Bolton Business Finance Ltd Privacy Policy - Bolton Business Finance Ltd

Last Updated: 25 September 2026

1. Introduction and Purpose

This Privacy Notice explains how Bolton Business Finance Ltd (“We”, “Us”, “Our”, “the Broker”) collects, uses, stores, shares and protects your personal data when you engage with Us as a client, prospective client, introducer, or visitor to Our website (https://bolton-finance.co.uk).

We are committed to protecting your privacy and handling your personal data in a transparent, fair and lawful manner in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, the Privacy and Electronic Communications Regulations (PECR), and the Code of Practice and Minimum Standards of the National Association of Commercial Finance Brokers (NACFB).

This Notice forms part of Our Terms of Business and is provided to You separately or alongside any Confirmation of Instructions Letter. By providing personal data to Us or by signing Our Terms of Business, You acknowledge that You have read and understood this Notice.

Important: Bolton Business Finance Ltd is not authorised or regulated by the Financial Conduct Authority (FCA). We provide non-regulated commercial finance broking services only (business loans, invoice finance, asset finance, merchant cash advances, trade finance, commercial mortgages, unregulated bridging loans, property development finance and non-regulated buy-to-let mortgages). We work with an unrestricted number of Lenders and act solely as an introducer.

2. Who We Are (Data Controller)

Data Controller: Bolton Business Finance Ltd

Company Number: 12495909 (registered in England and Wales)

Registered Office: Westgate House, Westgate Avenue, Bolton, Greater Manchester, BL1 4RF

ICO Registration: ZA712923 (you can check Our registration at www.ico.org.uk)

NACFB Membership: We are a full member of the National Association of Commercial Finance Brokers. You can verify Our status at www.nacfb.org.

Data Protection Contact / Information Officer: Marcus Wright

Telephone: 0161 546 9128

Email: marcus@bolton-finance.co.uk

Website: https://bolton-finance.co.uk

3. What Personal Data We Collect

We collect and process the following categories of personal data depending on the nature of the enquiry or engagement:

3.1 Identity and Contact Data

Full name, title, previous names/surnames, date of birth, nationality, marital status, gender, dependants and ages
Home address (current and previous if less than 3 years), residential status (homeowner/tenant/family), email address, mobile and landline telephone numbers
National Insurance number (where required for identity verification or credit searches)

3.2 Financial and Credit Data

Employment/self-employment status, job title, employer, length of service, income (employed or self-employed)
Residential property value, outstanding mortgage, monthly payments, arrears, CCJs, bankruptcy or insolvency history
Business turnover, accounts, management figures, bank statements (usually 3 to 6 months), existing borrowing, overdrafts, liabilities, hard assets
Details of adverse credit, tax arrears (VAT, PAYE, Corporation Tax), claims or lawsuits involving the business or directors
Business credit information, such as credit ratings, credit limits, CCJs and company financial data, obtained from business information providers

3.3 Property and Transaction Data (for Property Finance)

Property address, value, purchase price, existing lending, loan amount required, term, type of property, bedrooms, rental income, tenants, units (HMO/MUFB)
EPC rating, planned works/development costs, GDV, source of deposit, exit strategy, portfolio details
Security offered (including personal guarantees), estimated values

3.4 Business and Corporate Data

Company name, company number, trading name, start date, VAT registration, trading address, ownership structure, directors/shareholders (25%+), PSC information
Main business activities, number of employees, value of assets, card payment providers and average monthly card sales (for MCA/invoice finance)

3.5 Special Category / Sensitive Data

We do not routinely collect special category data (e.g. health, racial/ethnic origin, political opinions). If such data is required (for example health information relevant to keyman insurance or capacity), We will only process it with Your explicit written consent and for a specific purpose. Please do not include such information in enquiry forms or messages unless We ask for it.

You may choose to tell Us about circumstances that affect You, such as health, bereavement or other characteristics of vulnerability, so that We can support You appropriately. We will ask for Your explicit consent before recording or using this information, will share it with a Lender only where it is necessary and You have agreed, and will handle it in line with Our Vulnerable Customer Policy.

3.6 Technical and Website Data

IP address, browser type, device information, cookies and similar technologies (see Section 12)
Information You provide via website contact forms, enquiry forms, online advertising lead forms or chat
Advertising and campaign information showing how You found Us, such as the advert or search campaign You responded to

3.7 Information We Create About Your Enquiry

When We receive an enquiry We create information to help Our advisers respond, including an enquiry priority score, the finance product that appears most suitable, an assessment of whether the enquiry may fall within FCA regulation (and so outside the services We can provide), a short summary of the enquiry, and the adviser allocated to it. Section 6.1 explains how this is produced.

