance with this Privacy Policy (“Policy”).

1.     Who We Are

Senior Capital Solutions provides funding for later life assets globally.  If your mortgage was originated with one of our partners, you can see more about how we process your information by visiting our partner’s websites listed at the bottom of this page. Senior Capital Solutions is a Data Controller which means that we are collecting your personal information on our own behalf.  We collect this information so we can monitor performance of our website.

2.     Scope

We respect the privacy of our clients, and users of our website, and developed this Policy to demonstrate our commitment to protecting your privacy.  In order to deliver our website to you, from time to time we collect personal information.  This Policy describes:

• The types of personal information we may collect or that you may provide when you use or access our website.
• Our practices for collecting, using, maintaining, protecting, and disclosing that personal information.

This Policy applies only to personal we collect on this website.  This policy DOES NOT apply to information that:

• We collect offline or through any other means.
• You provide to or is collected by any third party, including through any application or content that may link to or be accessible from or on the website. These third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.

Our website may contain links third-party websites, which do not operate under this Policy, to connect you with partners, programs, products, and services to bring your financial goals to life.  These third-party websites may independently solicit and collect personal information from you.  While we strongly support the protection of privacy on the Internet, we do not have control over, and cannot be responsible for, the actions of other third parties.  We encourage you to review the privacy policies of all third-party websites you visit to understand their information practices before providing personal information directly to them. Please read this Policy carefully.  It is your choice whether or not to provide personal information to us.  If you choose not to provide your personal information to us, you may not be able to use our website and we may not be able to communicate with you.  If you do not agree with our policies and practices, do not access or use the website. By accessing or using the website, you accept and agree to be bound and abide by our Privacy Policy. 

3. Information We Collect and How We Collect It

We may collect several types of information from and about you, including information:

• By which you may be personally identified, including your full name, email address, phone number, information relating to your inquiry and any other information you may provide using the “Contact Us” feature on our website..
• About your internet connection, the equipment you use to access our website and other usage details.

We collect this information:

• Directly from you when you provide it to us, such as when you use the “Contact Us” feature on the website.
• Automatically when you access or use the website.

A. Information Provided by You

We collect the following types of personal information from you when you access the website.  The most common of these circumstances where you would provide personal information and the categories of personal information that we collect in those circumstances include the following:

1. Contact Us. When you use the “Contact Us” feature on the website, you will send an email to our customer service. In our email exchanges, we may ask you to provide, or confirm, personal information, including your first and last name and email address, your phone number, and the name of your employer so that we can better serve you.

1. Phone Calls Related to Your Inquiry. If you use the “Contact Us” feature on the website, we may call you to discuss your inquiry in further detail. In these phone calls, we may ask you to provide personal information, including first name, last name, and email address, so that we can provide you with relevant information.

 

• When You Apply For A Job. When you send us your CV, we may use your personal information on your CV or in any cover letter or other information you provide to us to evaluate you for a position with the company and to check your background or references.

  The above list provides examples of the personal information that may be collected when using the website. If you do not want us to collect your personal information, please do not provide it to us.  

B. Information that We Collect Automatically From You

  When you access and use the Website, we may use technology to automatically collect information to improve our Website and to deliver a better and more personalized service.

1. Usage Details. When you access and use the Website, we may automatically collect certain details of your access to and use of the Website, including location data, time of visit, length of time you visit the Website or specific pages, page views, scroll depth, logs, scoring content that you are interested in, and other communication data and the resources that you access and use on or through the Website.
2. Device Information. We may collect information about your device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, network information, Flash version, JavaScript support, screen resolution, and screen color processing ability.

C. Information Collection and Tracking Technologies

The technologies we use for automatic information collection may include:

1. Cookies (or browser/mobile cookies). When you visit our Website, we may assign your computer one or more cookies to help you navigate our Website efficiently, to personalize your online experience, and to perform certain functions, including Website traffic analysis. Through the use of a cookie, we also may automatically collect information about your online activity on our site, such as the web pages you visit, the links you click, and the searches you conduct on our site. Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies. If you choose to decline cookies please note that you may not be able to sign in or use some of the interactive features offered on our Website.  A cookie is a small text file that is stored on a user’s computer for record keeping purposes. Cookies can be either session cookies or persistent cookies.  A session cookie expires when you close your browser and is used to make it easier for you to navigate our Website.  A persistent cookie remains on your hard drive for an extended period of time.  For example, when you sign in to our Website, we will record your GUID (Globally Unique Identifier) in the cookie file on your computer. This cookie is removed when you sign-out.  In the case of sites and services that do not use a user ID, the cookie will contain a unique identifier.  We may allow our authorized service providers to serve cookies from our Website to allow them to assist us in various activities, such as doing analysis and research on the effectiveness of our site, content and advertising. You may delete or decline cookies by changing your browser settings (click “Help” in the toolbar of most browsers for instructions).  If you do so, some of the features and services of our Website may not function properly
2. Web Beacons and Other Technologies. We may use standard Internet technology, such as web beacons and other similar technologies, to track your use of our Website. We also may include web beacons in promotional email to determine whether messages have been opened and acted upon. The information we obtain in this manner enables us to customize the services we offer to our users and to measure the overall effectiveness of our Website.  Web beacons (also known as clear gifs, pixel tags or web bugs) are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users or to access cookies.  Unlike cookies, which are stored on the user’s computer hard drive, web beacons are embedded invisibly on the web pages (or in email) and are about the size of the period at the end of this sentence. Web beacons may be used to deliver or communicate with cookies, to count users who have visited certain pages and to understand usage patterns.

