Privacy Notice

In this Privacy Notice, Carrick Capital, we, us and our means Lucky Growth Partners Ltd, trading as Carrick Capital.

• Company: Lucky Growth Partners Ltd
• Company number: NI725486
• Trading name: Carrick Capital
• FCA reference number: 1053350
• Status: Appointed Representative of Switcha Limited
• Principal firm: Switcha Limited
• Switcha FCA reference number: 828963
• ICO registration: ZB966973
• Registered office: Legal & Financial House, 137 York Road, Belfast, Northern Ireland, BT15 3GZ
• Privacy contact: [email protected]

For data protection purposes, Lucky Growth Partners Ltd is the controller of the personal information you provide through Carrick Capital, unless we tell you otherwise.

Where we share information with Switcha Limited, authorised credit brokers, lenders, 365 Finance, Zempler, business credit card providers, or other selected service providers, those organisations may act as separate controllers of your personal information and process it in accordance with their own privacy notices.

Carrick Capital helps business customers explore business finance and related business-service options.

We may use the information you provide to:

• understand your business and funding requirements;
• assess which brokers, lenders or service providers may be appropriate for your enquiry;
• introduce you to authorised credit brokers, lenders, finance providers and selected business service providers;
• support document collection and onboarding;
• assist with communications between you and relevant partners;
• refer your enquiry to alternative providers where funding is declined, unavailable or not suitable;
• comply with legal, regulatory, fraud-prevention and record-keeping obligations.

We do not guarantee that any finance or service will be available. Any offer, quote, rate, repayment term, approval decision or funding decision is made by the relevant broker, lender or provider, not by Carrick Capital.

Information you provide to us

• your name, email address, phone number, date of birth and role or position in the business;
• business name, company number, trading address, registered address and company or registration information;
• funding amount requested, funding purpose, preferred repayment term, business sector, trading history, turnover, VAT status and existing borrowing or finance;
• residential status, home address and other information needed by brokers, lenders or providers to assess eligibility;
• information you provide in forms, calls, messages, emails, return visits or uploaded documents;
• Funding Circle extra-question data where collected, such as previous-year turnover, profit or loss position, overdraft status, overdraft limit and overdraft use;

Documents you upload or provide

• bank statements, filed accounts, management accounts, tax documents and VAT returns;
• proof of identity, proof of address and company documents;
• finance agreements, invoices and other supporting documents relevant to your enquiry.

These documents may be used to support your enquiry, assess eligibility, assist onboarding, verify information, prevent fraud, and share relevant information with appropriate brokers, lenders or service providers.

Information collected automatically

• IP address, browser type and version, device type and operating system;
• pages visited, time spent on pages, form interactions and referral source;
• cookie and tracking data, advertising click identifiers and approximate location derived from your IP address.

We use this information to operate the website, improve user experience, monitor performance, prevent misuse, and measure marketing effectiveness.

Information from third parties

• authorised credit brokers, lenders, finance providers and business service providers;
• fraud prevention agencies, credit reference agencies and identity verification providers;
• Companies House, credit and business-information providers, public registers, marketing platforms, analytics platforms, introducers, affiliates, commercial partners and Switcha Limited where relevant to supervision, compliance or complaints.

We use personal information to respond to your enquiry, contact you, understand what type of finance or business service you are looking for, and help identify partners who may be able to assist.

We may share your information with authorised credit brokers, lenders, finance providers and selected business service providers where relevant to your enquiry. This is to help assess eligibility, identify appropriate finance or business-service options, support onboarding, and progress your enquiry.

If you submit a business funding enquiry and answer optional follow-up questions about invoice finance or asset finance, we may use your existing application details and those answers to check whether those products may be relevant. Where relevant, we may share your contact, business, company, funding and follow-up answers with selected invoice finance or asset finance brokers, lenders or finance providers so they can assess eligibility and contact you about those options.

Our finance and introducer partners may include

• Switcha Limited, as principal firm for regulated credit broking activity;
• 365 Finance, where appropriate to your enquiry;
• iwoca Ltd;
• Approved Business Finance Ltd;
• business credit card providers, where relevant to your enquiry;
• Zempler Bank, where a sole trader business bank-account application is offered and you choose to submit it;
• Funding Circle or other providers where provider-specific eligibility questions are used or relevant to your enquiry;
• other authorised credit brokers, lenders, finance providers or selected business service providers appropriate to your enquiry.

This partner list may change from time to time. We will only share your information where it is relevant to your enquiry and consistent with this Privacy Notice.

Where we share your information with a broker, lender, finance provider or business service provider, that organisation may act as a separate data controller and process your information in accordance with its own privacy notice, terms and procedures.

We may also process your information to support applications and onboarding, support reassignment where funding is declined or unavailable, comply with legal, regulatory and compliance requirements, improve our website and service, and send marketing communications where permitted by law.