4. How We Collect Your Data

We collect personal data from the following sources:

Directly from You, via telephone, email, fact-find forms (Property Finance Fact Find and general Application Form), Asset Schedule, website forms, online advertising lead forms (including Google and Meta), WhatsApp, or face-to-face meetings
From third-party introducers, accountants, solicitors or other professional advisers who refer You to Us (with Your knowledge or consent)
From publicly available sources such as Companies House and Land Registry
From business information and credit reference providers, including Redflag Alert, which supplies company credit and director information, and credit reference agencies used by Us or by Lenders
From Lenders and ancillary service providers (solicitors, valuers, surveyors) during the application and underwriting process
Via cookies and analytics tools when You visit Our website

5. Lawful Bases for Processing

Under UK GDPR Article 6 We rely on the following lawful bases:

Performance of a Contract: Processing is necessary to take steps at Your request prior to entering into a contract (Terms of Business / Confirmation of Instructions) and to perform Our Credit Broking Services under that contract.
Legitimate Interests: To assess and prioritise enquiries and match them to suitable products (including using the automated tools described in Section 6.1), to check whether an enquiry may fall within FCA regulation, to introduce You to suitable Lenders, to administer Our business, to prevent fraud, to improve Our services, and to send relevant commercial marketing communications where We have a soft opt-in or legitimate interest that is not overridden by Your rights (You may object at any time). We have assessed these interests against Your rights and a copy of Our assessment is available on request.
Legal Obligation: To comply with anti-money laundering (AML), counter-terrorist financing, fraud prevention, tax and other statutory requirements.
Consent: Where We process special category data or where We send electronic marketing and a soft opt-in is not available. You may withdraw consent at any time by contacting Us.

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 obligations, including identity verification, financial crime prevention, 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. Withdrawing consent does not affect the lawfulness of processing carried out before You withdrew it. Where We process special category personal data or criminal offence data, We will only do so where an additional condition under data protection law is satisfied and appropriate safeguards are in place. The specific lawful basis relied upon depends on the purpose and circumstances of the processing.

6. How We Use Your Personal Data

We use Your personal data for the following purposes:

To assess, prioritise and respond to Your enquiry, including through the automated assessment described in Section 6.1
To assess Your finance requirements and prepare a Lending Proposal
To source Finance Offers from an unrestricted panel of Lenders and introduce You to them
To complete Our fact-find, Application Form, Confirmation of Instructions Letter and Commission Disclosure Document
To coordinate valuations, legals, insurance and other ancillary services
To manage the relationship through to Completion and for aftercare / renewal opportunities
To comply with Our legal and regulatory obligations (including NACFB Code)
To prevent and detect fraud, money laundering and other crime
To send You service-related communications and, where permitted, marketing about products and services that may interest You
To maintain records for audit, complaints handling and professional indemnity purposes

6.1 Automated Assessment of Enquiries

When You make an enquiry, Our systems automatically review the information You have given Us, together with information We already hold about Your business, business credit information and public information from Companies House. This produces the information described in Section 3.7. Rules We have set produce the priority score and the regulatory assessment. An artificial intelligence (AI) service provided by Anthropic suggests the most suitable product and writes the summary.

Before any information is sent to the AI service We remove Your name, email address, telephone number and home address. The AI service does not use Your information to train its models.

This is profiling, but it does not decide the outcome of Your enquiry. The system cannot decline Your enquiry, contact You, or decide which Lender You are introduced to. Every enquiry is reviewed by one of Our advisers, who decides how to proceed, and an adviser reviews every Lending Proposal, Finance Offer and case closure. Where the system indicates that an enquiry may be regulated, this only means that an adviser will review it more closely.

You can ask Us to explain the assessment of Your enquiry, ask an adviser to reconsider it, or object to this processing, by contacting Marcus Wright (details in Section 2).

7. Who We Share Your Data With

We may share Your personal data confidentially and only as necessary with:

Lenders and Funders: Banks, alternative lenders, invoice finance providers, asset finance companies, bridging and development lenders on Our panel (details available on request). Different Lenders pay different commission models (fixed fee, percentage of amount borrowed, rate for risk, etc.).
Ancillary Service Providers: Solicitors, valuers, surveyors, insurance brokers, accountants and other professionals engaged in connection with Your application.
Credit Reference, Business Information and Fraud Prevention Agencies: Redflag Alert for business credit and company information, and credit reference and fraud prevention agencies used by Us or by Lenders for identity verification, credit scoring and fraud prevention.
Our Service Providers: Organisations that process data on Our behalf and under Our instructions: HubSpot (customer relationship management), Microsoft (email and office systems), Dropbox (document storage), Cloudflare (hosting of Our automated systems), Supabase (secure database for system records) and Anthropic (AI assessment of enquiries). Each is bound by a data processing agreement.
Professional Advisers and Regulators: Our accountants, solicitors, professional indemnity insurers, the NACFB, ICO, HMRC, courts and law enforcement where required by law.
Introducers: Where You have been referred to Us, or where We refer You, commission arrangements will be disclosed.
Business Transfer: In the event of a sale, merger or reorganisation of Our business.