• Google Analytics. We use Google Analytics provided by Google Inc. It uses cookies to collect certain information, for example, information about the operating system and the browser that you use, your IP address, the website you previously accessed (referrer URL) and the date and time of your visit to the Website.  On subsequent repeated visits to the Website, frequently used information is automatically displayed for you.  We are able to track your usage patterns with the help of the cookies. The information generated by cookies about the use of the Website is transmitted to a Google server, which may be located within or outside of, the United States, and stored there. Google will use this information to evaluate your use of the Website.  Google may transfer these rights to third parties insofar as it is required to do so by law or in order that data may be processed on Google’s behalf. By accepting this policy, you consent to the processing of your data by Google.

4. Purposes and Our Legal Bases for Processing Personal Information

Purposes for using personal information. While the purposes for which we may process personal information will vary depending upon the circumstances, in general we use personal information for the purposes set forth below.

• Provide you with an overview of what we do.
• To respond to the inquiries you send via the “Contact Us” feature on this website
• To contact you, your prior employers or references in regard to a job inquiry
• To evaluate you for any open positions with the company
• Manage the Website
• Complete a transaction or service requested by you.
• Develop new services and to enhance, improve or modify our Website.
• Perform research and analysis about your use of, or interest in, our Website.
• Track and analyze non-identifying and aggregate usage and volume statistical information from our users.
• Exercise, defend, or protect our legal rights or the rights of our clients or third parties.
• Keeping our Website and IT systems secure.
• Ensuring that our own processes, procedures and systems are as efficient as possible.
• For legal compliance purposes.

Legal Basis for Processing.  The General Data Protection Regulation (GDPR) requires that we inform you of the legal bases for our processing of your personal information.  Where the GDPR is applicable, our legal basis for processing your personal information will depend on the personal information concerned and the specific context in which we collect it.  We rely on the following lawful basis for processing personal information:  your explicit consent, our legitimate interests, and compliance with legal obligations. When you provide us with your personal information by using the “Contact Us” feature,  our legal basis for the processing of that personal information is that processing is necessary to respond to your inquiry and process your requests. When you provide us with personal information related to a job opportunity, our legal basis for processing your personal information is your explicit consent and that processing is necessary to evaluate you for open positions with the company. We also collect and process personal information about you as necessary to provide the Website, product development and improvement, and/or product usage analytics.  In these instances, our lawful basis of processing your personal information is our legitimate interests (when not overridden by your data protection interests or fundamental rights and freedoms). If you have any questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided below.

5.     How Long We Retain Your Personal Information

We will retain your personal information for as long as is needed to fulfill the purposes set forth in this Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

6.     Sharing of Personal Information

We may share your personal information as necessary to provide the Website you request, including sharing information with our third party service providers, when required by law, to protect rights and safety, and with your consent.  Your personal information is not used for other business purposes than providing the Website to you and reporting to our Clients. We may share personal information with:

• Authorized service providers:  We may share your personal information with our authorized service providers that perform certain services on our behalf.  These services may include delivering our Website to you, providing customer service and support for your inquiries to us, supporting our Website functionality, and to assist us in completing diligence related to transactions that may be of interest to you.

• Our investors:  We may share your personal information with our investors who may evaluate and approve or deny proposed business relationships, investments, debt financing or otherwise.

 

• Other situations:  We also may disclose your information:

1. In response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.
2. When we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our company, our users, our employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce our website terms and conditions or other agreements or policies, related to this Privacy Policy, to our Websites or to our Services.
3. In connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
4. When you provide us with your consent to share your information with third parties.

Aggregated and Non-personal information: We may share aggregated and non-personal information we collect under any of the circumstances set forth in this Policy.  This information does not contain any personal information and may be used to develop website content and services that we hope you and other users will find of interest and to target content and advertising.  

7. Cross-border Transfer

Your personal information may be transferred to, stored, and processed outside your country of residence in a country, including the United States, that is not regarded as ensuring an adequate level of protection for personal information under European Union law.  For example, we store all data in United States-based databases.  Where this is the case we will transfer the personal information where we are satisfied that there are comparable levels of protection equivalent to your country of residence by using a legitimate transfer mechanism to the extent required under applicable laws, such as pursuant to contractual clauses and other safeguards.  Under certain data protection laws and regulations, there may be additional requirements with which we must comply before transferring any personal information outside of the territory from which it has been collected, including without limitation, having obtained explicit consent from you with respect to such offshore transfer of personal information and undertaken certain security assessments mandated by local laws and regulations.