Where required, marketing consent is collected separately from the core enquiry consent. You can opt out of marketing at any time.

We rely on different lawful bases depending on how and why we use your information.

Contract or steps before entering into a contract

We may process your information where necessary to provide the service you have requested, respond to your enquiry, and help connect you with relevant brokers, lenders or providers.

Legitimate interests

We may process your information where it is necessary for our legitimate business interests, provided those interests are not overridden by your rights and freedoms.

• operating Carrick Capital;
• responding to enquiries;
• matching enquiries with suitable brokers, lenders and providers;
• improving our website and service;
• preventing fraud and misuse;
• keeping business records;
• supporting compliance and complaints handling;
• measuring marketing performance.

Legal obligation

We may process your information where necessary to comply with legal, regulatory, tax, accounting, fraud prevention or reporting obligations.

Consent

We rely on consent where required, including for certain marketing communications, non-essential cookies, and certain data-sharing or processing activities where consent is the most appropriate lawful basis. You can withdraw consent at any time. Withdrawing consent does not affect processing that took place before withdrawal.

We may share your information with the following categories of organisations where relevant to the purposes described in this Privacy Notice:

• Switcha Limited, as principal firm for regulated credit broking activity;
• authorised credit brokers, lenders and finance providers;
• 365 Finance, where appropriate;
• business credit card providers, where relevant to your enquiry;
• Zempler, where a sole trader business bank-account application is offered and you choose to submit it;
• selected business service providers, such as insurance, banking, accounting, payment, utilities, energy, merchant-services, business credit card, company-formation or business-support providers;
• credit reference agencies, fraud prevention agencies and identity verification providers;
• Companies House and public-register data providers;
• website hosting providers, CRM platforms, customer support platforms, email, SMS and communications providers;
• analytics providers, advertising platforms and retargeting platforms, including Meta, TikTok, Google, Microsoft Clarity and Taboola;
• professional advisers, such as lawyers, accountants and compliance consultants;
• regulators, authorities, courts or law enforcement bodies where required.
• Anthropic, our AI technology provider, where you use the Virtual Fred automated chat assistant;

We do not sell your personal information as a standalone data list. However, we do share information with brokers, lenders and selected providers in order to deliver the introduction service you request, and we may receive commission or referral fees if you proceed with a product or service.

The brokers, lenders and service providers we introduce you to may use your information to assess eligibility, verify your identity, verify your business, prevent fraud, comply with anti-money laundering checks, carry out business verification checks, perform soft credit searches through credit reference agencies, and submit credit applications where you have agreed to proceed.

Soft credit searches should not affect your credit score. If a hard credit search is required, the relevant broker, lender or provider should explain this before it is carried out.

Fraud prevention checks may involve sharing information with fraud prevention agencies. If fraud or suspected fraud is identified, this may affect your ability to obtain credit, financial services, insurance, employment or other services in the future.

Carrick Capital does not make lending decisions. Any credit decision, affordability assessment, approval decision or funding decision is made by the relevant broker, lender or provider.

Zempler sole trader business account applications

If you are shown a Zempler sole trader business account application and choose to submit it, we may share information needed for that application with Zempler. This may include your name, title, date of birth, email, mobile number, home address, business name, business name to appear on a card, nationality, turnover, selected industry, selected occupation where captured, cash-deposit answers, whether the account will be your main account, account-purpose selections, selected product, accepted terms reference and tracking reference.

Zempler will process your information in accordance with its own terms and privacy notice. We do not persist sort code or account number by default; where returned immediately, those details are shown to you in the browser response.

365 Finance and merchant cash advance routes

Where your enquiry is suitable for a merchant cash advance or related business finance route, we may share application, applicant, company, address, card-sales, turnover, funding-purpose and supporting information with 365 Finance where appropriate. They may provide application links, open banking links, offers, document requests, agreements or onboarding steps directly to you.

Provider-specific questions

We may collect lender or provider-specific information, such as Funding Circle extra-question data, to assess eligibility or improve matching. This may include previous-year turnover, profit or loss status and amount, overdraft status, overdraft limit and overdraft amount used.

Virtual Fred automated chat assistant

We offer Virtual Fred, an automated chat assistant powered by artificial intelligence. When you chat with Virtual Fred, the messages you send — including any business or contact details you choose to provide in the conversation — are processed by our AI technology provider, Anthropic, to generate replies and to help capture your enquiry. Anthropic acts as our processor for this purpose and may process the conversation outside the UK, including in the United States, under appropriate safeguards such as standard contractual clauses.

Virtual Fred is an automated assistant, not financial advice, and it does not make any lending, eligibility or funding decision about you. Your conversations are not used to train AI models. If you would rather not use the assistant, you can complete the eligibility check directly or contact us instead.

We may contact you about your enquiry and provide service-related updates.