We do not sell Your personal data.

7.1 Credit Searches and Fraud Prevention

With Your consent, We or a Lender may carry out a search with one or more credit reference agencies (CRAs) to assess Your application, check Your identity and prevent crime. A search may leave a footprint on Your credit file that other lenders can see, and Your data may be linked to that of any joint applicants or financial associates. We will tell You beforehand which type of search will be carried out. We can provide the identities of the CRAs used and how they share information on request.

We and fraud prevention agencies may use Your personal data to prevent fraud and money laundering and to verify Your identity. We do this on the basis of Our legitimate interest in preventing crime and protecting Our business, and to comply with the law. Law enforcement agencies may access this data to detect, investigate and prevent crime. If You are considered to pose a fraud or money laundering risk, fraud prevention agencies may hold Your data for up to six years.

7.2 International Transfers

Some of Our service providers store or process personal data outside the UK, in the European Economic Area and the United States. Transfers to the European Economic Area rely on UK adequacy regulations. Transfers to the United States are protected by Standard Contractual Clauses with the UK International Data Transfer Addendum or, where the provider is certified, the UK Extension to the EU-US Data Privacy Framework. For Our AI assessment We remove direct identifiers before any transfer. You can ask Us for more information about these safeguards.

8. How Long We Keep Your Data

We retain personal data only for as long as necessary for the purposes for which it was collected, including to satisfy any legal, accounting or reporting requirements.

Typical retention periods:

Client files and application records: duration of the relationship + 6 years (limitation period for contract claims)
Enquiry data where no engagement: up to 12 to 24 months for legitimate interest / soft opt-in marketing, or sooner if You object
Enquiry assessments (Section 3.7): kept with the enquiry or client record they relate to, for the periods above
System audit records of automated assessments: 24 months, or longer if needed for a complaint or claim
Fraud prevention records: up to 6 years
Website cookies: as set out in Section 12

9. Your Rights Under UK GDPR

You have the following rights in relation to Your personal data:

Right to be informed: This Privacy Notice provides the required information.
Right of access: You may request a copy of the personal data We hold about You (Subject Access Request), including any assessment of Your enquiry.
Right to rectification: You may ask Us to correct inaccurate or incomplete data.
Right to erasure (“right to be forgotten”): You may request deletion in certain circumstances.
Right to restrict processing: You may request that We limit how We use Your data.
Right to data portability: You may request Your data in a structured, commonly used and machine-readable format.
Right to object: You may object to processing based on legitimate interests, including the automated assessment of Your enquiry (and including direct marketing, which is absolute).
Rights relating to automated decision-making: We do not make decisions about You based entirely on automated processing. Our automated assessment supports Our advisers, who make every decision. You may ask for an adviser to review any assessment and to explain it to You (see Section 6.1).

To exercise any of these rights, please contact Marcus Wright (details in Section 2). We will respond within one month (extendable in complex cases). We may need to verify Your identity. There is usually no fee, but We may charge a reasonable fee or refuse unfounded or excessive requests.

10. Marketing and Communications

We may contact You by telephone, email or post about products and services that We believe may be of interest to You (including renewals, refinance opportunities and portfolio reviews).

For existing clients or those who have enquired, We rely on legitimate interests or soft opt-in under PECR. You can opt out of marketing at any time by:

Clicking the unsubscribe link in any marketing email
Emailing marcus@bolton-finance.co.uk with “Unsubscribe” in the subject
Calling 0161 546 9128

Service-related communications (e.g. updates on Your application, fee invoices, Terms of Business) are not marketing and will continue.

11. Data Security

We take appropriate technical and organisational measures to protect Your personal data against unauthorised or unlawful processing, accidental loss, destruction or damage. These include secure IT systems, access controls, staff training, encrypted communications where appropriate, and secure storage of paper files (We operate a largely paperless office with documents saved to Dropbox and notes in HubSpot). Our automated systems use encrypted credentials, restricted database access and an audit log of every automated assessment, and access to Our records is limited to Our advisers. We maintain professional indemnity insurance.

12. Cookies and Website Tracking

Cookies are small text files placed on Your device when You visit Our website. Essential cookies needed for the website to work are always set. We also use analytics and advertising cookies, listed below. Our cookie banner tells You about these when You first visit. You can block or delete cookies at any time through Your browser settings, and refusing non-essential cookies will not stop the website working.

We use the following types of cookie:

Essential: to remember Your cookie choices and keep the website secure.
Analytics: to understand how visitors use the website so We can improve it (Google Analytics, HubSpot).
Advertising: to measure how well Our Google and LinkedIn adverts work and to show relevant adverts on other websites (Google Ads, LinkedIn).