8. Your Privacy Rights

You may have certain rights in relation to your personal information. If you would like to exercise any of them, please contact us (contact details below). We will consider all such requests and provide our response within a reasonable period (and in any event within any time period required by applicable law).  Please note, however, that certain personal information may be exempt from such requests in certain circumstances.  If an exception applies, we will tell you this when responding to your request.  We may request you provide us with information necessary to confirm your identity before responding to any request you make.   How You Can Access or Request to Delete Your Information:  You may request to have your personal information that you provided when you used the “Contact Us” feature along with the information relating to your use of the Website removed from our databases, as well as request for the deletion/deregistration of any online accounts you have created (where applicable) by submitting a request to our contact information set forth at the end of this Policy, and insert “Privacy Rights Request” in the subject line.  We will remove such information as soon as practicable for us, however, we may still retain certain information associated with your account for analytical purposes and record keeping integrity, as well as to prevent fraud, collect any fees owed, enforce our terms and conditions, take actions we deem necessary to protect the integrity of our web site or our users, or take other actions otherwise permitted by applicable law.  In addition, if certain information has already been provided to third parties as described in this Policy, retention of that information may be subject to those third parties’ policies. Your Choices About Collection and Use of Your Information:  You can choose not to provide us with certain information, but that may result in you being unable to use certain features of our Website because such information may be required in order for you to receive personalized guidance, a financial health report, and recommended connections to facilitate your achievement of your financial goals.

9. Data Security

The security and confidentiality of your personal information is important to us.  We have implemented reasonable measures (including by taking physical, technical, and administrative measures) to protect your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. While we are focused on the security of your personal information and follow strict standards, processes and procedures that are designed to protect your personal information, you must remember that the Internet is a global communications vehicle open to threats, viruses and intrusions from others and so we cannot promise, and you should not expect, that we will be able to protect your personal information at all times and in all circumstances. The safety and security of your information also depends on you. Users should also take care with how they handle and disclose their personal information and should avoid sending personal information through insecure email.  Where we have given you (or where you have chosen) a username and password which enables you to access the Services, you are responsible for keeping these details confidential. We ask you not to share your password with anyone.

10. No Collection of Information from Children

The Website are not intended for use by children under 16 years of age. We do not solicit or knowingly collect any information from visitors or users under 16 years of age.  Please do not use the Website if you are under 16 years of age.  If we learn we have collected or received personal information from a child under 16, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us immediately through the contact information found in this Privacy Policy.  

11. No Rights of Third Parties

This Policy does not create rights enforceable by third parties.  

12. Changes to this Policy

We will occasionally update this Policy to reflect material changes in our privacy practices.  If we make any material changes in the way we collect, use, and/or share your personal information, we will notify you by email and posting the modified Policy on our Website and indicating at the top of the Policy the date it was last updated, and, where required by applicable law, obtain your consent.  We encourage you to review the Policy each time you visit the Website to see if this Policy has been updated since your last visit to make sure you understand how your personal information will be processed.

13. Additional Information for Residents in Certain Jurisdictions

In this section, we set forth additional information as required under applicable privacy laws in certain jurisdictions.

European Union/European Economic Area

If you are an individual located in the European Union or European Economic Area, you have the following rights, under the GDPR, regarding your personal information: You have the right to request access to your personal information, and the rectification of inaccurate personal information concerning you and obtain a copy of the personal information held by us.  You have the right to obtain the deletion or the restriction of processing of your personal information in certain circumstances, including when the data are no longer necessary in relation to the purposes for which they were collected or otherwise processed, except when we are required by law to maintain or otherwise process your personal information, for the establishment, exercise, or defense of legal claims, or for the protection of the rights or another person.  You may have the right to request that we stop processing your personal information and/or to stop sending you marketing communications.  In certain circumstances, you may have the right to be provided with your personal information in a structured, machine readable and commonly used format and to request that we transfer the personal information to another data controller without hindrance.  You also have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence, place of work, or place of an alleged infringement of the applicable data protection law. If you would like to make such a request, please email: SeniorCapitalSolutions.com and insert “GDPR Privacy Rights Request” in the subject line. To protect your privacy and security, we may take steps to verify your identity before taking action on your request.

14. Contact Us

If you have any questions about this Policy or our privacy practices, please contact us as follows: Senior Capital Solutions Attn:  Data Protection Officer Rudy Khaita 3 More London Riverside London, SE1 2AQ UNITED KINGDOM

15.  Partner Privacy Polices

More2Life: https://more2lifeapex.co.uk/privacy-policy