We may also send marketing communications about relevant business finance and business services where you have opted in or where permitted by law. You can opt out of marketing communications at any time by using the unsubscribe link in our emails or by contacting us.

Opting out of marketing will not stop us from sending service-related communications about an active enquiry.

We use cookies and similar technologies to operate our website, understand how visitors use it, improve performance, and measure advertising effectiveness.

• essential cookies needed for the site to function;
• analytics and session tools, including Microsoft Clarity, used to understand user journeys and identify technical issues;
• advertising tools, including Meta Pixel, server-side Conversions API, TikTok, Google and Taboola or similar services;
• cookies or identifiers used to remember form progress, attribution data, device information and advertising click identifiers.

Where we use session recording or replay tools, we aim to configure them so that sensitive fields, financial information and uploaded documents are masked or excluded.

Non-essential cookies and similar technologies should only be used where you have given consent, unless the law allows otherwise.

We keep personal information only for as long as necessary for the purposes described in this Privacy Notice.

• enquiry records may be kept for up to six years where needed for compliance, complaints, audit, accounting or legal purposes;
• uploaded documents are normally kept only for as long as needed to support your enquiry and transfer information to relevant partners, unless a longer period is required for legal, regulatory, fraud-prevention, complaint or audit purposes;
• temporary document-room uploads are normally retained for a short period, typically around 7 days, to facilitate transfer to relevant partners and are then deleted from temporary storage where no longer required;
• marketing records are kept until you unsubscribe or ask us to delete them, subject to suppression-list requirements;
• website analytics data is kept in accordance with the settings of the relevant analytics provider;
• complaint records may be kept for as long as needed to comply with regulatory or legal requirements.

Where we no longer need your information, we will delete it, anonymise it, or securely restrict access to it.

We use appropriate technical and organisational measures to protect personal information against unauthorised access, loss, misuse, alteration or disclosure.

• access controls;
• secure document handling;
• encryption where appropriate;
• staff and contractor access restrictions;
• secure hosting and storage providers;
• monitoring and logging;
• internal policies and procedures.

No website, system or transmission method is completely secure. We cannot guarantee absolute security, but we take reasonable steps to protect the information we process.

We use appropriate security measures and only share your information as described in this Privacy Notice.

Some of our technology providers may process personal information outside the United Kingdom. Where personal information is transferred internationally, we will take steps designed to ensure that appropriate safeguards are in place. These may include adequacy regulations, standard contractual clauses, international data transfer agreements, or other lawful transfer mechanisms.

You have rights under data protection law. These may include the right to:

• access the personal information we hold about you;
• ask us to correct inaccurate or incomplete information;
• ask us to delete your information;
• ask us to restrict how we use your information;
• object to certain uses of your information;
• request transfer of your information;
• withdraw consent where we rely on consent;
• object to direct marketing at any time;
• complain to the Information Commissioner's Office.

Some rights only apply in certain circumstances. We may need to verify your identity before responding to a request. To exercise your rights, contact us at [email protected].

You also have the right to complain to the Information Commissioner's Office if you are unhappy with how we use your information.

Where we introduce you to a broker, lender or service provider, that organisation may become responsible for how it uses your information. Those organisations will process your information in accordance with their own privacy notices, terms and procedures.

We recommend that you read the privacy notice of any broker, lender or provider before proceeding with an application, offer or service.

Carrick Capital does not make solely automated decisions that have legal or similarly significant effects on you.

Brokers, lenders and service providers may use automated tools or scoring systems to assess eligibility, affordability, fraud risk or suitability. Where this applies, the relevant organisation should explain this in its own privacy notice.

Carrick Capital is intended for business users aged 18 or over. We do not knowingly collect personal information from children.

We may update this Privacy Notice from time to time. When we make changes, we will update the Last updated date at the top of this page. Where changes are material, we may take additional steps to bring them to your attention.

If you choose to connect your business bank account, the connection is made through Plaid, an account information service provider authorised by the Financial Conduct Authority. Plaid shares your account transactions and balances with us so we can prepare a bank transaction report, verify business revenue and cash flow, and share that report with the funding partners handling your application. The connection is read only and optional: you can upload bank statements instead at any time. We disconnect the bank link automatically within 2 days of connection. We keep the transaction data for up to 90 days and the generated report for up to 7 days, after which both are deleted. You can disconnect earlier at any time through your bank or the Plaid Portal (my.plaid.com). Plaid's own privacy policy is available at plaid.com/legal.

For questions about this Privacy Notice or how we use your information, please contact:

• Lucky Growth Partners Ltd, trading as Carrick Capital
• Legal & Financial House
• 137 York Road
• Belfast
• Northern Ireland
• BT15 3GZ
• Privacy contact: [email protected]
• ICO registration: ZB966973

If your query relates to a financial services complaint rather than data protection, please contact us and we will direct you to the appropriate complaints route.