Cookie	Provider	Type	Typical expiry	Purpose
eucookielaw	Bolton Business Finance (Jetpack)	Essential	Up to 6 months	Records that the cookie banner has been seen
_ga, _ga_FT9EXFX45N	Google Analytics	Analytics	2 years	Distinguishes visitors and sessions
__hstc, hubspotutk, __hssc, __hssrc	HubSpot	Analytics	Session to 6 months	Tracks visits and links form enquiries to visits
_gcl_au	Google Ads	Advertising	90 days	Measures conversions from Google adverts
bcookie, lidc, li_sugr, UserMatchHistory	LinkedIn	Advertising	1 day to 1 year	Measures LinkedIn adverts and supports retargeting

Cookie names and expiry periods are set by the providers and may change. For more information about cookies, visit www.allaboutcookies.org.

12.1 Links to Other Websites

Our website contains links to other websites. This Privacy Notice does not apply to those websites, and We recommend You read their privacy notices.

13. Complaints

If You are unhappy with how We have handled Your personal data, please contact Marcus Wright in the first instance (details in Section 2). We will acknowledge Your complaint within 30 days, investigate it and tell You the outcome without undue delay.

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO):

Information Commissioner’s Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Telephone: 0303 123 1113
Email: casework@ico.org.uk
Website: www.ico.org.uk/make-a-complaint

As a NACFB member We also follow the NACFB complaints and mediation procedures set out in Our Terms of Business.

14. Changes to This Privacy Notice

We may update this Privacy Notice from time to time to reflect changes in law, Our practices or Our services. The latest version will always be available on Our website or on request. Material changes will be notified to existing clients where appropriate. This version is dated 25 September 2026.

15. Contact Us

If You have any questions about this Privacy Notice, how We handle Your data, or wish to exercise Your rights, please contact:

Marcus Wright
Information Officer / Director
Bolton Business Finance Ltd
Westgate House, Westgate Avenue, Bolton, Greater Manchester, BL1 4RF
Tel: 0161 546 9128
Email: marcus@bolton-finance.co.uk
Website: https://bolton-finance.co.uk

This Privacy Notice should be read in conjunction with Our Terms of Business and any Confirmation of Instructions Letter.

Simon Johnson

Simple, easy and professional. Listen to business requirement and found the perfect funding solution. Thank you...!

Ihsan Gungor

Great help and fast

Hassan Raza

Many Thanks Marcus for arranging funds for my business despite having several challenges on credit file.

Craig Barclay

Amazing service - Thank you Marcus first class

Shazad “Shaz” Khan

The service is undecrible. I had a lot of issue through other brookers but it has been dealt professionally by Marcus. The service i received is more then beyond expectations.

Gordon Angus

I can't recommend Bolton Business Finance Ltd highly enough. They were able to get us excellent terms and a higher loan amount than expected - far better than any other broker. Marcus was very friendly, helpful and supportive throughout the application and I will definitely use their services again.

Gerad Barclay

Exemplary Business Finance Service Bolton Business Finance and its MD Marcus Wright are professional and an example to others in the industry. Strongly recommended. Most business people searching for a business finance broker will have dealt with Estate Agents, Recruitment Agencies, or both. You know the types; recruitment “consultants” that try to palm you off with unsuitable candidates having doctored the CV to look great, or estate agents that assure you the enquirer is a “Cash Buyer” or in a fabulous position when in fact they have not even got an offer yet for their overpriced property. Many Business Finance Brokers are as above, probably worse. They work the numbers game of collecting applicants then punt the applicants around the types of lenders that want to tie you down with crazily high interest rates, unviable repayment terms and the ubiquitous PG. My advice is to look out for these shady practitioners. They want your personal ID, 6 months Bank Statements and annual accounts before even discussing solutions to your problem. They have only a passing conversational interest in your business. Be especially alert to the additional introduction “Fee” for getting to offer stage. One such broker added a 5% fee unto an already sky-high rate of interest front-loaded unto the principle, no reduction for early settlement, and of course the dreaded PG. Try getting 5% Interest per year on deposit of £200,000…. It is currently almost impossible yet, some brokers want 5% (£10,000 on that £200K) just for the introduction. That’s 3–5 times what Estate Agents will charge, and they typically must do some work and wait 6 months for the transaction to complete. The broker may well have punted your most personal details by email to any number of lenders leaving you exposed in many ways. Marcus did none of the above. He listened to the requirements. Noted preconditions, made no promises but came back very quickly with imaginative propositions. Very personal details and confidential information were requested only when there was agreement in principle. I will certainly use again.

Tyler Homeyard

Great company to deal with. Marcus is a great guy and knows what he’s doing. They helped me with factoring my invoices on Courier Exchange. Very seem less process. Highly recommend.